PPWR · sample output Map of your obligations
Map of your obligations
This is what it looks like.
This is what you get in the Map package: for your role and your products, a list of obligations with the articles of Regulation (EU) 2025/40 and of the Czech and Slovak national laws, deadlines and recommended next steps in the order to tackle them. Below is a shortened sample for a fictitious company.
This is a sample – anonymised and shortened. The real Map covers all your products and packaging and is tailored to your markets. The company below is fictitious; the articles, sections and deadlines are real and checked against the text of the rules. The sample covers the Czech and Slovak markets; obligations in your home country are outside its scope.
1. Company profile and role
| Company | Cosmetics online shop established in Germany, 12 employees (small enterprise, not a micro-enterprise) |
|---|---|
| Goods | 40 Korean cosmetic products imported directly from the manufacturer outside the EU, sold with unchanged packaging under the manufacturer’s original brand |
| Markets | Czech Republic and Slovakia – sales directly to consumers, shipped in the shop’s own boxes with its logo |
| Main role | Importer (Article 3(1), point 17): you place the packaging of the 40 products on the EU market for the first time. You are not treated as the manufacturer under Article 21 – you do not place the packaging on the market under your name or trademark and do not modify it in a way that could affect its compliance. Your obligations for this packaging follow from Article 18. |
| Secondary role | Manufacturer of your own shipping boxes with the logo (Article 3(1), point 13): you have the packaging made under your trademark, so you bear the obligations of Articles 15 and 39 for it. |
| Producer | In the Czech Republic and in Slovakia under Article 3(1), point 15(d): you make packaged products available for the first time directly to end users in a Member State where you are not established; for the shipping boxes (e-commerce packaging is transport packaging) under point 15(c). Under the national rules you are also a person placing packaging on the market under the Czech Packaging Act and a packaging producer (výrobca obalov) under the Slovak Waste Act – according to the Slovak ministry’s guidance, since 12 August 2026 this is determined directly by Article 3(1), point 15 PPWR. The national obligations already apply today, alongside the PPWR. |
| Not relevant to you | The ban on PFAS in food-contact packaging (Article 5(5)) – it does not apply to cosmetics packaging. |
2. Your obligations
Seven obligations that follow from your role. In the full Map each one comes with a verbatim quote of the rule, a link to the primary source and the products or packaging it applies to.
| Obligation | Legal basis | Applies from | Recommended next step |
|---|---|---|---|
| 1 Before placing on the market, verify that the Korean manufacturer has carried out the conformity assessment and drawn up the technical documentation, that the packaging is marked and accompanied by the required documents; indicate on the packaging your name or trademark and postal address as the importer (if that is not possible, in an accompanying document or on a data carrier); keep a copy of the EU declaration of conformity | Art. 18(2), (3) and (7); Art. 38; Annex VII | from 12 August 2026 (the Regulation has applied since then) | Ask the manufacturer for a copy of the EU declaration of conformity for each of the 40 packaging items and a written confirmation that it has carried out the conformity assessment and drawn up the technical documentation; archive the copies for 5 years after placing on the market (Art. 18(7)) and keep them at hand – on a reasoned request of the authority you must provide them within 10 days (Art. 18(8)) |
| 2 Your own shipping boxes with the shop’s logo: conformity assessment, technical documentation, EU declaration of conformity (DoC) and marking of the boxes with a type or batch number and your name and address – you are their manufacturer (you have them made under your trademark) | Art. 3(1), point 13; Art. 15(1)–(3), (5) and (6); Art. 39; Annexes VII and VIII | from 12 August 2026 (already in force) | Draw up the technical documentation for the boxes under Annex VII (description of the packaging and its intended use, conceptual design and drawings, materials of the components, standards applied, risk analysis, test reports; the assessment under Articles 6 and 10 where already relevant – minimisation under Article 10 from 1 January 2030, the recyclability assessment only after the delegated acts under Article 6(4)) and issue a DoC under Annex VIII; issue a new one with every change of material or design |
| 3 Czech Republic today: appoint in writing an authorised representative for extended producer responsibility in the Czech Republic and ensure take-back and recovery of the packaging that becomes waste in the Czech Republic – in practice by a contract with the authorised packaging company | Art. 3(1), point 15(c) and (d); Art. 45(3); Czech Act No. 477/2001 Coll.: § 2(d), § 10(1), § 12(1), § 13(1)(c), § 14, § 15 | the representative under Art. 45(3) from 12 August 2026 (a Commission proposal to suspend it until 2035 has not been adopted); the Czech Packaging Act obligations already today | Sign a contract with EKO-KOM (it covers packaging from the start of the quarter in which you sign; with a contract covering all your packaging you do not register in the List of persons, § 14(12)); without it, apply for entry in the List of persons with the Ministry of the Environment within 60 days of the obligation arising – the application may be filed in English (§ 14(6)) – and keep records with an annual report by 15 February (§ 15). A representative under the Czech Act (§ 13a(1)) is voluntary for ordinary cosmetics packaging and mandatory only for single-use plastic packaging from Annex 4, Part C or D sold at a distance (§ 13a(2)); the representative under Art. 45(3) PPWR is mandatory for you. The § 15a exemption (up to 300 kg of packaging a year and at the same time turnover up to CZK 25 million) applies only if both conditions are met |
