Only around 100 days left until the new EU Packaging and Packaging Waste Regulation (PPWR) takes effect - and your packaging portfolio is not yet fully PPWR-ready?

This guide gives you a practical last-minute PPWR checklist that leads you through the final weeks before the deadline in a structured way - organized by priority, time required, and responsibilities. For a detailed introduction to PPWR objectives, scope, and obligations, see the PPWR Guide 2026.

The PPWR (Regulation (EU) 2025/40) has been in force since 11 February 2025 and becomes binding for packaging in the EU from 12 August 2026. From this date onwards, all newly placed packaging types require a valid PPWR Declaration of Conformity (DoC). Without a structured plan, you risk loss of market access, fines, and last-minute crisis projects.

What You Will Take Away From This Guide

By the end of this article, you will know:

  • which minimum requirements you must implement in the final 100 days before PPWR applies,
  • how to create a prioritized PPWR checklist for your business,
  • which packaging regulations (DoC, recyclability, substance restrictions, labelling) are especially relevant now,
  • how to close data gaps efficiently - ideally with digital packaging management instead of Excel,
  • Note: This guide does not replace legal advice. It helps you set up a structured organizational and data approach.

Prerequisites: What You Need Before You Start

Before you begin working through the 100-day checklist, you should have the following basics in place:

  • A person responsible for PPWR compliance (e.g. Head of Packaging, Sustainability Lead, Regulatory/QA)
  • A list of your packaging types (SKU groups are sufficient): sales, secondary, transport, and e-commerce packaging
  • Access to the current PPWR requirements for your business model (e.g. Legal/Regulatory, internal guideline)
  • At least one central data source for packaging specifications (PIM/PLM/ERP, an Excel master file, or a digital packaging management system such as Packa)
  • Clarity on which external partners you need to involve (suppliers, contract packers, laboratories, potentially consultants)

Tip: If you do not yet have a structured status overview, start with a compact PPWR checklist to spot your highest-risk areas immediately.

Step-by-Step Through the Final 100 Days

The following steps build on one another in terms of content. In practice, many tasks will run in parallel - what matters is that all blocks are completed by the deadline.

1. Clarify Scope and Responsibilities in 10 Days

Goal: You know which packaging is subject to which PPWR obligations - and who is responsible internally.

  1. Assign roles under PPWR
    Clarify when your company acts as a producer (placing on the market), manufacturer, importer, or distributor. The PPWR sets out clear obligations for these roles, such as design, documentation, and EPR financing.

  2. Define your packaging scope

    • Primary packaging (food/non-food)
    • Secondary and tertiary packaging
    • E-commerce packaging
    • Private label vs. own brands

  3. Create a responsibility matrix (RACI)
    Define who is Responsible and Accountable, for example:

    • Procurement: supplier data and contracts
    • Packaging engineering: specifications and design
    • Sustainability/Regulatory: assessment of sustainable packaging and PPWR interpretation
    • Quality/Legal: approval of Declarations of Conformity

Common pitfall: "PPWR is a sustainability topic, everything else stays as it is."
Procurement, packaging engineering, quality, and legal are equally affected. Without alignment, critical packaging may remain invisible until the deadline.

2. 20 Days: Packaging Inventory and Identify Data Gaps

Goal: You know which packaging lacks relevant data - and can steer follow-up actions in a targeted way.

  1. Consolidate your packaging inventory Use product master data, EPR reporting lists, and purchasing data. The aim is to create a binding master list (you do not need every SKU individually).

  2. Define a minimum data set per packaging type:

    • Material composition (including layers, coatings, adhesives)
    • Weight of each component
    • Suitability for food contact / non-food
    • Recycled content (where relevant)
    • Relevant certificates (e.g. Declarations of Conformity, test reports)

  3. Flag data gaps
    Mark where information is missing or only exists as a PDF/email.
    In many companies, 30-70% of packaging records lack critical information - especially on material structures, recycled content, and additives.

Tip: With Packa for digital packaging management, you can spot gaps directly in the dashboard or via automated completeness checks.

