Methodology

How your report is produced.

Every report is generated the same way: a rules engine takes the packaging profile you enter and screens it, obligation by obligation, against the text of Regulation (EU) 2025/40. Here is exactly how that works — and where its limits are.

1. You describe your packaging

The report is built from six inputs: your role in the supply chain, whether your brand appears on the packaging, whether you are established in the EU, the member states you place packaging in, and each distinct packaging type you sell — its level (primary, grouped, transport, e-commerce, service), its material, and whether it is food-contact or reusable. The report reflects exactly what you enter; it does not guess at facts you didn't provide.

2. A rules engine maps you to the regulation

Each input is matched against the conditions the regulation itself sets out. The engine works through the substantive obligations in turn and, for each, decides whether it applies to a packaging type like yours and what the specific threshold and deadline are. For example:

Recyclability grade (Art. 6) — design-for-recycling grades and the dates each grade becomes mandatory, by material.
Minimum recycled content (Art. 7) — the recycled-plastic percentage required for your material and use, for the relevant target years.
Minimisation (Art. 10) — weight, volume and empty-space limits and the documentation you must hold.
Reuse and refill (Art. 29) — whether your category carries binding reuse targets.
Substances and PFAS (Art. 5) — heavy-metal limits and the PFAS restriction in food-contact packaging.
Single-use restrictions (Annex V) — whether a format you use is restricted.
Labelling (Art. 12) — harmonised material and sorting labels and reusability marking where it applies.
EPR registration (Art. 45) — where you must register, and when a non-EU seller needs an authorised representative.

3. Every point is cited to its article

Each obligation in the report names the article or annex it comes from. That is deliberate: it is what lets you — or your compliance team, or your counsel — open the source text in EUR-Lex and confirm the point in a minute rather than take our word for it. A screening you can't check is worth little; a cited one is a starting map you can hand to an adviser.

The Article 21 brand-on-pack determination

One rule catches many businesses off guard, so the engine treats it as a distinct check. Under Article 21, where packaging is placed on the market under a person's own name or trademark, that person is treated as the manufacturer and takes on the manufacturer's obligations — including drawing up the Declaration of Conformity — even if a contract packer physically made the packaging. So if you answer that your brand appears on the pack, the report flags that Article 21 likely places the manufacturer's duties on you, not your packer, and explains what that means for the documentation you need to hold.

Law-dependent values are dated and re-verified. Thresholds, percentages and deadlines in PPWR come from the regulation and, in several places, from implementing and delegated acts the Commission has yet to finalise. Every figure in the report carries an "as of" date, and where a requirement still depends on a pending implementing act — or on a detail the Commission is expected to specify later — the report flags it as provisional rather than presenting it as settled. We re-verify the law-dependent values against the current regulation text before each relaunch and periodically after, because a figure set by regulation can change and a stale number is a real error, not a rounding issue.

What the method does not do

The engine screens your stated inputs against the regulation. It does not inspect your packaging, test its recyclability, measure substance content, or assess conformity — those are the jobs of an accredited lab or notified body. It cannot see facts you didn't enter, and it does not interpret genuinely ambiguous provisions for your specific case; where the regulation's application to your situation is a matter of legal judgement, the report says so and points you to the source. This is a screening to focus your effort and document your diligence — not a substitute for advice or an official assessment.

Read next: The sources we cite · About the tool