| 4 Slovakia today: appoint in writing an authorised representative established in Slovakia, register in the Register of producers of reserved products (Register výrobcov vyhradeného výrobku) and fulfil the obligations through a producer responsibility organisation (OZV) | Art. 3(1), point 15(c) and (d); Art. 45(3); Slovak Act No. 79/2015 Coll.: § 27(6) and (18)–(20); § 30(1) | the representative under Art. 45(3) from 12 August 2026 (a Commission proposal to suspend it until 2035 has not been adopted); registration and OZV under the Slovak Act already today – without registration packaging may not be placed on the Slovak market | Appoint in writing an authorised representative (splnomocnený zástupca) established in Slovakia, for at least one year (§ 27(19)) – the representative then answers for all your obligations as packaging producer and acts in its own name (§ 27(20)); with the representative, sign a contract with one OZV for packaging and file the application for registration with the confirmation of the contract – the ministry registers within 10 working days (§ 30(3) and (5)). The relief below 100 kg of packaging a year does not remove registration or record-keeping (§ 54(6)) |
| 5 Harmonised label on material composition on every packaging – including shipping boxes (e-commerce packaging must bear it) | Art. 12(1), (5) and (12); implementing acts under Art. 12(6) and (7) | from 12 August 2028, or 24 months after the implementing acts enter into force – whichever is later; the acts had not been adopted by 1 October 2026, so the start will be later | Start collecting data on the material composition of all 40 packaging items and the boxes now; do not invest in label design until the Commission sets the format; stock made or imported before the deadline may still be supplied for 3 years (Art. 12(12)) |
| 6 Empty space in shipments at most 50% – fillers (paper strips, air cushions, bubble wrap) count as empty space | Art. 24(1) and (3) | from 1 January 2030, or 3 years after the implementing acts under Art. 24(2) enter into force – whichever is later | Measure the ratio of the volume of the sales packaging inside to the box volume for typical shipments and adjust box sizes; the Commission is to adopt the calculation methodology by 12 February 2028 |
| 7 Registration in the PPWR producer register in the Czech Republic and in Slovakia – you are a producer in both states | Art. 3(1), point 15; Art. 44(1), (2) and (4) | once the states set up the register: they have 18 months from the entry into force of the first implementing act under Art. 44(14) (Art. 44(1)); without registration you may then not make packaging available for the first time | Follow the set-up of the register: in Slovakia today’s Register of producers of reserved products is something different from the register under Art. 44, which does not exist yet; in the Czech Republic no act sets the rules of the register yet; the authority assigns the registration number at the latest 12 weeks after receiving complete information (Art. 44(11)) |
Articles refer to Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste (PPWR); sections (§) to the Czech Act No. 477/2001 Coll. on packaging and the Slovak Act No. 79/2015 Coll. on waste. Each Member State sets penalties for breaches of the PPWR in national law by 12 February 2027 (Art. 68); breaches of the national obligations can already be fined today (§ 44 and 45 of the Czech Packaging Act, § 117 of the Slovak Waste Act).
3. Recommended next steps (in order)
Steps in the order that makes sense – from determining your role to setting up a routine. No timeframes: you set the pace.
- Determine your role for each of the 40 packaging items and the shipping boxes: where you are the importer (Art. 18) and where the manufacturer (Art. 3(1), point 13; Art. 21).
- Appoint authorised representatives for extended producer responsibility in the Czech Republic and in Slovakia (Art. 45(3)); in Slovakia also under § 27(18) of the Waste Act.
- Sign a contract with EKO-KOM in the Czech Republic and with an OZV in Slovakia, and register in the Slovak Register of producers of reserved products before your next shipment to Slovakia.
- Ask the Korean manufacturer for copies of the EU declarations of conformity and confirmation that it has carried out the conformity assessment and drawn up the technical documentation (Art. 18(2)); add your name and address as importer on the packaging or in an accompanying document (Art. 18(3)).
- Set up a table of the material composition of all packaging – the basis for the boxes’ technical documentation, packaging reports and the future label (Art. 12).
- Draw up the technical documentation (Annex VII) and issue a DoC (Annex VIII) for your own shipping boxes with the logo, and mark the boxes with a type or batch number and your name and address (Art. 15(5) and (6)).
- Keep an archive of the EU declarations of conformity and technical documentation with the date each packaging item was placed on the market – for 5 years (Art. 15(3), for an importer Art. 18(7)).
- Measure the empty space of typical shipments and adjust box sizes (Art. 24(1) and (3)).
- Follow the set-up of the producer registers under Art. 44 in the Czech Republic and in Slovakia.
- Set an internal rule: every change of packaging material or design = new verification and new DoC.
4. What the full Map contains
- A complete list of obligations for your role and all your products and packaging – not just seven sample rows
- Verbatim quotes of the rules and links to primary sources for each obligation
- Deadlines for each obligation, noting which still wait for an implementing act
- A recommended next step for each obligation, in the order to tackle them
- An overview of your portfolio: what applies to which products or packaging
What the Guide adds
- EU declaration of conformity and technical documentation under Annexes VII and VIII for your packaging
- Letters to suppliers: what exactly to request from a manufacturer outside the EU under Art. 18(2)
- 30/60/90-day action plan
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