3. Translate PPWR Requirements to Your Portfolio (Approx. 10 Days)

Goal: You know which PPWR requirements apply to which packaging categories.

In the last 100 days, focus on these areas:

  • Recyclability according to EU criteria (mono-materials, composites, sortability and recyclability)
  • Packaging minimization (e.g. empty space limits in e-commerce)
  • Substance restrictions (especially heavy metals, additives, PFAS in food contact packaging)
  • Recycled content quotas for specific plastic applications
  • Labelling and QR/Digital Product Passport data (where relevant)
  • Declaration of Conformity (DoC) and technical documentation

Classify each packaging family as critical, unclear, or low risk to set priorities.

Common pitfall: Focusing on "sustainable packaging" in marketing without legally robust evidence. The PPWR requires verifiable data.

4. Supplier Data Offensive (Days 70-40)

Goal: You close as many data gaps as possible via standardized supplier requests.

  1. Introduce standardized questionnaires At minimum, request:

    • full material composition (including coatings, adhesives, additives)
    • PPWR-relevant substance restrictions (e.g. heavy metals, PFAS)
    • available test reports and certificates
    • information on recyclability according to recognized methods

  2. Define a communication and deadlines plan

    • Prioritize key suppliers (by spend, volume, risk)
    • Set clear response deadlines and escalation steps (e.g. 14/28 days)

  3. Use digital workflows Scattered Excel files and email requests become a risk under PPWR, because you must provide article-level data.
    Platforms such as Packa automate supplier requests, standardize forms, and store responses in a traceable way.

Tip: Link your requests directly to the PPWR project plan: "No new orders without complete data by date X" often drives the fastest response.

5. Assess Recyclability and Critical Substances (In Parallel, 20-40 Days)

Goal: You identify short-term showstoppers - particularly recyclability and PFAS.

  1. Assess recyclability in a structured way

    • Use recognized methods/guidelines (national or industry standard).
    • Document method, assumptions, and result for each packaging family.

  2. Check PFAS risk (food contact) From 12 August 2026, food contact packaging containing PFAS above defined limits will be banned in the EU. Focus on: grease-resistant paper packaging, coated boards, multilayer composites, and critical plastics.

  3. Derive an actions list

    • Packaging with no recyclability: start medium-term redesign projects
    • PFAS risks: explore alternative materials, plan test programs, manage existing stocks

Common pitfall: Treating PFAS as "the supplier's problem." Under PPWR, the party placing the product on the market is liable.

6. Define Your Structure for Declarations of Conformity (DoC) (Days 60-30)

Goal: You define how DoCs are structured and how many you need.

  1. Decide on the level of granularity Each distinct packaging variant (material, size, design) requires its own PPWR Declaration of Conformity.
    Group into packaging families to gain efficiency.

  2. Specify mandatory content
    According to the PPWR annex, DoCs must include:

    • a unique number
    • manufacturer/producer details
    • precise packaging identification
    • formal statement of conformity (Art. 5-12)
    • reference to technical documentation and assessment methods
    • name, role, date, and signature of the authorized person

  3. Use a template
    Standardize the structure of your DoCs. You can find a sample via the PPWR Declaration of Conformity template.

Tip: Pilot 5-10 critical packaging families to refine workflows and templates.

7. Consolidate Technical Documentation and Evidence (Days 50-20)

Goal: Each DoC is backed by a coherent documentation set.

  1. Define your documentation structure
    For each family, you should have:

    • material and construction data
    • supplier declarations, certificates
    • test results (migration, mechanical performance, recyclability)
    • assessment methods/calculations (e.g. empty space)
    • history/version control

  2. Plan retention periods Technical documentation for DoCs must typically be retained for 5 years (single-use) or 10 years (reusable).

  3. Document digitally For large portfolios, manual DoC and document management quickly becomes inefficient. Digital platforms enable secure storage, search functions, permission management, and audit trails.

Common pitfall: Treating the DoC and the technical file separately. Authorities check the evidence and its plausibility - not just the form.

8. Pilot DoCs, Approve Internally, and Close Gaps (Days 40-10)

Goal: The first internally approved DoCs are in place - and remaining gaps are visible.

