What to have in place under Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation, in force since 12 August 2026. Nine steps, in the order they depend on each other.
For each packaging item, establish who places it on the EU market: manufacturer, importer, distributor or fulfilment service provider. Obligations follow the role, and the role can differ item by item. Record it per item, not per company.
List every packaging item you are responsible for, down to its components, materials and layers. Every later step reads from this register, so build it before assessing anything.
Much of what the regulation asks is decided upstream, in the materials and components you buy. Request data and evidence from suppliers for what you cannot prove yourself, and file it against the item it supports.
Work through each applicable requirement per item and mark it met only when evidence backs it. Keep gaps visible instead of assuming green. An honest unknown is more defensible than an optimistic pass.
Draft the Annex VIII Declaration of Conformity and assemble the technical documentation behind it. The declaration is the last page of the file, not a substitute for it.
Harmonised labelling requirements apply from 12 August 2028, or 24 months after the implementing acts if that is later (Art. 12(1)). Map which items need new artwork and plan print runs early, so stock changes over in time.
From 1 January 2030 at the earliest, packaging is graded for design for recycling (Art. 6) and the first recycled-content targets apply (Art. 7). Both are tied to the delegated and implementing acts, so 2030 is the floor, not a fixed date. Know each item's likely position early enough to redesign what will not pass.
Extended producer responsibility runs market by market: register where you sell and report quantities placed in each. Keep registrations and reported figures next to the packaging record they come from.
Packaging changes; declarations refer to the version that shipped. Preserve records and versions so any past declaration traces back to the exact item, evidence and assessment behind it.
Regtrue keeps the register, supplier evidence, assessments and declarations on one verified packaging record. Each step reads from it, and versions preserve what was true when you declared.