PPWR packaging self-assessment

Article 15; Article 5–12; Article 35–39; Annexes VII–VIII

Article 21; Article 15

Article 18; Article 16

Article 44–48; Article 56

Article 45; Article 47

Article 19; Article 21

Article 45; Article 19

Article 21; Article 19

Article 50; Annex X; Article 68

Article 11; Article 29–33

Article 5–7

Article 5–6; Article 10

Article 5–6

Article 5–6; Article 11

Article 5–7

Article 6; Article 8; Annex II

For each role, review the specific actions, required evidence and references to PPWR provisions.

The self-assessment shows which obligations require further checking. This stage identifies the specific obligations and the actions needed to fulfil them.

• Review the obligation cards relevant to your case, such as those for the manufacturer, importer, distributor, EPR producer, online marketplace provider, deposit return system or reuse.
• For each obligation, check three things: what must be done, which data or documents prove fulfilment, and which PPWR provision creates the obligation.
• Avoid checking the same requirement repeatedly. If compliance was already checked earlier in the supply chain, use the existing data and evidence instead of recreating it.
• Ensure fulfilment can be demonstrated by retaining the necessary data, declarations of conformity, technical documentation, registrations, contracts and internal procedures.

Basis: Regulation (EU) 2025/40 (PPWR). Always check the official text and future applicable EU and national legislation.

The manufacturer must ensure that the packaging complies, carry out the required conformity assessment, prepare technical documentation and an EU declaration of conformity, and take the necessary corrective measures in the event of non-compliance.

A manufacturer may place on the market only packaging that complies with the requirements laid down in or pursuant to Articles 5–12 of the PPWR. Depending on the packaging, the assessment must cover, among other things, substances in the packaging, recyclability, minimum recycled content in plastic packaging, compostability, packaging minimisation, reuse, and marking and information requirements.

Before placing packaging on the market, the manufacturer must carry out, or have carried out on its behalf, the conformity-assessment procedure laid down in Article 38 of the PPWR. The assessment demonstrates that the packaging complies with the requirements applicable to it.

The manufacturer must prepare technical documentation in accordance with Annex VII to the PPWR. It identifies the requirements applicable to the packaging and describes its design, manufacture and operation to the extent necessary. Where relevant, it includes a description of the packaging and its intended use, component materials, technical specifications, standards used, descriptions of assessments and test reports.

Once conformity assessment has demonstrated compliance with the applicable requirements, the manufacturer draws up the EU declaration of conformity under Article 39 and Annex VIII to the PPWR. The declaration must identify the packaging, and by drawing it up the manufacturer assumes responsibility for the packaging's compliance with the PPWR.

The manufacturer must ensure packaging traceability. The packaging must bear a type, batch or serial number or another mark that enables it to be identified. The manufacturer's name, registered trade name or registered trade mark and postal address, and where possible electronic contact details, must also be provided. If the information cannot be placed on the packaging, the PPWR provides alternative ways to supply it.

If a manufacturer considers or has reason to believe that packaging it has placed on the market does not comply with the applicable PPWR requirements, it must immediately take the necessary corrective action. As appropriate, the packaging must be brought into conformity, withdrawn or recalled. The market-surveillance authority of the Member State concerned must also be informed of the suspected non-compliance and the measures taken.

The manufacturer must retain the technical documentation and EU declaration of conformity for five years for single-use packaging and ten years for reusable packaging from the date on which it is placed on the market.

PPWR basis: Article 15; product requirements in Articles 5–12; conformity in Articles 35–39 and Annexes VII–VIII.

Packaging compliance is assessed separately against each applicable PPWR requirement rather than only as a whole.

PPWR basis: Articles 5–12; Article 24 on empty space; Article 12 on labelling.

The substance limits laid down in the PPWR that an economic operator can verify for its packaging are set out here.

The sum of the concentration levels of lead, cadmium, mercury, and hexavalent chromium resulting from substances present in packaging or packaging components must not exceed 100 mg/kg.

From 12 August 2026, food-contact packaging must not be placed on the market if it contains PFAS substances at or above the following limit values: 25 ppb for any individual PFAS substance, measured using targeted PFAS analysis (polymeric PFAS substances are excluded from quantification); 250 ppb for the sum of PFAS substances, measured as the sum of targeted analyses, where applicable with prior degradation of precursors (polymeric PFAS substances are excluded from quantification); 50 ppm for PFAS substances, including polymeric PFAS substances.

