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Packaging records: the basis for the PPWR and EPR registration

Methodology: Marek Galetka, founder of Pravano. English translation of our Czech article, which a person approved before publication; every number, date and legal reference of the translation is checked automatically against the original.

Cross-checked as of 5 October 2026 · based on primary sources

Updated 5 October 2026. Based on Regulation (EU) 2025/40 (PPWR) and Czech Act No. 477/2001 Coll. on Packaging. An informative readiness check, not a legal service or an official audit. Original: česká verze.

This article is general information, not individual legal advice. To assess the specific situation of your company, consult a professional adviser.

If you sell goods in packaging – whether cardboard boxes, plastic bags, void fill or transport film – the PPWR (Regulation (EU) 2025/40 on packaging and packaging waste) concerns you. And without proper packaging records you will not manage any of what the regulation requires: neither the EU declaration of conformity (DoC) nor registration in the register of producers for the purposes of extended producer responsibility (EPR).

This article shows you exactly what belongs in the records, how to structure them and how to link them to the other obligations under the PPWR – with a clear distinction between what applies with certainty and what implementing acts will still specify.

Why packaging records are so important

Packaging records are the data foundation without which none of the key obligations of the PPWR can be met.

The manufacturer must draw up a DoC (EU declaration of conformity) for every packaging item placed on the EU market. To be able to draw it up, it must know the exact material composition of the packaging, its weight, its category and whether it meets the requirements on recyclability, recycled content or the restriction of hazardous substances. All these data come precisely from the records.

EPR registration in the register of producers (Article 44 of the PPWR) then requires you to document what packaging you place on the market, in what quantity and from what materials. Without systematic records you will be tracing these figures retrospectively – and very likely inaccurately.

In the Czech Republic, however, packaging records are nothing new brought by the PPWR: anyone required to register in the List of Persons under Act No. 477/2001 Coll. keeps ongoing records of packaging and packaging waste, reports the data for the previous year to the Ministry of the Environment by 15 February and keeps the documents for at least 5 years (Section 15(1)); anyone with a contract on joint fulfilment covering all its packaging does not keep the statutory records for the Ministry and reports its quantities to the authorised packaging company (Section 15(1) in conjunction with Section 14(12)(a)). These national obligations continue to apply alongside the PPWR.

What applies with certainty from 12 August 2026

Packaging must be recyclable – for now, however, under the existing rules. Article 6(1) reads “All packaging placed on the market shall be recyclable” and has no deferral period, so it applies from 12 August 2026 (this is also how the Commission's PPWR guidelines, C/2026/3084, Section 6, interpret it). What is deferred is the yardstick for compliance: the design-for-recycling criteria under Article 6(2), first subparagraph, point (a) (from 1 January 2030, or 24 months from the date of entry into force of the delegated acts under paragraph 4, whichever is later), recycling at scale under point (b) (from 1 January 2035, or five years from the date of entry into force of the implementing acts under paragraph 5, whichever is later) and classification into grades A, B or C under paragraph 3. Until the design-for-recycling criteria under point (a) apply, according to the guidelines manufacturers need only meet the existing requirements under Directive 94/62/EC and the related harmonised standards (for example EN 13430:2004); they do not have to carry out a conformity assessment with regard to recyclability until the delegated acts under Article 6(4) enter into force.

The PPWR has entered into force and most of its provisions apply from 12 August 2026.

Regulation (EU) 2025/40 entered into force on the twentieth day following its publication in the Official Journal of the EU. From 12 August 2026 the following apply, among other things:

• The obligation to draw up a DoC for every packaging item placed on the EU market (annex to the regulation).
• The ban on PFAS in food contact packaging in a concentration equal to or above the limit values – 25 ppb by targeted analysis, 250 ppb for the sum and 50 ppm for PFAS including polymeric PFAS (Article 5(5)).
• EPR registration – producers (a role different from manufacturers) register in the register of producers in every Member State where they make packaging or a packaged product available for the first time, as soon as the state has set up the register (within 18 months of the entry into force of the first implementing act under Article 44(14); as at 1 October 2026 the act had not been adopted); if a producer has mandated a producer responsibility organisation, that organisation fulfils this obligation, unless the state provides otherwise.

