EU EPPR July 2026: The 10-Point Compliance Checklist for Packaging Teams

Why July 2026 Matters

The EU Packaging and Packaging Waste Regulation (EPPR) replaces Directive 94/62/EC and applies directly across all 27 member states. The July 2026 deadline is not the end date — it is the audit trail start date. From July 1, all packaging placed on EU markets must be traceable through a documented recyclability assessment.

The 10-Point Checklist

1. Inventory all packaging formats sold into EU markets Include primary, secondary, and tertiary packaging. Do not overlook e-commerce formats — CRTN ($0.361/unit) and FLEX ($0.370/unit) structures are both in scope.

2. Map every structure to a recyclability tier (A-F) A = fully recyclable. F = non-recyclable. Your converter should supply this — if they cannot, it is a red flag.

3. Identify formats at risk of volume caps Multi-layer laminates with >10% non-recyclable content face restrictions from 2028.

4. Register with your national EPR scheme UK: OPRA. Germany: LUCID. France: Citeo. Deadline: before first Q3 2026 tonnage report.

5. Quantify your EPR fee exposure Model fees using PackIndex category volumes. Flexible formats typically attract higher EPR fees than mono-material corrugated.

6. Audit PCR content levels Rigid plastic: 25% PCR required now (2025 mandate). Confirm with converter and get documentation.

7. Request recyclability certificates from all converters This is the core of the audit trail. Without certificates, you cannot demonstrate compliance.

8. Review label structures LABL ($23.37/1,000) — BOPP-faced pressure-sensitive labels on non-recyclable release liners are at risk. Check adhesive and liner composition.

9. Prepare Q3 2026 EPR tonnage report Quarterly from Q3 2026. You need format-level tonnage data. If your ERP does not track packaging format by weight, start now.

10. Brief procurement on EPPR cost implications EPR fees will add 2-8% to finished packaging costs for non-recyclable formats by 2028. Factor into 2027 budget models now.

PACKIQ's PPWR Grader agent assesses your packaging portfolio against EPPR recyclability tiers A-F and outputs an EPR fee model. Run it before your July audit trail kicks in.