If the total fluorine content exceeds 50 mg/kg, evidence must be provided to the manufacturer or importer at their request showing how much of the measured fluorine derives from PFAS substances and how much derives from non-PFAS substances. This information is used to prepare the technical documentation under Annex VII to the PPWR.

Packaging must be manufactured so that the presence and concentration of substances of concern in packaging material and packaging components are minimised. This also concerns the presence of those substances in emissions and waste-management outputs and the adverse environmental impact caused by microplastics. Article 5(1) of the PPWR does not establish a single list of numerical limits for all substances of concern.

PPWR basis: Article 5. Note: REACH and the legislation on food-contact materials also continue to apply.

• No transitional sell-through period is provided for stocks of PFAS-containing food-contact packaging. Packaging placed on the market from 12 August 2026 must comply with the PPWR PFAS limits regardless of its date of manufacture.

The EU declaration of conformity is drawn up on the basis of the evidence contained in the technical documentation, so the same data need not be compiled separately again.

The technical documentation must make it possible to assess the packaging's conformity with the PPWR requirements applicable to it. The documentation must identify the applicable requirements and, where relevant, include among other things: a general description of the packaging and its intended use; information on packaging design and manufacture; the materials of packaging components; the harmonised standards, common specifications, and other technical specifications applied; descriptions of the assessments under Articles 6, 10, and 11; and test reports. The technical documentation must also include an appropriate analysis and assessment of the risks of non-compliance.

Where the conformity assessment has demonstrated that the packaging complies with the applicable requirements, the manufacturer draws up an EU declaration of conformity. The declaration must follow the model set out in Annex VIII and clearly identify the packaging for which it was drawn up. Under Annex VII to the PPWR, a written declaration of conformity is drawn up for each packaging type.

The EU declaration of conformity must be based on the conformity assessment and be consistent with the technical documentation. The packaging, applicable legislation, standards, and other technical specifications named in the declaration must be traceable to the documentation demonstrating conformity.

The EU declaration of conformity must be kept continuously up to date. If the packaging design or characteristics change, or if a harmonised standard, common specification, or other technical specification used in the conformity assessment changes, and the change may affect the packaging's conformity, a new conformity assessment must be carried out.

PPWR basis: Articles 35–39; Annexes VII and VIII.

For each packaging type, prepare an internal technical record containing the technical data and evidence needed to assess conformity.

Technical data must be up to date and verifiable and must be based on reliable sources and evidence.

A large share of the information needed to demonstrate packaging conformity comes from suppliers. The manufacturer must ensure that the necessary information and documents have been obtained from suppliers and are suitable for demonstrating conformity.

Request from the supplier the information needed to demonstrate the packaging's compliance, such as: material type and material composition, the mass of the packaging or packaging component, the content of substances of concern and other relevant substances, surface treatments and other treatments, material data for packaging components and, for food-contact packaging, relevant food-contact information. The scope of the information requested depends on which PPWR requirements must be demonstrated for the particular packaging.

The supplier's technical data and specifications, declarations provided by the supplier, test reports, and other documents demonstrating compliance. The contract may also specify which information and documents the supplier must provide, but the contract itself does not automatically demonstrate the packaging's compliance.

If the information needed to demonstrate compliance contains confidential business information, it must be appropriately protected while ensuring that the necessary information remains available to demonstrate compliance. In general, the PPWR does not simply give a supplier the right to submit the required information confidentially.

A change-notification procedure should be agreed with the supplier so that the company can assess whether a change in a material, packaging component, composition, production process, or other relevant characteristic affects the packaging's compliance. Important: a change of supplier or process does not in itself automatically mean non-compliance—the impact of the change must be assessed.

Relevant data and evidence received from the supplier are taken into account in the conformity assessment and, where necessary, included in or linked to the technical documentation. They are used to demonstrate the packaging's compliance with the applicable requirements and to draw up the EU declaration of conformity.

Related PPWR provisions: Article 15, Articles 38–39, and Annexes VII–VIII.

If you determine the characteristics of the packaging or place packaging or a packaged product on the market under your own name or trademark, it must be established to whom the manufacturer's obligations apply, including those relating to conformity assessment, technical documentation, and the EU declaration of conformity.