Only from 1 January 2030 does packaging minimisation apply – packaging must be designed so that its weight and volume are reduced to the minimum necessary for its functionality (Article 10(1)) – and, according to the Commission's PPWR guidelines (C/2026/3084), also the ban under Article 10(2) (packaging not meeting the functional criteria of Annex IV, and packaging with double walls, false bottoms or unnecessary layers).

If you sell food in packaging with a fluorinated surface treatment, this information belongs in the records – and from 12 August 2026 you may not place such packaging on the market if the PFAS concentration reaches or exceeds the limit values under Article 5(5). This ban does not apply to packaging of cosmetics and drugstore products: Article 5(5) concerns exclusively food contact packaging. Nevertheless, note in the records what the packaging is treated with – for packaging used for both, the stricter regime is decisive.

What implementing and delegated acts will still specify (outlook)

A number of key parameters of the PPWR depend on acts the Commission has yet to issue – without them, the specific numerical requirements cannot be met.

Exact values and methodologies that are not yet final:

• Design-for-recycling criteria (grades A, B, C under Annex II) – the Commission will lay them down by delegated acts by 1 January 2028. The grades are defined in the regulation (A ≥ 95%, B ≥ 80%, C ≥ 70% recyclability by weight), but the methodology for assessing specific packaging is still to come.
• Methodology for calculating and verifying the recycled content of plastic packaging – the Commission will lay it down by an implementing act by 31 December 2026.
• The format for registration in the register of producers and for reporting for EPR – the Commission was to lay it down by implementing acts by 12 February 2026 (Article 44(14)); from the entry into force of the first such act, states have 18 months to set up the register. As at 1 October 2026 the act had not been adopted, so the period is not yet running.
• Methodology for calculating the reuse targets (Article 29) – the Commission will lay it down by 30 June 2027.

Practical impact: build your records so that they capture raw data (material, weight, category, composition), not just the results of calculations. When the methodologies arrive, you will have something to calculate from.

What exactly belongs in packaging records

Good records capture four dimensions: the identity of the packaging, its material composition, the role of your company and compliance with the PPWR requirements.

Identity of the packaging

For each packaging item, record:

• Internal code or SKU of the packaging
• Trade name and description (e.g. “cardboard box 300×200×150 mm”)
• Category under the PPWR: sales packaging, grouped packaging, transport packaging, e-commerce packaging
• Whether it is single-use packaging or packaging intended for reuse
• Whether it comes into contact with food
• From which economic operator you obtained the packaging or packaged product and to which economic operator you supplied it – you must disclose this to the market surveillance authorities on request and be able to provide the information on suppliers for five years for single-use packaging and ten years for reusable packaging, in each case from the date of supply (Article 22)

Material composition

• Main material (paper/cardboard, plastic – stating the polymer, glass, metal, wood, composite)
• Weight of the packaging in grams (empty packaging)
• Share of the individual materials as a percentage by weight (key for calculating recyclability and recycled content)
• Share of post-consumer recycled content in plastic parts (under Article 7(5)(b), any plastic part accounting for less than 5% of the weight of the whole packaging unit is exempt from the obligation)
• Presence of surface treatments, varnishes, barrier layers, adhesives, inks
• Presence of PFAS or other substances of concern (SoC)

The role of your company

The PPWR distinguishes roles, and the obligations depend on the role:

• Manufacturer – the one who manufactures packaging or a packaged product, or has it designed or manufactured under its name or trademark (Article 3(1), point 13); for sales and grouped packaging, according to the Commission's guidelines (C/2026/3084, Section 2), this is usually the one who fills it with its product, and for transport packaging without the name or trademark of the user, usually its manufacturer
• Importer – the one established in the EU who places packaging from third countries on the EU market (Article 3(1), point 17)
• Distributor – anyone in the supply chain other than the manufacturer or importer who makes packaging available on the market (Article 3(1), point 18); if it places packaging on the market under its own name or trademark or modifies it in a way that may affect its compliance, it becomes a manufacturer (Article 21)
• Producer – the role for extended producer responsibility and registration in the register (Article 3(1), point 15): the one who makes packaging or a packaged product available for the first time on the territory of a Member State, or unpacks it without being the end user

