Regulation (EU) 2025/40 · applies 12 August 2026

Navigate the PPWR yourself, without paying a consultant.

The PPWR replaced a directive you could interpret with a regulation that applies directly in all 27 Member States. PPWR Toolkit is the workbench you handle it on: what applies to this packaging, what evidence is still missing, and one organized place for the documents that close the gap. The work stays yours — the tool keeps it structured.

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Article 5, 15, 18, 38–39 and 44–45

until the first PPWR obligations apply
    27+1
    EU Member States and the UK, each with its own labelling duty and register
    34
    material codes assigned by Commission Decision 97/129/EC, every one print-ready as SVG and PNG
    27
    deposit-return markets screened by volume, ABV and refillability
    14
    generated documents, from the Annex VIII declaration to the Finnish fee sheet
    Why this is hard

    The obligation is per product, per market — and the fines are not.

    Most teams discover the PPWR as a spreadsheet of unanswered questions. The regulation is directly applicable, but the duties that actually bite are national: who registers where, which label is mandatory, which deposit scheme takes this bottle.

    One regulation, 27 rulebooks

    A single EU registration is not a passport. You are a "producer" in every market where you first make the packaged product available — potentially 27 registrations, each with its own deadline, threshold and fee schedule. Italy mandates the material code; Finland does not. Get that backwards and you have printed the wrong artwork.

    Missing evidence is not a pass

    From 12 August 2026 you need a technical file and a signed declaration for the packaging you place on the market. Absence of test data does not read as compliant — it reads as unverified. Chinese suppliers rarely volunteer heavy-metal reports, so the gap has to be found and chased before the artwork is signed off, not after.

    Catalogues, not products

    Nobody has one SKU. Assessing four hundred products by hand is a quarter of work that is out of date the moment a supplier changes a film. The answer has to be computed from data you already hold, and recomputed when the data changes.

    What the toolkit does

    Nine modules that help you answer one question: is this product ready to sell?

    Each module reads the same dossier, so an answer entered once lands everywhere — in the readiness matrix, in the audit workflow, and in every document you print. Guided setup walks you through all of them in one flow, and fourteen documents come out the other end.

    Material marks that print

    Every 97/129/EC code from 1 to 98 in three styles, with the composite C/ convention handled, exported as SVG or PNG at any size. Batch-generate a whole artwork sheet from a CSV.

    Article readiness matrix

    Arts 5 to 45 on one screen with a live state per row — pass, gap, fail, or waiting on a delegated act. Every verdict defers to the engine that owns it, so the matrix cannot claim your declaration is ready while it is un-issuable.

    Design checks with numbers

    Annex II recyclability grade by weight with the gap to the next grade in grams. Art 7 recycled content across the four categories with the sub-5 % exemption applied. Art 24 empty space from real dimensions, counting filler as void.

    Art 5 substances, done properly

    A heavy-metals ledger per component against the 100 mg/kg sum, and the stepwise PFAS screen for food contact: total fluorine trigger, EOF confirmation, then the three targeted limits. No test data means unverified — never a pass.

    Deposit-return screening

    27 national schemes with the gates that actually decide scope — volume bands, ABV ceilings, refillable treatment, glass carve-outs — plus the marking each operator requires before you release artwork.

    The documents themselves

    Annex VIII declaration of conformity with a validator that refuses to render an incomplete one. Annex VII technical file with gap badges. Supplier data request and a pre-filled declaration for signature. Print to PDF or download as HTML.

    National labelling, split correctly

    Italy and Spain let you compose the sorting label, so the toolkit generates it per component. France's Triman block and every deposit mark belong to a scheme, so it writes the request instead. Guessing which is which is how a pack ends up carrying a mark nobody had the right to print.

    Guided setup, one flow

    Every field in the dossier as one continuous set of questions, each explained in plain language, with no tab-hopping. The flow adapts as you answer — a drink adds the deposit steps, food contact adds PFAS, Finland adds producer responsibility.

    How it works

    Six steps from "we don't know" to "gathered, organized and documented".

    The same workflow runs for one product or for four hundred. Every step is computed live from the dossier, and the catalogue view shows all six states for every product on one screen.

    Determine your role

    Is the item even packaging under Art 3(1)? Are you the manufacturer, the importer, or caught by the Art 21 rebranding trap? Your duties follow from the answer.

    Complete the product data

    Components, materials, weights, recycled content, heavy metals. Whatever is missing becomes a supplier data request you can send under Art 16.

    Register per market

    One row per target market with the register name, the deadline and your registration number tracked to completion.

    Confirm the artwork

    A checklist of mandatory elements derived from this product's markets, role and deposit screening — separating what the law requires from what is merely convention.

    Issue the documents

    Declaration of conformity and technical file, generated from the dossier and refusing to render while a required block is empty.

    File the evidence

    An evidence register with expiry tracking and the retention clock — five years from last placing, ten for reusables.

