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.
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. 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 the producer identity and a type, batch, or serial identifier; imports must additionally carry the importer’s identity (Art. 18(3)). |
| Conformity assessment | Art. 38 | 12 Aug 2026 | Manufacturers only (incl. Art. 21 cases). Internal production control (Module A) plus technical documentation (Annex VII). |
| EU Declaration of Conformity | Art. 39 | 12 Aug 2026 | Manufacturer, importer, distributor, authorised representative — with different tasks (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. |
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 — 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).
- 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).
Declaration of Conformity: generate or collect — depending on the role
The EU Declaration of Conformity duty carries one of two task labels 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, distributor, 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. |
| 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. |
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.