  1. Create pilot DoCs Select 5-10 key families (highest volume, complexity, brand impact) and create full DoCs, including technical documentation.

  2. Establish an internal review process

    • Legal/Compliance: check liability-relevant statements
    • Quality/Technical: confirm technical assessments
    • Procurement: verify supplier data and contracts

  3. Embed lessons learned

    • Adjust checklists, templates, and governance
    • Define responsibilities (sign-off, updates)

  4. Rollout plan for the portfolio Prioritize by risk: start with high-volume, critical packaging, then move on to niche products.

Tip: Track openly which DoCs are final, under review, or still in development. Transparency is better than evasive documentation.

9. Final 10 Days: PPWR Dress Rehearsal and Governance From Go-Live

Goal: You are compliant by the deadline and have clear processes for ongoing operations.

  1. Simulate an authority audit request

    • Which packaging would likely be in scope?
    • How quickly can you provide DoC and documentation per SKU?
    • Are responsibilities and deputies clearly defined?

  2. Fix your governance model from day one

    • What triggers a DoC review?
    • Who monitors certificates/test reports?
    • How are new projects integrated in line with PPWR?

  3. Connect to EPR and national packaging law The PPWR complements national regulations such as the German Packaging Act and EPR schemes. Align your data and role definitions so that PPWR compliance and EPR reporting are based on the same packaging data.

  4. Monitoring and continuous improvement Treat PPWR as an ongoing system:

    • regular portfolio reviews
    • KPIs on data quality, recyclability, and EPR fees
    • integration into your sustainability and cost strategy

Typical Blockers in the Last 100 Days - and How to Solve Them

Blocker 1: Suppliers do not respond in time Set clear deadlines and link them to purchasing decisions. Digital supplier workflows with automated reminders significantly increase response rates.

Blocker 2: Data chaos in Excel and emails Moving to a central packaging data system pays off quickly. Modern packaging management platforms collect supplier data automatically, verify recycling requirements, and generate audit-ready reports in real time.

Blocker 3: Uncertainty about whether evidence is sufficient Work with standardized methods and document assumptions and sources. For PFAS or complex multilayer structures, commission lab tests where necessary - prioritized by risk.

Next Steps: From Last-Minute Fix to Ongoing PPWR Compliance

Once you enter the "100-day phase" towards the Packaging Regulation 2026, every week counts. The good news: with a clear, data-driven approach, you can address risks in time. For an in-depth step-by-step guide to obligations, transition periods, and practical examples, see the PPWR Guide 2026.

Next steps:

This way, a last-minute reaction becomes a robust foundation for sustainable packaging, transparent risk and cost control, and long-term PPWR compliance.

Talk to Packa

FAQ: Common Questions in the Last 100 Days Before PPWR

Does the 12 August 2026 deadline apply to all packaging or only new products?

From 12 August 2026, the PPWR requires a valid Declaration of Conformity for every packaging type newly placed on the EU market. Stocks that were placed on the market lawfully before that date generally fall under transitional rules - confirm details with your legal team.

Do I need a separate Declaration of Conformity for every SKU?

No, not necessarily for every single SKU. In most cases, each distinct packaging variant (material, size, design) requires its own DoC. Multiple SKUs can share one DoC if they belong to the same packaging type.

Is an Excel list sufficient as a system for PPWR compliance?

In the short term, you can use Excel to build an initial overview. In the long term, detailed requirements, evidence and retention obligations, plus ongoing updates, will make reporting unreliable and inefficient. For larger portfolios, a dedicated digital packaging management system is essential.

How detailed do our recyclability assessments need to be?

PPWR expects traceable assessments at packaging level, not just qualitative statements. Use recognized methods and document material structure, assumptions, test methods, and results. "Assumed recyclability" without robust data will be heavily scrutinized in audits.

What happens if a Declaration of Conformity is missing or incomplete?

If a valid, complete PPWR Declaration of Conformity is missing, the packaging is considered non-compliant - with risks for audits, market access, and sanctions. Treat the DoC as a central compliance document, not as a "form in the appendix."