Obligation Checklist

Overview

On every packaging unit’s detail page, Polygon One shows an obligation checklist: the list of PPWR duties that apply to exactly this unit. The list is derived automatically from the economic-operator role and the unit’s properties — you never maintain a checklist by hand. Above the checklist you see the context: “These duties follow from this unit’s role”. Duties that do not apply to the role simply never appear — the checklist only shows what actually concerns you.

Not in this checklist. The checklist covers the duties Polygon One derives and tracks per packaging unit — it is not an exhaustive list of all PPWR duties. Duties to watch outside the platform include:

Compostability (Art. 9) — from 12 Feb 2028, e.g. for permeable tea and coffee bags.
Design of reusable packaging (Art. 11) — already applies since the PPWR entered into force on 11 Feb 2025; the minimum number of rotations follows from an implementing act (due by 12 Feb 2027).
Environmental claims (Art. 14) — claims about properties the PPWR regulates are only allowed where you exceed the minimum requirements.
Empty space (Art. 24) — at most a 50% empty-space ratio for grouped, transport, and e-commerce packaging; for sales packaging there is no fixed threshold, minimisation under Art. 10 applies instead.
Format bans (Art. 25, Annex V) — bans on certain single-use formats from 1 Jan 2030.

Obligation checklist on the detail page of a packaging unit

Which duties exist

Every row carries a badge with the relevant PPWR article and a plain-language explainer. The possible duties:

Duty	Article	Applies from	Who gets it
Heavy metals	Art. 5	12 Aug 2026	Market actors (manufacturer, importer, distributor) and suppliers — the data duty sits with the manufacturer or supplier. Sum of Pb+Cd+Hg+Cr(VI) ≤ 100 mg/kg per component.
PFAS in food contact	Art. 5	12 Aug 2026	Like heavy metals, but only when the unit has at least one food-contact component.
Manufacturer ID + marking	Art. 15	12 Aug 2026	Market actors. Packaging must carry a type, batch, or serial number (or another equivalent element) plus the manufacturer’s name, postal address, and — where available — electronic means of communication; imports must additionally carry the importer’s identity (Art. 18(3)). See below the table for what batch level means in practice.
Conformity assessment	Art. 38	12 Aug 2026	Manufacturers only (incl. Art. 21 cases). Internal production control (Module A) plus technical documentation (Annex VII). The manufacturer retains the Annex VII technical documentation for 5 years (single-use) or 10 years (reusable) (Art. 15(3); Commission FAQ X.10).
EU Declaration of Conformity	Art. 39	12 Aug 2026	Manufacturer, importer, authorised representative — with different tasks (see below). The importer additionally retains the Annex VII technical documentation (5 years single-use / 10 years reusable, Art. 18(7)). The distributor carries no declaration duty here (Art. 19), only a due-care duty (see below).
EPR registration	Art. 44	12 Aug 2026	Only units with the Producer (EPR) switch active and market Member States on file. The row names the affected states and links directly to EPR registration.
Traceability records	Art. 22	12 Aug 2026	All roles except fulfilment service providers. Document upstream and downstream business partners, keep records for 5 years (reusable packaging: 10 years).
Sorting label	Art. 12	12 Aug 2028	Market actors. Harmonised material and sorting labels, once the EU implementing act applies.
Recycled content	Art. 7	2030	Market actors with at least one plastic component.
Recyclability grade	Art. 6	2030	Market actors. Grade A, B, or C; the grading methodology comes via delegated acts (expected 2028) — until then the app only stores your declared grade and does not grade anything itself.
Packaging minimisation	Art. 10	2030	Market actors. Reduction to the minimum weight and volume needed.

Marking: batch level, not individual items

Traceability under Art. 15(5) works at type, batch, or serial level, not at the level of the individual item. Concretely:

No per-item serialisation. A type, batch, or serial number is enough, and it may refer to a packaging type or a production batch. Commonly used standardised items such as adhesive tapes, generic plastic bags, or desiccant bags are normally traceable at production-batch level.
One component is enough. For a unit made up of several components, the information on one of them suffices — for a yoghurt cup, on the cup itself, not additionally on the lid and sleeve.
Accompanying document as the fallback. Where the size or nature of the packaging does not allow the information to be affixed, it may be provided in a document accompanying the packaging. Whether affixing is possible is assessed case by case, taking into account the physical dimensions, shape, and functional characteristics.
Manufacturer details. Required are the name (or registered trade name or registered trademark), the postal address, and, where available, the electronic means of communication of the manufacturer (Art. 15(6)).

Information provided under food law (the Food Information to Consumers Regulation (EU) No 1169/2011) does not automatically satisfy Art. 15(5)/(6). The responsible food business operator and the manufacturer of the packaging are not necessarily the same person, and the two sets of information serve different purposes. If you want one statement to serve both regimes, it must satisfy the requirements of both.

