The EU's Packaging and Packaging Waste Regulation (PPWR) has applied since 12 August 2026, and it covers every business that places packaged products on the EU market — there's no small-company exemption. It asks producers to classify their packaging, register in every country they sell in, and report tonnage every year, among other things.

Root already holds three of the building blocks every PPWR obligation is built on: what your packaging is made of, how much it weighs, and to which Member States is shipped. The PPWR export file takes that starting point and turns it into a working file you can complete and use to register and report.

This file is a staging file. Root fills in what the platform already knows, whereas you fill in the rest. Then you (or whoever handles compliance for you) use the completed file to register and report with each country's authority. Root doesn't submit anything on your behalf — filing means being the registered compliance party in that country, and that has to be you (Art. 44).

Note: each chapter accommodates the article reference to keep track of where it sits in the PPWR. Link for the regulation here: eli/reg/2025/40/oj

Three tabs are filled in by Root and are not yours to edit. Everything else in the file is built from them plus your answers.

Every tab is colour-coded so you always know what to do with a cell:

Open Matching - Annex II. Every line gets one of PPWR's 22 packaging categories suggested by Root, with the reasoning attached. Your product packaging comes first, one row per material; your logistics packaging follows directly underneath, one row per item with its material shown as "-" because Root holds no component breakdown for it.

If a suggestion looks right, leave it. If not, correct it in the override column and say why. This is the only place a category gets decided, and every report and tonnage figure downstream reads from here.

Categories 7 to 16 need one extra answer. Those are the plastics, and for them the file asks whether the packaging is clear, coloured or opaque, because colour decides whether a sorting machine can identify the polymer. Until you answer, the line's flag reads "TO FILL - colour/transparency" rather than OK, and Validation counts what's still outstanding. Check the flag column before you move on.

On Packaging units, mark each item single-use or reusable, and name the re-use system for anything reusable. Art. 11 only lets you call packaging reusable if a system exists to get it back, so naming it is part of the claim.

This decides two things: how the item's volumes are counted, and how long its paperwork has to be kept — five years, or ten for reusable (Art. 15(3)).

Reusable packaging is counted once, when it first goes into circulation, because placing on the market means the first making available (Art. 3(1)(10)). Ten pallets doing forty trips a year are still ten pallets.

Root knows what your logistics packaging weighs in total, but not where it went. LP units per market works that out for you, so most of the time there is nothing to do on this tab.

The rows build themselves from your sales orders: for each item, every reporting year and Member State that its own facility ships to, counted once. If a facility makes two products and both sell into the Netherlands, the Netherlands still appears once.

The split is suggested the same way. The file reads how many product units that facility sold into each country that year, and divides the item's mass in the same proportion — if 40% of the facility's units went to the Netherlands, 40% of the pallet mass is reported there. The shares always add back to the total mass Root exported, so the tonnage reconciles whether or not you touch the tab.

Override it only where you know the real split differs. The units column is yours to type into, and if you use it, fill every row of that item and that year. The file switches to your figures only once the set is complete, because a part-filled set would divide the mass by the wrong denominator. Leave one row blank and the suggested split stays in force for all of them, and the tab says so rather than failing quietly.

On Market volumes, Root has already filled in the year, country, item and units for your product packaging from your sales orders, with your logistics packaging following underneath. For each row, say whether you're the producer in that market, and whether the units are a first sale or a reusable item coming back around.

Not everything you ship is reportable, and the file needs that information. The producer definition in Art. 3(1)(15) decides who owes the filing, so packaging sold through a local distributor who imports it, packaging that leaves the EU, and a returning reusable crate on a repeat trip are all handled here rather than counted twice. Logistics packaging rows will read "Mass allocation - see Tonnage detail" in the units column instead of a number when those items are reported by mass rather than by unit count. If you entered units for an item on step 3, those appear here instead.

On Registration - Annex IX A, fill in your registration details once, then once per country register you're enrolled in. You may not place packaging on a market before you're registered there (Art. 44(4)), and there's no single EU registration — each Member State runs its own.

If you sell through an online marketplace or use a fulfilment provider, log what you've shared with them in the table further down the same tab (Art. 45(4) and (7)-(9)) — they're allowed to suspend your access without it.

Open Report - Annex IX B1 or B2. Set the year and country at the top of either tab, and the file tells you which applies: the standard report by the 22 packaging categories (Art. 44(7)) once you're at or above 10 tonnes in that country that year, or the reduced report by material group (Art. 44(8)) below it. You only ever file one of the two per country per year — never both. Both are due by 1 June for the preceding calendar year.

Send Chemical limits - Art 5 to your packaging suppliers to fill in. This is their data, not something to estimate on their behalf. Two limits sit on this tab:

Heavy metals apply to everything (Art. 5(4)). The sum of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg in any packaging or packaging component, whatever the material and whatever the sector. Two things people get wrong: it's the sum of the four, not 100 mg/kg each. Derogations exist for glass packaging and for plastic crates and pallets circulating in closed, controlled loops, under Commission Decisions 2001/171/EC and 2009/292/EC, which PPWR keeps in force.