Check whether you are considered a manufacturer under the PPWR. If a distributor or importer places packaging on the market under its own name or trademark, the manufacturer's obligations apply to it in the cases specified in the PPWR.

Adding an ordinary shipping or logistics label to standard packaging does not in itself mean that the packaging is placed on the market under the economic operator's own name or trademark. What matters is the purpose of the label and whether the economic operator presents the packaging or packaged product under its own name or trademark.

Check separately whether you are considered a producer within the meaning of the PPWR for the application of extended producer responsibility (EPR), and which registration, reporting, and other EPR obligations apply in Estonia.

Clearly agree with the manufacturer, packaging supplier, or contract manufacturer:

who will provide the necessary technical data and evidence, who will prepare and update the technical documentation and the EU declaration of conformity, and how changes affecting the packaging's compliance will be communicated.

PPWR basis: Article 21; Article 15; Articles 44–45 where EPR applies.

Before placing packaging from a third country on the market, the importer must ensure that the manufacturer has fulfilled the conformity-assessment and documentation obligations required by the PPWR and that the packaging meets the requirements the importer must check.

Before placing packaging on the market, the importer must check that the manufacturer has carried out the required conformity assessment and drawn up the technical documentation. It must also be checked that the packaging is properly labelled and accompanied by the required documents and the manufacturer's identification details.

Documents and data to be checked: the EU declaration of conformity, technical documentation, the manufacturer's identification and contact details, and data enabling the packaging to be traced.

Check that the documents and identification details can be linked to the specific packaging being imported and that the packaging labelling meets the requirements.

In the context of the PPWR, it is more accurate to refer to packaging labelling, packaging components, and packaging identification rather than product ingredients.

If the importer considers or has reason to believe that packaging does not comply with the applicable PPWR requirements, it must not place the packaging on the market until it has been brought into compliance.

If non-compliant packaging has already been placed on the market, the importer must take the necessary corrective measures and, where appropriate, withdraw or recall the packaging and inform the relevant market-surveillance authority.

If an economic operator makes packaging or a packaged product available on the market in Estonia for the first time, it must be checked separately whether it is considered an EPR producer in Estonia and which extended producer responsibility obligations apply to it.

PPWR basis: Article 18; Article 21 if the importer acts under its own trademark or modifies the packaging.

A distributor does not assume the manufacturer's obligations, but must check the required information and labelling before making packaging available on the market, and must not make non-compliant packaging available on the market.

Before making packaging available on the market, the distributor must check that:

the producer with EPR obligations for the packaging is registered in the register of producers referred to in Article 44;

the packaging is labelled in accordance with Article 12;

the manufacturer has fulfilled the requirements for providing packaging identification and manufacturer details laid down in Article 15(5) and (6);

where applicable, the importer has provided the identification and contact details required by Article 18(3).

If the distributor considers or has reason to believe that packaging does not comply with the requirements laid down in or pursuant to Articles 5–12 of the PPWR, it must not make the packaging available on the market until it has been brought into compliance.

If the packaging has already been made available on the market and non-compliance is identified, the distributor must ensure that the necessary corrective measures are taken and, where appropriate, that the packaging is withdrawn or recalled. The relevant market-surveillance authorities must also be informed of the suspected non-compliance and the measures taken.

If a distributor places packaging on the market under its own name or trademark, or modifies packaging already placed on the market in a way that may affect its compliance with the PPWR requirements, it is considered a manufacturer and the manufacturer's obligations under Article 15 apply to it.

PPWR basis: Article 19; Article 21 in the event of a change of role.

If you are an EPR producer, you must register, submit the required reporting data, fulfil the EPR obligations, pay the required financial contributions, and be able to demonstrate fulfilment of those obligations.

Register in the register of producers in each Member State where you make packaging or a packaged product available on the market for the first time, or where you unpack a packaged product without being the end user. The information required by Article 44 and Part A of Annex IX to the PPWR must be provided upon registration. A producer must not make packaging or a packaged product available on the market in the territory of a Member State for the first time unless it, or where applicable its authorised representative for EPR, is registered in that Member State.

Submit to the register of producers the data required by Part B of Annex IX to the PPWR on packaging made available on the market for the first time. Reporting includes, among other things, the reporting period and the quantities by mass of the relevant packaging categories. The precise level of detail of the data to be submitted depends on Article 44, Annex IX, and the implementing rules adopted pursuant to them.

