This checklist provides a structured approach to PPWR compliance for packaging producers, brand owners, and importers. It covers all major PPWR requirements with indicative deadlines.
Phase 1: Packaging Portfolio Assessment (Now)
- ☐ Inventory all packaging formats placed on the EU market by material type
- ☐ Identify packaging subject to SUP Directive prohibitions (polystyrene, etc.)
- ☐ Identify packaging subject to PPWR minimisation rules (excessive void space, etc.)
- ☐ Assess recyclability of each packaging format against current EU recyclability criteria
- ☐ Calculate current recycled content for plastic packaging
- ☐ Identify packaging in DRS scope (plastic bottles, metal cans)
Phase 2: EPR Registration (Now — ongoing)
- ☐ Register with EPR schemes in all EU member states where packaging is placed on market
- ☐ Establish annual packaging reporting processes (weight by material type)
- ☐ Pay EPR fees based on packaging quantities and eco-modulation criteria
- ☐ Register with UK EPR scheme if selling in UK market
- ☐ Register with UK Plastic Packaging Tax if manufacturing/importing plastic packaging in UK
Phase 3: Prohibited Packaging Elimination (by 2027)
- ☐ Eliminate packaging formats prohibited by PPWR minimisation rules
- ☐ Redesign e-commerce packaging to comply with void space limits (<40%)
- ☐ Remove double walls, false bottoms, and other deceptive packaging features
- ☐ Ensure all packaging serves a genuine functional purpose
Phase 4: Digital Product Passport (by 2028)
- ☐ Select a digital product passport platform or develop in-house solution
- ☐ Define data model for packaging DPP (material composition, recycled content, recyclability)
- ☐ Implement QR code or data carrier on packaging
- ☐ Establish data collection processes from packaging suppliers
Phase 5: DRS Compliance (by 2029)
- ☐ Register with national DRS operators in all relevant member states
- ☐ Pay DRS fees for plastic bottles and metal cans placed on market
- ☐ Ensure packaging design is compatible with DRS collection and sorting
Phase 6: Recycled Content Compliance (by 2030)
- ☐ Source recycled plastic meeting 30% threshold for relevant packaging categories
- ☐ Establish chain-of-custody documentation for recycled content claims
- ☐ Commission third-party verification of recycled content declarations
- ☐ Prepare recycled content declarations for packaging DPP