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Phase 1 is the part of PPWR that carries the August 2026 deadline, so it's where every company should start. Below is the full set of questions covering packaging inventory, roles and liability, PFAS and heavy metal restrictions, data structure, and the Declaration of Conformity, straight from Simvia's 5-step PPWR readiness checklist.

This is just one of five phases. Download the full PDF checklist to see Phases 2 through 5 (labelling, recycled content, restricted formats, and ongoing compliance monitoring) and to calculate your overall PPWR readiness score.

1.1 Your packaging inventory

The PPWR applies at packaging level, not just product level. You need a complete overview across all formats. Most companies underestimate how many packaging formats and components they actually manage. You cannot prove compliance if your packaging inventory is incomplete.

Ask yourself:

• Do you have a complete and up-to-date inventory of all packaging units? Yes / No / Partially

• Which packaging types do you handle that are going to end up in the EU? (Not Scored) Sales packaging / Grouped packaging / Transport packaging / E-commerce packaging

• Do you fall under any simplified reporting thresholds? (Even below thresholds, e.g. <10 tonnes/year, simplified reporting still applies, not full exemption.) Yes / No

• Have you validated this per EU Member State? Yes / No

1.2 Your role and liability

Under PPWR, almost every actor in the supply chain has some level of responsibility. You don't need to do the packing yourself to have obligations. If your business manufactures, imports, distributes, or simply sells products that arrive already packaged, you are considered an economic operator. Buying pre-packaged goods is enough to bring you into scope, even if you never touch the packaging process itself. Many companies have multiple roles at the same time, each with different legal obligations.

Ask yourself:

• Have you mapped responsibilities per role (including liability)? Yes / No

• Which roles apply to your organisation based on the packages you bring to the EU market?

  (Most companies have multiple roles)

  Manufacturer / Distributor (including retailer / own-brand) / Supplier of packaging materials / packaged products / Fulfilment service provider / Importer / Authorised representative

1.3 Simplified obligations and thresholds

Not all organisations have the same responsibility within the PPWR. Check what the exceptions are and whether they apply to you. There is a threshold limit of 10 tonnes of packaging placed on the market per year, but simplified reporting still applies below that level. Requirements can also differ per EU Member State.

Ask yourself:

• Do you fall under any simplified reporting thresholds? (Even below thresholds, e.g. <10 tonnes/year, simplified reporting still applies, not full exemption.) Yes / No

• Have you validated this per EU Member State? Yes / No

1.4 Packaging material composition

PPWR compliance starts with data. Every obligation (DoC, recyclability, PFAS) depends on verified packaging data. The real challenge is not only understanding the regulation, but collecting structured packaging data with traceable supplier evidence behind it.

If you're the manufacturer under PPWR, both questions below apply.

Ask yourself:

• Do you have full material breakdown per product/SKU down to packaging component level? Yes / No / Partially / Not applicable

• Is this data supplier-verified? Yes / No / Not applicable

1.5 Substance restrictions — PFAS (food contact)

From August 2026, food-contact packaging must comply with strict limits on hazardous chemicals: 25 ppb (parts per billion) per individual PFAS substance and sum of 250 ppb total PFAS. Companies should already start PFAS screening in food-contact and coated materials and request verified supplier declarations.

Note: There is no harmonised EU test methodology for PFAS in food-contact packaging. The Commission has issued a recommended stepwise approach (May 2026): Total Fluorine (TF) screening first, with more targeted analysis only where TF exceeds 50 mg/kg. Most companies are still at the stage of identifying their high-risk components and finding labs with the right capability. This section is designed to help you assess where you are in that process, not just whether you have a final result.

Ask yourself:

• Have you identified which packaging components are food-contact? Yes / No / Partially

• Do you have lab test results that prove you comply? Yes / No / Partially

• For food-contact components: Have you identified an accredited lab capable of performing Total Fluorine / Total Organic Fluorine testing on your packaging materials? Yes / No / Partially

• Where testing or supplier declarations have been obtained, do you have the results stored and linked to the relevant packaging component in your documentation? Yes / No / Partially

Watch this space: The European Commission and ECHA are conducting a broader study to identify additional "substances of concern" in packaging (due December 2026) — this could add more substances to this list.