Fulfil extended producer responsibility obligations through the EPR system operating in the relevant Member State, either individually or through a producer responsibility organisation, in accordance with the PPWR and the Member State's requirements. Article 45 of the PPWR imposes extended producer responsibility on a producer for packaging that it makes available on the market in a Member State for the first time or that it unpacks without being the end user.

Pay the applicable EPR financial contributions and retain data and documents evidencing registration, reporting, and fulfilment of EPR obligations. Depending on the national system, evidence may include registration details, an agreement with a producer responsibility organisation and a certificate issued by it, submitted reports, and documents proving payment of financial contributions. Annex IX to the PPWR also requires information upon registration about how EPR obligations are fulfilled.

Notify the competent authority responsible for the register without undue delay of any changes to the information provided upon registration and if you cease making the relevant packaging or packaged product available on the market in the Member State for the first time.

PPWR basis: Articles 44–48; Article 56 on reporting.

Accurate EPR records help ensure that packaging is reported in the correct Member State and the correct packaging category, while preventing double counting and omissions from reporting.

PPWR basis: Articles 44–48 and 56.

For distance sales and logistics, the economic operator's role, the packaging used, and the related PPWR obligations must be assessed separately.

Check whether the company makes packaging or packaged products available directly to end users in Estonia through distance sales and whether it thereby assumes the role of an EPR producer in Estonia. For distance sales, the Member State in which the end user is located and whether the economic operator makes the packaging or packaged product available there for the first time are relevant.

If sales take place through an online marketplace, determine whether the company is the marketplace provider or itself sells packaging or packaged products. Check the PPWR obligations associated with the relevant role. Placing on the market under one's own name or trademark should be assessed separately from the perspective of the manufacturer's role.

If packaging or packaging components are added in the course of a fulfilment service, check which economic operator is subject to the EPR and other PPWR obligations relating to that packaging. If existing packaging is modified, it must also be assessed whether the modification may affect the packaging's compliance.

Check who the EPR producer is in Estonia, whether it is properly registered, and whether the registration, reporting, and other EPR obligations have been fulfilled.

PPWR basis: definitions and Articles 44–45; Article 21 where a trademark or modification is involved.

In addition to the packaging material, the applicable requirements depend on the type of packaging, how it is used, and whether it is covered by a deposit return, reuse, or refill system.

Check whether the beverage packaging falls within the deposit return system and which deposit, marking, return and system-participation requirements apply.

The PPWR provides that by 1 January 2029 Member States must ensure separate collection of at least 90% of single-use plastic beverage bottles and metal beverage containers up to three litres, using a deposit return system in the cases laid down in the Regulation. Article 50 also contains exemptions.

If packaging is treated as reusable packaging, check that it meets the reusable-packaging requirements and is used in a compliant reuse system.

Under the PPWR, merely calling packaging reusable is insufficient. The packaging must meet the reusable-packaging requirements in Article 11 and the reuse system must meet Article 27 and Annex VI. The system must allow the packaging to circulate and undergo repeated use cycles, or rotations.

Where refill is offered, check the refill rules, requirements for the containers used, hygiene requirements, information supplied to consumers and the refill station's compliance with the PPWR.

Article 28 of the PPWR requires, among other things, that end users receive information on permitted container types and hygiene requirements and that refill stations comply with Annex VI, Part C.

Retain data and documents demonstrating fulfilment of the applicable requirements, such as the reuse-system description and rules, records of packaging uses and returns, refill instructions and agreements between system participants.

PPWR basis: Article 11; Articles 29–33 on reuse/refill where applicable; Article 50 and Annex X on deposit return systems.

Incomplete or disorganised packaging data may prevent compliance from being demonstrated and cause problems when placing packaging on the market and throughout the supply chain.

Member States establish penalties applicable to infringements of the PPWR. The penalties must be effective, proportionate and dissuasive.

Article 68 requires Member States to establish those rules by 12 February 2027. For infringements of Articles 24–29, penalties must also include administrative fines or fines of equivalent effect under the Member State's legal system.

Non-compliant packaging must not be placed or made available on the market unless the compliance required by the PPWR has been ensured. Corrective action, withdrawal or recall may be required for packaging already placed on the market.

An EPR producer must ensure correct registration, reporting and fulfilment of extended producer responsibility obligations in every Member State where they apply.

