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From today onwards, live: the PPWR has entered into force – here is the compliance checklist

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What You Need to Know About Today

The entry into force of the PPWR does not mean an obligation to be fulfilled overnight, but rather the starting point of a process. The European Commission has made it clear that the primary role of authorities is awareness-raising and providing opportunities for correction, not immediate sanctioning. However, this does not mean that companies should not strive for compliance as soon as possible.

It is important to keep in mind, on one hand, that there is no grace period for the PFAS ban. This means food-contact packaging must comply with the limit values starting today, regardless of when it was manufactured. On the other hand, products currently in stock and placed on the market before August 12 can continue to be sold freely, with no obligation for recall.

What is mandatory today and what is not?

Applicable starting today:

  • Compliance with PFAS limit values in food packaging

  • Heavy metal concentration limit values for all packaging

  • General obligation to minimize hazardous substances

  • Manufacturer and importer identification obligations (name, address on the packaging or accompanying document)

  • Unique packaging traceability (type, batch, or serial number)

  • EU Declaration of Conformity for every new packaging type

  • Completion of the conformity assessment (technical documentation) procedure

Not yet mandatory (2030 deadlines):

  • Recyclability requirements (DfR-based)

  • Mandatory recycled content in plastic packaging

  • Packaging minimization requirements

  • Empty space ratio for transport and e-commerce packaging

  • Reuse targets

PPWR Compliance Checklist

The following list is based on the obligations taking effect on August 12. It is not a legal checklist, but a practical first step to assess where you stand.

Note: This is designed as a foundational audit to help companies pinpoint immediate regulatory gaps.

  • ✅ 1. Identifying Involvement and Role

    • Have we determined whether our company is a manufacturer, importer, or distributor under the PPWR (or involved in multiple roles)?

    • Have we identified which packaging types (sales, grouped, transport, e-commerce) our obligations apply to?

    • If using branded packaging: Have we clarified whether the company with the name/trademark or the physical manufacturer is considered the manufacturer under the PPWR?

  • ✅ 2. PFAS Compliance (for food-contact packaging)

    • Have we assessed whether our packaging contains PFAS (greaseproof paper, certain coated boxes, microwave packaging, etc.)?

    • Do we have a supplier declaration or laboratory test result regarding the PFAS content?

    • If we lack certification: Have we ordered the necessary testing from a laboratory?

  • ✅ 3. Heavy Metal Compliance

    • Do we have supplier documentation confirming that the combined concentration of lead, cadmium, mercury, and hexavalent chromium in our packaging does not exceed the 100 mg/kg limit?

  • ✅ 4. Manufacturer and Importer Traceability

    • Does every packaging placed on the market starting today (or its accompanying document) display the manufacturer’s name, registered trade name, or trademark and postal address?

    • As an importer: Do our own name and contact details appear on the imported packaging or accompanying document?

  • ✅ 5. Unique Package Traceability

    • Does every packaging type feature a type number, batch number, or serial number (or at least one of these on an accompanying document)?

    • Can this identifier be linked to the relevant EU Declaration of Conformity?

  • ✅ 6. EU Declaration of Conformity

    • Have we prepared the EU Declaration of Conformity for every packaging type?

    • Does the declaration include the packaging identifier, relevant PPWR articles, and the assessment method applied?

    • Was the declaration drafted in the language of the member state where the packaging is placed on the market?

    • Have we prepared the declaration and related technical documentation for retention—5 years for single-use packaging and 10 years for reusable packaging?

  • ✅ 7. Supply Chain and Documentation

    • Have we received all necessary information and documentation for compliance from our suppliers?

    • If our supplier cannot or will not provide it: Have we filled in the missing data from alternative sources (e.g., our own testing)?

    • In case of imports: Have we verified that the third-country manufacturer performed the conformity assessment and issued the declaration?

  • ✅ 8. Warehouse Inventory Management

    • Have we identified which stocks were placed on the market before August 12 (as the PPWR does not apply retroactively to these)?

    • Have we prepared an accompanying document for packaging manufactured before August 12 but still in stock to fulfill the manufacturer identification obligation?

  • ✅ 9. Internal Responsibility and Processes

    • Have we designated the person or team responsible for PPWR compliance within the company?

    • Are the procurement, legal, and packaging design areas aware of the obligations effective starting today?

    • Do we have a monitoring process in place to track implementing acts and guidelines issued by the Commission (especially regarding the 2030 deadlines)?

What comes next?

Today is just the beginning, not the end. The second, much larger wave of PPWR obligations arrives on January 1, 2030. This is when requirements for recyclability assessment, mandatory recycled content, packaging minimization, and the fulfillment of reuse targets take effect. That is less than three and a half years away, but the planning, portfolio assessment, and supply chain transformation required to achieve compliance are worth starting right now.

If you need help completing the checklist above or planning for your 2030 readiness, the team at Planet Fanatics’ Network Kft. is available as a consulting partner.

Stuck or unsure how to begin? We can help!

PPWR compliance is not a one-off task, but a long-term process. The recently published FAQ highlights how many detailed questions require precise answers.

Planet Fanatics’ Network Kft. is prepared as an accredited sustainability consultancy precisely to address these questions, supporting our partners in fast and efficient preparation, transition, and ultimate compliance.

What we can do right away:

  • PPWR Impact Assessment: We identify which products, packaging types, and roles in your packaging portfolio fall under the obligations effective from August 12. We map out PFAS risks, the question of manufacturer status, and traceability gaps, and formulate a concrete action plan to achieve compliance if needed.

  • Regulatory Monitoring Service: We continuously track implementing acts, guidelines, and FAQ updates published by the European Commission and domestic authorities so our partners are always notified in time if anything changes.

[Get in touch with us →]

Related Sources: * PPWR Frequently Asked Questions – 2nd edition, DG ENV, August 2026