Example: you sell cosmetics, pack them in your own boxes bearing your brand logo and sell them to customers in the EU. You are the manufacturer of the packaging within the meaning of the PPWR – the DoC is your obligation, not that of the box manufacturer (unless you are a microenterprise and the box manufacturer is established in the Union, Article 15(12)). Registration in the register of producers is the obligation of the producer (Article 44(2)); if the producer has mandated a producer responsibility organisation, that organisation fulfils it on the producer's behalf, unless the Member State provides otherwise.

Example: you buy goods from a Chinese supplier who packs them in plastic bags bearing your logo, and you sell them in the EU. You are the importer – and because you place the packaging on the market under your brand, you again bear the obligations of a manufacturer, even as a microenterprise: the Chinese supplier is not established in the Union (Article 15(12)).

Compliance with the PPWR requirements

For each packaging item, record whether and how it meets:

• The PFAS ban (Article 5) – from 12 August 2026
• Recyclability requirements (Article 6) – from 1 January 2030 (or later under the deferral clause) at least grade C, from 1 January 2038 only grades A or B
• Recycled content requirements for plastics (Article 7) – from 1 January 2030 (or later under the deferral clause)
• The 50% empty space limit for grouped, transport and e-commerce packaging (Article 24(1)) – from 1 January 2030 or three years from the entry into force of the implementing acts, whichever is later; anyone using sales packaging as e-commerce packaging is exempt under Article 24(5) (such sales packaging must, however, meet the requirements of Article 10)

How to link the records to the DoC

The DoC is not a stand-alone document – it is an output of the records, not a substitute for them.

The manufacturer must draw up the EU declaration of conformity for every packaging item placed on the EU market. In it, the manufacturer must demonstrate that the packaging meets the requirements of the PPWR. Without records capturing the material composition, weights and the results of the recyclability assessment, a DoC cannot be credibly compiled.

In practice: the DoC is a formal document, the records are its data foundation. If you keep the records on an ongoing and structured basis, compiling the DoC is an administrative step. If you do not have records, you are compiling the DoC blind – and risk it being incorrect.

How to link the records to EPR registration

EPR registration requires aggregated data from the records – the quantity of packaging on the market by material and category.

The register of producers (Article 44 of the PPWR) will require you, in every Member State, to document what packaging you place on the market, in what quantity (in tonnes or units) and from what materials. The regulation does, however, already lay down what will be reported: after registration, the producer submits to the authority responsible for the register, by 1 June for each previous calendar year, the weight of the packaging it made available for the first time on the territory of the state concerned, by the packaging categories in Annex II, Table 1, i.e. by material and type of packaging (Article 44(7), Annex IX, Part B, point 1); anyone who makes available there for the first time less than 10 tonnes of packaging in a year submits only simplified data (Article 44(8)). The format for registration and reporting will be laid down by the Commission in implementing acts (Article 44(14)). We do not yet know the exact form of the template – but we do know that without records capturing the material and quantity of each packaging item, you will have nothing to report from.

Recommendation: keep the records so that summary tables can easily be exported from them: “plastic – PET – X kg per year”, “paper/cardboard – Y kg per year” etc. That is the basis of every EPR report.

Real scenarios for online shops

Two examples show how records differ depending on what you sell and how you pack it.

Scenario 1 – an online shop with electronics: You sell your own branded accessories, which you have manufactured in Asia. The product comes in a plastic blister with a paper card (your logo). You import it into the EU yourself. You are the manufacturer of the packaging. The records include: the blister (material PET or PVC, weight; if it accounts for 5% or more of the weight of the whole packaging unit, you monitor its recycled content), the paper card (material, weight, surface treatment). In addition: the cardboard box in which you pack the shipment for the customer (e-commerce packaging – you monitor the empty space ratio).