    Built for a whole catalogue

    Import every dossier field from one spreadsheet: 83 columns, one row per component, rows sharing a product and SKU merged into one dossier. The Excel template ships with real dropdowns on every field that has a fixed set of values, so an import cannot carry a typo.

    • Validated before anything is written — one bad cell rejects the sheet whole, with the row and column named
    • Round-trip: export the catalogue, enrich in Excel, re-import with overwrite
    • Audit scoring cached per product; the overview paginates and filters by open step
    • Tested at 400 products — under a second to import and score the lot
    Finland

    The only toolkit that also does the Finnish paperwork.

    PPWR is the EU layer. In Finland you still owe producer responsibility under jätelaki 646/2011 and VNA 1029/2021, and from 12 August 2026 the definition of producer widens to transport, service and primary-production packaging.

    • Eligibility wizard covering the 2026 scope widening, including distance sellers
    • Fee calculator on the published Sumi 2026 and Suomen Pakkaustuottajat 2025 per-kilo price lists, with consumer and business channels, the clamped service fee and VAT at 25.5 %
    • Late-filing and laiminlyöntimaksu exposure, so the cost of ignoring it is on the same screen as the cost of complying
    • Palpa module: deposit by container and volume, reverse-vending geometry, barcode and mark sizes, and the beverage-tax comparison at your volumes
    • Rinki/Sumi-ready data sheet and the FI/SV stream vocabulary

    Authority handover tracked

    The producer register moves from Pirkanmaan ELY-keskus to Lupa- ja valvontavirasto on 1 January 2026, and Tukes is designated for PPWR market surveillance from 12 August 2026. The dataset carries both, with the dates.

    Kept current, on purpose

    The regulatory datasets are versioned and separated from the code. A scheduled watch agent checks official sources — EUR-Lex, ministries, PRO price lists — cross-checks each country against its own primary source, and never mixes one Member State's rules into another's.

    Free reference

    Look something up without signing in.

    The same datasets the app runs on, published as plain reference pages. No account, no paywall.

    Questions

    Straight answers

    Does this replace a compliance consultant?

    No. It replaces the spreadsheet. The toolkit computes what the regulation says about the data you enter, shows its working, and cites the source — but it is informational, not legal advice, and provisional calculations are flagged with the delegated act they depend on. Most teams use it to arrive at a consultant with the questions already narrowed to the ones that need judgement.

    We import from Asia and will never get test reports. Is that fatal?

    For ordinary low-risk packaging — tools in a carton with a poly bag — a signed supplier declaration covering Art 5 is the accepted minimum evidence for heavy metals, and the toolkit ships a pre-filled one for signature. It stops chasing per-component test data once that declaration is on file. PFAS on food-contact packaging is different: there is no stock-exhaustion transition, so that one needs analysis.

    Where is our data stored?

    On your own server. The application is a small self-contained Node service with a SQLite database and no third-party dependencies — no analytics, no external fonts, no CDN. Multi-tenant isolation is enforced at the database key, and every sign-in, dossier change and account change is written to an audit log you can read.

    Opened as plain files with no server, it runs entirely in the browser and nothing leaves the machine.

    How current is the regulatory data?

    Every dataset carries a version stamp that is printed on the documents you generate, so an audit can tell which snapshot a decision was made against. A scheduled agent monitors official sources daily and updates the data — never the code — flagging anything that needs a code change as a separate issue.

    What happens to the parts of the PPWR that are not decided yet?

    They are shown as pending, not guessed. The Art 6 design-for-recycling criteria, the Art 7 calculation rules and the Art 12 pictograms all depend on acts that have not been adopted. Any figure that depends on one is marked provisional and names the act and its due date, so you know which numbers will move.

    Can we try it on our real catalogue?

    Yes — that is the fastest way to see whether it fits. Export your packaging data into the Excel template, import it, and the catalogue view will show all six audit steps for every product. The trial has no row limit.

    What we are — and are not

    A tool you work with, not a service that works for you.

    PPWR Toolkit exists to help you navigate the requirements and to keep everything you gather in one organized place. The knowledge of your products is yours, the work is yours, and the responsibility stays yours. We sell the structure, not the expertise.

    What we are

    Software: a checklist of what applies to each product, calculators that show their working and cite their sources, one organized home for your evidence, and generated drafts for you to check, complete and sign.

    What we are not

    A certification body, a testing laboratory, a consultancy or a law firm. Nobody here reviews your data or checks your answers, and nothing the toolkit prints is an approval of anything.

    Which is why it costs what it costs

    A consultancy sells hours of an expert doing the work for you. This sells the structure for doing it yourself — once, with a tool that remembers it. That difference is the whole price list.

    Find out where your catalogue actually stands.

    Import your products, get six audit states per SKU, and print the documents you are missing. Free for seven days, no card.