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The Path to PPWR Compliance

This page summarizes the conformity process in one place — in the order that has proven itself in practice. The goal: by the general date of application on 12 August 2026, every packaging unit has complete technical documentation and an EU declaration of conformity.
The PPWR Cockpit shows you at any time where each packaging unit stands in the process and what comes next. This page explains why the stages make sense in this order.
The most important practical tip up front: the decisive data — material composition, heavy metal values, PFAS evidence, recycled content — sits with your suppliers, not with you. Supplier data requests are therefore the most time-consuming part of the process. Build up your master data quickly and send the requests as early as possible; everything else runs in parallel.

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The Four Stages

Stage 1: Build Master Data

Create your articles, packaging units, and components and link them into a bill of materials. The packaging unit is the subject of the declaration of conformity — it must be complete before the declaration can be produced.Use the CSV import — bulk import instead of manual entry. Recurring components (e.g. the same folding box used in several products) are created once and reused across packaging units.

Stage 2: Clarify Roles & Obligations

Determine your economic operator role for each packaging unit — manufacturer, importer, distributor. The role decides which obligations from the obligations catalog apply to you and whether you must issue the declaration of conformity.Complete this stage before data collection: that way you don’t collect data for packaging where a different operator carries the obligation.

Stage 3: Collect Data — Request from Suppliers Early

Request missing component data from the responsible suppliers via data requests — ideally all affected suppliers in one go. Your suppliers respond conveniently through the supplier portal; uploaded evidence documents are analyzed by AI, which proposes values you only need to review.Whatever you already have on file (data sheets, test reports), upload directly in parallel.
The completeness of the component data determines when a packaging unit is ready for its declaration of conformity — the Cockpit shows progress per unit.

Stage 4: Create Documentation

For each packaging unit, create the technical documentation (Annex VII) and, building on it, the EU declaration of conformity (Annex VIII) — individually or as a bulk action for all ready units.

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In Parallel: EPR Registration & Volume Reporting

Independent of the four stages — and therefore well suited to run in parallel:
  • The EPR registration per member state (in Germany: LUCID/ZSVR). Start early: registration happens in the respective authority’s portal, and without it you may not place packaging on that market.
  • The volume report with validated XML export for LUCID.

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Afterwards: Ongoing Operations

  • New articles and packaging follow the same path — master data, role, data collection, documentation.
  • If a supplier changes material or recipe, re-request the affected component data; the declaration of conformity is re-issued on the new basis.
  • The Cockpit remains your starting point: compliance funnel, progress, and next steps at a glance.

Questions about the process?

Our team is happy to guide you through the setup personally.