PPWR compliance, step by step

The eight steps

Each step produces something you can show. If a step has no output, it has not really been done — that is the simplest progress test for a PPWR project.

1. Step 1

   List the packaging you place on the EU market

   Start from products, not documents. For each product, list every packaging level — primary, grouped and transport — and every component: body, closure, liner, label, ink, adhesive. Many SKUs share one packaging system; group them now so evidence is collected once.

   Output: Packaging inventory, grouped into packaging systems

2. Step 2

   Decide your role for each packaging system

   Manufacturer, importer, distributor or fulfilment service provider. A brand owner that has packaging made to its specification and sells under its own name usually carries manufacturer obligations. Your role decides what you must hold yourself and what you may obtain from others.

   Output: Role per packaging system, with the reasoning

3. Step 3

   Identify which requirements apply — and when

   Not every requirement applies to every packaging, and not all apply yet. Separate what applies now (for example the PFAS restriction for food-contact packaging), what applies from a later fixed date, and what depends on delegated or implementing acts still to be adopted.

   Output: Requirement matrix with status: applies now, later, or conditional

4. Step 4

   Request supplier evidence per component

   Most evidence sits with suppliers. Ask per component and per requirement, for signed and dated documents, not yes/no questionnaires.

   Output: Supplier requests sent, with dates

5. Step 5

   Review what comes back and record gaps

   Check that each document names the right article, is signed and dated, and covers the requirement it is filed against. Record anything missing with its owner and request date.

   Output: Evidence register and open-gap list

6. Step 6

   Assemble the Annex VII technical documentation

   Description, components and materials, the applicable requirements, the assessment against each, and the supporting evidence — indexed and versioned.

   Output: Technical file per packaging system

7. Step 7

   Draw up and sign the EU Declaration of Conformity

   Only once the file supports it. The Declaration follows the Annex VIII model and is signed by the manufacturer under its sole responsibility.

   Output: Signed Declaration, filed with the documentation

8. Step 8

   Maintain it

   A new supplier, a changed coating, a new market or a newly adopted act can each change the file. Keep a change log and review on a schedule.

   Output: Change log and review calendar

Where to start if you are already selling

The Regulation has applied generally since 12 August 2026, so most businesses are not starting from zero — packaging is already on the market. Work in order of exposure: first packaging that falls under requirements that already apply (food-contact packaging and the PFAS restriction is the common case), then your highest-volume packaging systems, then the rest. Steps 1–3 for the whole portfolio are usually quicker than steps 4–6 for a single system, and they tell you where the real work is.

How long it takes

It depends far more on supplier responsiveness than on the number of products. A portfolio of a few packaging systems with cooperative suppliers can move quickly; one component with an unresponsive supplier can hold up a file for weeks. Plan around step 4, and send supplier requests early — see the supplier evidence request.

Doing it yourself or with help

Every step can be done in-house. Where internal time is the constraint, our technical documentation service covers steps 1–7 for an agreed scope, and ongoing management covers step 8. The manufacturer still signs the Declaration.

This page is general information about Regulation (EU) 2025/40, not legal advice.