The statuses

Every duty in the checklist has exactly one of three statuses:

Status	Meaning
Met	The app has verified that the required data or evidence is on file — e.g. all components below the heavy-metals limit.
Outstanding	The duty already applies, but data or evidence is missing. For the marking duty, the row shows a concrete hint about what is missing (e.g. add the manufacturer details under Settings → PPWR) and offers the Upload marking evidence button directly.
Not yet in force	The duty applies to this unit, but its effective date is still in the future.

Honesty rule: Duties with a 2028 effective date (sorting label) or 2030 (recycled content, recyclability grade, packaging minimisation) are shown as Not yet in force with the note “Applies from {date} — not applicable today (not a deficiency)”. A future duty is never counted as an open gap. The duties tied to the general application date of 12 August 2026, in contrast, are treated as actionable today — preparing for that milestone is the current task.

Assessed vs. Not assessed

In addition to the status, every duty carries a coverage marker:

Assessed — the app checks your evidence for this duty and shows whether it is met (heavy metals, PFAS, marking, conformity assessment, EU Declaration of Conformity — the latter neutral/informational for distributors).
Not assessed — the duty applies to your role, but the app does not yet verify it. This is not a compliance gap: track it yourself and keep evidence in your records (e.g. traceability, packaging minimisation).

Not-assessed duties appear with a neutral badge and are never rendered as a warning.

Declaration of Conformity: generate or collect — depending on the role

The EU Declaration of Conformity duty carries a different task label depending on the role:

Role	Task	Met when …
Manufacturer (incl. Art. 21 reclassification)	Generate	an active Declaration of Conformity generated in the app itself exists. A merely collected third-party declaration does not discharge your own Art. 39 duty.
Importer, authorised representative	Collect & retain	an active Declaration of Conformity from the upstream supplier is on file and verified (AI check passed or manually approved). A mere upload is not enough. The importer must in addition ensure that the third-country manufacturer carried out the Art. 38 conformity assessment and drew up the declaration, that the Art. 15(5)/(6) marking requirements are complied with, and that the packaging is accompanied by the required documents. Both the declaration and the Annex VII technical documentation must be retained — 5 years for single-use, 10 years for reusable packaging (Art. 18(7)).
Distributor	Due care (Art. 19)	no duty to collect or retain the Declaration of Conformity. But distributors too may only make compliant packaging available — the Commission reads Art. 15(1) as placing that obligation on the chain of manufacturers, importers, and distributors (Commission FAQ X.1). Before making the packaging available, the distributor checks the producer’s registration (Art. 44), the marking (Art. 12), and the identity details of the producer and importer. A distributor who becomes aware of non-compliance informs the competent authorities (Art. 19(5)) — in every Member State concerned, where one warehouse serves several national markets. Collecting a declaration is optional, as due-care evidence; the unit’s declaration row is informational and never triggers action needed.
Supplier, fulfilment service provider	—	These roles do not draw up a Declaration of Conformity; the duty does not appear in the checklist.

Declaration of Conformity

How to generate the declaration from your data or verify collected declarations.

Unit-level status and dashboard rollup

From the obligation checklist, the app derives an overall status per unit that you will find again in the units table, at article level, and in the cockpit:

Overall status	Meaning
Action needed	At least one assessed, already-in-force duty is Outstanding.
On track	All assessed, already-in-force duties are Met.
Upcoming	There is no assessed, in-force duty (yet) — e.g. because all of the unit’s duties only take effect in 2028/2030.

Important: only assessed and already-in-force duties feed the overall status. “Not yet in force” and “Not assessed” duties can never pull the status to Action needed — so the rollup never contradicts the checklist on the detail page. The KPI tile on the units overview counts your units by exactly these three values; at article level, the worst status of all linked units applies (Action needed dominates).

KPI distribution of units by overall status

Next steps

Data collection

Close outstanding duties: collect data and evidence from suppliers.

Evidence documents

Upload test reports and technical documentation — the AI reads out the values.

Transition & enforcement

What happens to existing stock, and how authorities will act from 12 Aug 2026.

Overview

Master Data (Stage 1)

Roles & Obligations (Stage 2)

Data Collection (Stage 3)

Documentation (Stage 4)

EPR & Volume Reporting

Supplier View

Overview

Which duties exist

Marking: batch level, not individual items

The statuses

Assessed vs. Not assessed

Declaration of Conformity: generate or collect — depending on the role

Declaration of Conformity

Unit-level status and dashboard rollup

Next steps

Data collection

Evidence documents

Transition & enforcement

​Overview

​Which duties exist

​Marking: batch level, not individual items

​The statuses

​Assessed vs. Not assessed

​Declaration of Conformity: generate or collect — depending on the role

Declaration of Conformity

​Unit-level status and dashboard rollup

​Next steps

Data collection

Evidence documents

Transition & enforcement

Overview

Which duties exist

Marking: batch level, not individual items

The statuses

Assessed vs. Not assessed

Declaration of Conformity: generate or collect — depending on the role

Unit-level status and dashboard rollup

Next steps