Scenario 2 – an online shop with food: You sell your own spice blends in plastic jars bearing your logo. You buy the jars from a Czech manufacturer. You are the manufacturer of the packaging within the meaning of the PPWR – unless you are a microenterprise; in that case the manufacturer is the Czech supplier of the jars, because it is established in the same Member State (Article 3(1), point 13(b)). The records include: the jar (material – polymer, weight, share of the weight of the whole packaging unit; given the food contact, additionally a PFAS check from 12 August 2026), the lid (material, weight), the label (material, adhesive). Shipping box: e-commerce packaging – empty space ratio.

30/60/90-day action plan

Three phases will help you get your records into working order – the obligations already apply from 12 August 2026, so do not put off the inventory.

First 30 days – inventory:

1. Draw up a list of all the packaging you place on the EU market (sales, grouped, transport, e-commerce).
2. For each packaging item, find out the material, the weight and the manufacturer/supplier of the packaging.
3. Determine your role under the PPWR (manufacturer, importer, distributor) for each packaging item.
4. Flag packaging that comes into contact with food – it has priority for the PFAS check.

Days 31–60 – completing the data:

1. Request material data sheets from your packaging suppliers (composition, recycled content, surface treatments, presence of PFAS).
2. For each plastic part accounting for 5% or more of the weight of the whole packaging unit, find out the share of post-consumer recycled content; parts below 5% are exempt from the obligation (Article 7(5)(b)).
3. For e-commerce and transport packaging, measure or estimate the empty space ratio in typical packing.
4. Record the annual quantity of each packaging item placed on the market (in kg or units).

Days 61–90 – structuring and linking:

1. Transfer the data into a structured table or system from which summary reports by material can be exported.
2. Packaging that does not comply with the PFAS ban applicable from 12 August 2026 may no longer be placed on the market – if the inventory reveals it in step 4, deal with its replacement immediately, not only in this phase.
3. Prepare the documents for the DoC – for each packaging item, check that you have all the data needed for the declaration of conformity.
4. Follow developments regarding the harmonised template of the register of producers (the Commission was to lay it down by 12 February 2026) and prepare for EPR registration.

Want to know exactly where your records stand? Use the quick check.

Common misconceptions

The three most common mistakes companies make when building packaging records.

Misconception 1: “Packaging records are only for large companies.”
The PPWR does not lay down a general exemption for small companies. Every producer must register in the register of producers regardless of turnover or number of employees (or a mandated producer responsibility organisation on its behalf). For the DoC, however, size can play a role: if the one who has packaging manufactured under its name or trademark is a microenterprise and the packaging supplier is established in the Union, the supplier is considered the manufacturer for the purposes of Article 15 (Article 15(12)). Member states may lay down exemptions in national law, but you cannot rely on them before they are clearly defined.

Misconception 2: “The invoice from the packaging supplier is enough for me.”
An invoice documents the purchase, not the material composition, the recycled content or the presence of PFAS. Neither a DoC nor an EPR report can be compiled from an invoice. You need a material data sheet (specification) from the packaging manufacturer – and ideally its declaration of composition.

Misconception 3: “I will assess recyclability only once the delegated acts have been issued.”
The delegated acts on the design-for-recycling criteria are due by 1 January 2028, but the obligation to place on the market only packaging of grade C and above applies from 1 January 2030 or 24 months from the date of entry into force of those acts, whichever is later (Article 6(3)). That does not mean you have until 2030 – the transition period is short, and changing the design of packaging (material, composition, surface treatment) takes months to years. Start the records and the recyclability assessment as soon as possible, even if the methodology is not yet final.

Summary

Packaging records are not a bureaucratic formality – they are the data foundation without which none of the key obligations of the PPWR can be met: neither the DoC, nor EPR registration, nor demonstrating compliance with the requirements on recyclability or recycled content. Regulation (EU) 2025/40 applies in full from 12 August 2026; the only exception is Article 67(5), which applies only from 12 February 2029 (Article 71). The records must capture the identity of the packaging, its material composition, the role of your company and the status of compliance with the requirements of the regulation. Start with the inventory right away – the transition periods are shorter than they look, and changing packaging takes longer than you expect.

This article is a general explanation, not individual legal advice. A specific overview for your company (Pravano Kompas) comes with the free check – in writing, within 2 working days.