How to scope and launch a PPWR compliance programme

The inventory is the programme's foundation, because every PPWR duty attaches to a packaging unit and a legal person. For each format, record its components and materials, what it holds, who supplies it, whether it carries your name or trademark, and whether the contents ship as dangerous goods. Record which of your legal entities places it on the EU market, the Member States it reaches, and whether each customer resells the goods or uses them.

Take a fictional manufacturer, Tarnwick, with an EU company established in Ireland and 18 packaging formats. Five show the range. A 200 L steel drum holds coatings. A 20 L HDPE jerrycan holds an alkaline degreaser that ships as dangerous goods under the ADR rules for road transport. A 25 kg paper sack holds powder coatings. A 1 L HDPE bottle holds laundry liquid. Pallet stretch wrap is bought on a roll from a film maker.

Decide the manufacturer of each format early, because it decides who owes the conformity work. Packaging that carries Tarnwick's name is Tarnwick's. Unbranded packaging bought ready to use, such as the wrap, belongs to the company that makes it. The Commission's FAQ treats the company that orders unbranded custom-made packaging and sets its design as its manufacturer.

Conformity is one piece of work for the whole EU. The manufacturer makes sure each format meets Articles 5 to 12, carries out the conformity assessment, keeps the technical documentation and signs an EU declaration of conformity (Article 15). It has applied since 12 August 2026.

EPR is separate work in each country. The producer registers with each Member State where it first makes packaging available, reports quantities and pays for the collection and recovery of that packaging (Articles 44 and 45). Until the Commission adopts the format for the new producer registers and Member States set them up, producers register under each country's existing rules. The producer for a format is often not its manufacturer. If Tarnwick sells sacks through a distributor in France, the distributor is the producer there. If Tarnwick delivers drums straight to German factories that use the coatings, Tarnwick is the producer in Germany and registers there.

Run the two strands with different owners and calendars, and link them through the inventory. Conformity follows packaging changes and the Regulation's dates. EPR follows national registration deadlines and reporting years.

Give each format a row for each requirement that reaches it. Record the article, the date it applies, whether that date waits on a Commission act, the act's status, and the evidence that shows compliance. Tarnwick's map includes these rows.

The drum must meet the 100 mg/kg limit for lead, cadmium, mercury and hexavalent chromium, summed, which has applied since 12 August 2026 (Article 5(4)). The evidence is the drum maker's test report, filed in the drum's technical documentation.

The jerrycan would need 35% recycled content from 1 January 2030 or later (Article 7(1)(d)), but packaging used to transport dangerous goods under Directive 2008/68/EC is exempt (Article 7(4)(f)). The row records the claim, the check that every size ships as dangerous goods, and the note in the technical documentation that the Commission's FAQ asks for.

The wrap's recycled content target applies from 1 January 2030 or later and is owed by the wrap's maker, as its manufacturer. Tarnwick's row is a request for the maker's evidence. The sack must reach recyclability grade C or better from 1 January 2030 or 24 months after the Commission's design for recycling criteria, whichever is later (Article 6(3)). Those criteria are due by 1 January 2028. The bottle needs the harmonised sorting label from 12 August 2028 or 24 months after the label acts, whichever is later (Article 12(1)). The label acts were due by 12 August 2026 and were still not adopted on 14 October 2026.

Keep the Commission's acts in a separate list that feeds these dates. When an act is adopted, every row that depends on it gets a calculated date.

Every row needs one owner. Packaging engineering usually owns design rows, such as recyclability and minimisation. Product stewardship usually owns substance rows and the dangerous goods exemption. Procurement owns supplier requests, and whoever runs EPR registrations owns the national rows.

Article 16 requires packaging suppliers to give the manufacturer all the information and documentation it needs to show conformity, including for the technical documentation. Send each request against a row, with the requirement, the document needed and a due date, and log what comes back. For bought-in formats that belong to the supplier, ask for a copy of its declaration of conformity instead.

Set two approval points. One person agrees the formats and requirements before mapping starts. The same person checks each row against its source at the end and approves the plan. At Tarnwick, that is Hannah Okafor, Head of Product Stewardship.

A brief for the work states the scope, inputs, outputs and approver. Tarnwick's reads as follows. Scope: the 18 packaging formats its EU company places on the market, in the Member States it sells in. Inputs: the format list with specifications, the markets, the supplier evidence received so far and the approver's name. Outputs: a requirement map for every format, a milestone plan for each format, and a decision log that ties each decision, such as a role or an exemption, to its article. Approval: Hannah Okafor agrees the scope first and approves the plan last.

Foresight's PPWR compliance programme project runs in that order. Your team shares its packaging, Foresight finds the requirements, your approver agrees them, Foresight maps every format, and your approver approves the plan.

Maintain the programme after launch. Recheck the rows that depend on a Commission act when it is adopted, and the rows for a format when its design, supplier or market changes. Keep the technical documentation and declaration for 5 years after single-use packaging is placed on the market, or 10 years for reusable packaging (Article 15(3)). A national authority can ask for them with 10 days to respond (Article 15(10)).