1.6 Substance restrictions: Heavy metals

For all packaging components you must comply with strict limits for heavy metals (lead, cadmium, mercury, chromium VI). Your packaging needs to have less than 100 mg/kg combined cap. These restrictions apply across all packaging formats, not only food-contact materials. Evidence should remain traceable back to the relevant packaging component.

Ask yourself:

• For all packaging: Do you have evidence that heavy metals (lead, cadmium, mercury, chromium VI) combined are below 100 mg/kg? Yes / No / Partially

• Are these results traceable per packaging format? Yes / No

1.7 Data structure and mapping

Compliance is not a one-off exercise. PPWR requires continuous, structured and scalable data collection. The companies getting ahead of PPWR are treating it as a data problem first. Structured packaging data is what makes traceability, reporting and audits manageable.

These questions are of utmost concern for manufacturer and distributor roles:.

Ask yourself:

Data Model

• Do you currently have a way to map and structure your packaging data? Yes / No / Partially

• Can you structure this data at packaging component level? Yes / No

• Can you structure this data at packaging unit level? Yes / No

Supplier linking

• Do you have a way to find out which supplier provides the different packaging types? At packaging unit level: Yes / No At component level: Yes / No

• Do you collect supporting documentation i.e. technical files from suppliers? Yes / No / Partially

• Can you link compliance documentation from suppliers to specific packaging units? Yes / No / Partially

1.8 Data collection and storage

PPWR turns compliance into a continuous data process instead of a one-off exercise. Companies need a repeatable way to collect, verify, store and retrieve supplier and packaging documentation at scale.

Ask yourself:

• Is data collection standardised across suppliers? Yes / No / Partially

• Is data stored in a centralised system? Yes / No

• Do you automate supplier requests and follow-ups? Yes / No

• Can you retrieve audit-ready data quickly and automatically? Yes / No

1.9 Declaration of Conformity & Technical documentation file

The PPWR requires a signed Declaration of Conformity per packaging unit from August 2026. The DoC itself is a short formal document, the real challenge is having the technical file, including the underlying data and evidence in place to support it. The DoC is not just a document. It is the output of having complete, structured and verified packaging data available. Required documentation includes material composition, substance compliance evidence and supplier declarations. This list will expand as further requirements come into force. The technical file becomes the legal foundation for market access. It should remain accurate, traceable and continuously up to date.

Ask yourself:

Data Readiness for Technical file & DoC Creation

• For August 2026, can you currently link the following to each packaging unit?

  
  

  Material composition / Supplier declarations Substance compliance evidence (PFAS and/or heavy metals) / Packaging weight and dimensions Description + intended use of the packaging / References to harmonised standards or technical specifications applied Design drawings + material specifications

  
  

• Do you have all the information needed to create a DoC for your packaging units by August 2026? Yes / No / Partially

• Could you make your compliance documentation available electronically within 10 days if requested by an authority? Yes / No / Unsure

• Is that information organised per packaging unit, with supplier evidence linked to it? Yes / No / Partially

Note: As packaging portfolios grow and requirements expand through 2028 and 2030, managing DoC data manually becomes increasingly difficult. A centralised digital system significantly reduces that burden.

1.10 Traceability and evidence retention

Every actor in the supply chain must verify, document and retain their own evidence of compliance. Documentation should remain available for inspection for at least five years for single-use packaging and ten years for reusable packaging.

Ask yourself:

• Do you have the infrastructure to retain documentation for the required periods (5 years for single-use packaging, 10 years for reusable)? Yes / No / Partially

1.11 EPR registration

Most companies selling packaged products in the EU are already registered with national EPR schemes. PPWR doesn't replace that obligation, it harmonises and extends it. If you operate in multiple Member States, existing registrations may need to be reviewed and updated to meet the new harmonised requirements.

Ask yourself:

• Are you registered with a Producer Responsibility Organisation (PRO) in every EU Member State where you place packaging on the market? Yes / No / Partially

• Have you confirmed that your existing registrations will satisfy PPWR's harmonised requirements, or identified where updates are needed? Yes / No

Most teams don't struggle with understanding PPWR, they struggle with collecting and maintaining the data behind it. If Phase 1 turned up more gaps than you expected, that's normal, and it's exactly what this checklist is for. Download the full PDF to work through Phases 2–5 and calculate your overall PPWR readiness score. Or book a 15 minute PPWR consult to go through your specific use case.