The PFAS limit in PPWR reaches food-contact packaging only (Art. 5(5)), from 12 August 2026: 25 ppb for any single PFAS, 250 ppb for the sum of measured PFAS (both excluding polymeric PFAS), and 50 ppm for PFAS including polymeric. All three apply at once, so failing any one is a failure.

"Not food contact" doesn't mean "no PFAS question". PFAS are used for grease and water resistance in paper and board, in inks, coatings and release layers, and in textile packaging — none of which PPWR's Art. 5(5) reaches. What does reach them is REACH (Annex XVII to Regulation (EC) No 1907/2006) and the POPs Regulation (EU) 2019/1021, which already restrict specific PFAS regardless of what the packaging holds, with a broader EU-wide PFAS restriction under assessment. PPWR itself acknowledges the overlap: Art. 5(5) requires the Commission to evaluate by 12 August 2030 whether this restriction should be amended or repealed to avoid duplicating those acts. So asking your suppliers the question for non-food packaging is worth doing even where PPWR doesn't force it.

There's also a separate trigger worth knowing: where total fluorine exceeds 50 mg/kg, your supplier must show, on request, how much of it is PFAS and how much isn't, so you can complete your technical documentation (Art. 5(5)(c)). The file flags those lines for you.

All of this is demonstrated in the technical documentation, not filed separately (Art. 5(6)) — which is why the declarations belong on the Technical file tab once they arrive.

On Technical file - DoC, log the evidence behind each packaging item as it arrives — test reports, supplier declarations, marking evidence, and the EU declaration of conformity itself. Annex VII sets out what the technical documentation has to contain; Annex VIII is the declaration's own template, and Art. 15(2) requires one per packaging type before it goes on the market.

If you make a claim about your packaging (recyclable, made with recycled content, and so on), log it on Environmental claims - Art 14 too. Art. 14 allows a claim only where the property it describes goes beyond what the regulation already requires anyway, and only if the claim says what it covers.

Validation gathers every check in the file into one list, and won't read "Ready" until everything blocking has been cleared.

Each of these is either waiting on a method the EU hasn't published, or on its own start date. We'll add them as they land.

Does Root file this for me?

No. Root gives you the data each obligation needs; you, or your compliance team, submit it to each country's authority.

Do I need to submit both Report B1 and B2?

No. They're alternatives, not a pair. Which one applies depends on your tonnage in that country that year — the file tells you which.

Is the 10-tonne threshold per material or in total?

In total. Art. 44(8) tests the quantity of packaging you made available in that Member State in a calendar year, all materials added together, once per country per year. You can't split materials into separate filings, and if the combined total passes 10 tonnes you file the full table for everything, not just the material that took you over. Because it's tested per country, you can be above it in one market and below it in another in the same year.

Do pallets, stretch film and outer cartons have to be in here?

Yes — they're packaging under PPWR like anything else (Art. 3(1)(7)) and are reported by weight in the same tables. Whether they're reportable by you is a separate question that Art. 3(1)(15) answers. If you buy them from a supplier in the same country and fill them yourself, point (a) usually makes that supplier the producer, not you. If they arrive on imported goods and you strip them off at your own warehouse, point (e) makes you the producer, because you unpacked them without being an end user. Either way they stay in the file — a row marked as someone else's duty answers the question; a missing row looks like an oversight. National registers have taken differing views on inbound transport packaging, so it's worth confirming with your register or EPR representative.

Why does a line show "TO FILL - colour/transparency"?

Because it falls in Annex II categories 7 to 16, the plastics, where the file needs to know whether the packaging is clear, coloured or opaque. Colour decides whether a sorting machine can identify the polymer, so the answer belongs with the classification. Pick a value from the drop-down and the flag clears.

Some countries ask for this quarterly instead of annually — is that covered?

Yes. Under Art. 44(9) a Member State may require quarterly rather than annual reporting for budgetary reasons. There's a frequency flag at the top of the report tab — leave it on Annual unless your register has told you otherwise. The regulation doesn't fix quarter boundaries, so confirm the calendar with the register itself.

What if I made a marketing claim about my packaging?

Log it on Environmental claims - Art 14. A claim is only allowed if the property it describes exceeds PPWR's own minimum requirement — not simply what the law already asks for anyway — and if it says what it covers: this packaging unit, part of it, or everything you place on the market.

What if my packaging has more than one part — like a jar and its cap?

Each part is classified and reported on its own, because Art. 6(9) treats integrated and separate components as assessed on their own material. A PET jar with a PP cap is two categories, not one, so Matching - Annex II holds one row per material rather than per packaging item.

Can I add rows to the file myself?

If your packaging list has grown, re-export the file from Root rather than extending it by hand: the export sizes each section to your data.