Practical To-do List — Step by Step to PPWR Compliance

1. What this guide is about

This guide is intended for customers who act as producers under the PPWR and have little experience with packaging regulations to date. It shows in a sensible order what needs to be done first, what next, and what on an ongoing basis.

2. To-do list for the producer — in the right order

Click on the round checkmark to mark a step as complete — saved automatically. Clicking on the tile jumps to the details.

1. 1 Clarify role and responsibility
2. 2 Check national registration and EPR duties
3. 3 Create a packaging inventory
4. 4 Obtain supplier documents
5. 5 Assess each packaging technically
6. 6 Create technical documentation per packaging
7. 7 Prepare the EU declaration of conformity
8. 8 Prepare labelling and digital information
9. 9 Set up ongoing change management

Clarify role and responsibility

• Check whether you act as a producer and / or manufacturer under the PPWR.
• Determine which packaging or packaged products you are responsible for.
• Check in which countries you first place packaging on the market and where EPR obligations arise.
• Assign responsibility internally in writing to a person or department.

Check national registration and EPR duties

• Registration in the LUCID packaging register.
• If packaging subject to system participation is affected: conclude a contract with an approved dual system.
• Quantity reports to LUCID and to the dual system must be identical.
• If applicable, check early for other EU countries whether additional EPR registrations are required there; the specific harmonized EU register formats will be further specified by implementing and delegated acts.

Create a packaging inventory

• Record each individual packaging or packaging variant in a list.
• Now assign a fixed internal packaging ID so that all documents can be clearly assigned later.
• Recommended columns for the packaging list: article number, description, packaging type, main material, secondary materials, weight, supplier, scope of use, country of first supply, PPWR documents available yes / no.

Obtain supplier documents

• Request material data and weights for each packaging.
• Request information on heavy metals and — if relevant — PFAS.
• Obtain technical specifications and, if possible, information on recyclability.
• Important for 2028: Also request recycled content and existing conformity or test documents.

Assess each packaging technically

• Check packaging for minimisation — i.e. not larger, heavier or more material-intensive than necessary.
• Check substance restrictions, in particular heavy metals.
• For food contact packaging, check PFAS thresholds and substance use separately.
• Check how well the packaging can be collected, sorted and recycled.
• Already now reduce problematic material combinations.

The PPWR requires, among other things, design for recycling, minimisation, substance conformity and technical evidence. The exact methodology will be specified in parts by supplementary EU legislation.

Create technical documentation per packaging

• Create a separate file or digital folder for each packaging.
• Place drawings or photos, material lists, weights, supplier certificates, test reports and assessment documents in it.
• Document changes to material, weight, supplier or labelling in a traceable manner.
• Use uniform file names and a fixed document structure if possible.

Prepare the EU declaration of conformity

• Prepare an EU declaration of conformity for each affected packaging based on the technical documentation.
• Include packaging identification, manufacturer data, material description, legal reference and date.
• If applicable, provide for internal approval by quality, procurement or regulatory affairs.

The regulation designates the EU declaration of conformity as the central proof document. The PPWR has applied since 12.08.2026; individual detail requirements also depend on further legislation.

Prepare labelling and digital information

• Check what labelling requirements apply to the respective packaging.
• Make provision for future harmonised sorting or digital information.

Set up ongoing change management

• Update documentation when material, supplier, coating, label, adhesive or weight changes.
• Check whether the conformity assessment and declaration need to be updated.
• Conduct a brief PPWR approval check before each new introduction.