Incomplete or incorrect data can cause EPR registration and reporting errors and leave obligations unfulfilled.

The PPWR requires producer registration and reporting of packaging quantities in the relevant Member State and fulfilment of EPR obligations under Article 45.

Proper registration, reporting and fulfilment of EPR obligations support packaging-waste prevention, separate collection, recycling and reuse.

PPWR basis: Article 68 and obligations throughout the packaging life cycle.

• Operator role — I have confirmed the operator role or roles identified in the self-assessment.
• Packaging — I have linked the obligations to the packaging type.
• Material — I have identified the main material, other materials used, packaging parts and multi-material cases.
• Compliance — I have mapped the requirements, limits, technical file and EU declaration.
• EPR/deposit return — I have clarified registration, data, system, fees, deposit or reuse.
• Evidence — I know where documents and data are retained and where responsibility lies.
• Legislative updates — I have checked applicable delegated and implementing acts and the latest Commission guidance/FAQ.

Assessing PPWR compliance requires linking the operator role, packaging type and material, applicable requirements, and the data and documents demonstrating their fulfilment.

The key question is therefore not only: ‘Which PPWR obligations apply to me?’

It is also: ‘Do I have the data and documents needed to demonstrate proper fulfilment of those obligations?’

If necessary evidence is missing or its sufficiency is uncertain, compliance has not yet been adequately demonstrated.

Summary: the self-assessment determines the operator role, packaging type and materials. The detailed obligations assessment identifies the applicable PPWR requirements, actions needed to fulfil them, and data and documents demonstrating compliance.

The self-assessment determines the operator role, packaging type and materials; the obligations assessment establishes the requirements, actions and evidence.

Updated 10 August 2026.

• Packaging and Packaging Waste Regulation (EU) 2025/40 — legally binding source.
• Commission Notice C/2026/3084 — Commission interpretative guidance, 10 June 2026.
• Commission FAQ — edition of 3 August 2026; non-binding interpretative explanations.
• Subsequent legislation — check delegated and implementing acts on EUR-Lex and the DG ENV website, harmonised standards, common specifications and applicable national provisions.
• Use — a general self-assessment tool; more complex cases require specific technical and legal review.

Interpretative sources do not alter the Regulation's text. A purely informational document prepared by Department III of the ECB Directorate-General. Packaging and Packaging Waste Regulation (EU) 2025/40 — always check applicable EU and national legislation.

The self-assessment ensures that all operator roles are considered for the specific packaging, rather than only one.

Example: an Estonian company buys food products packaged in glass bottles from another EU Member State. The bottles have metal caps and are packed in cardboard boxes. The Estonian company makes these packaged products available on the Estonian market for the first time.

Note: purchasing from another EU Member State is not import under the PPWR, but first making packaged goods available on the Estonian market may create EPR obligations for the company.

Modules 1, 2 and 3 are complete. Now combine their results so that the applicable obligations can be determined in module 4.

Which operator roles have been recorded? Manufacturer, importer, producer (EPR producer), distributor, online marketplace provider, logistics operator, end user… If the company has several roles, include them all in the assessment.

Which packaging types have been recorded? Sales, grouped, transport, e-commerce, service, reusable/refill, beverage/deposit-return, and multi-material/possible composite packaging… If there are several types, include them all in the assessment.

What material is the packaging made from? Plastic, paper/cardboard, glass, wood, metal, no unambiguous main material / several materials… If there are separate components, include every component in the assessment.

If the operator role, packaging type or material is undetermined, return to the relevant module and complete the assessment. Only then proceed to the obligations.

The self-assessment is complete. You can now proceed to the obligations whose application must be checked.

• a list of operator roles;
• packaging types;
• the main material and components;
• possible special cases: EPR, deposit return, reuse and multi-material packaging;
• the obligation cards to read in module 4.

• Open module 4.
• For each role, review what must be done and which evidence must be retained.
• If you have several roles, do not use only one card.
• Requirements applying from 12 August 2026 are addressed separately in the detailed PPWR obligations assessment stage.

The self-assessment is complete. The operator role, packaging type and materials have been determined, and you can now proceed to assess the obligations.

• Do not proceed to module 4 yet.
• Return to module 1, 2 or 3.
• Review the module's guiding question again.
• Record the questions that must be answered in the technical or legal review.
• Only then proceed to module 4, where the obligations are determined.