Run an Applicability Check

Overview

The applicability check is a short, structured questionnaire per company. You answer five sections about the company's activities, and kolum computes in real time whether PPWR applies, which roles the company holds, and which obligations follow. The check completes once every section is explicitly answered.

Before you start

• Know the company's actual activities: does it manufacture, fill or pack, import, or sell under its own brand?
• Know its countries: where it is established, where it first places packaged products, and where it sells cross-border to end users.
• Know its packaging categories (sales, grouped, transport, e-commerce, service) and whether any packaging is food-contact.
• If you are unsure how to answer a question, see Understanding the Applicability Questions; every question also carries an info icon with a short explanation in the product.

Step by step

1. Start the check. In the Applicability table, click Check PPWR relevance next to the company. The check page opens, titled with the company name.
2. Answer the five sections. Each section shows its status (Incomplete or Complete) and its questions; mandatory fields are marked with *, and unanswered mandatory questions carry a NEEDS ANSWER tag:
   1. Manufacturing & own brand. Determines whether the company acts as manufacturer under Art. 3(1)(13).
   2. Imports. Determines whether the company acts as importer under Art. 3(1)(17).
   3. Establishment & cross-border sales. Determines producer status per member state under Art. 3(1)(15).
   4. Packaging categories. Which packaging categories you use (Art. 3(1)(4) to (8)); decides later obligations (2028 to 2030).
   5. Food contact & environmental claims. Gates the PFAS limits (Art. 5(5)) and the environmental-claims discipline (Art. 14).
3. Answer explicitly, including the negatives. The check never treats silence as a No. Where none of the options apply, say so explicitly: check No first placement in any member state in section 3, or None of these categories in section 4. Select every country and every category that applies.
4. Watch the live result. The panel on the right updates as you answer: it shows how many sections are answered (for example 0/5 sections), the roles derived so far, and, once enough is known, the verdict and the obligation programme. Until then it reads "Answer the sections to compute obligations".
5. Complete the check. The footer counts your progress (for example, 0 of 5 sections answered; answer every section to complete the check). Once all five sections are answered, click Complete check to save the result. The company's row in the Applicability table now shows the verdict and its obligations.

You can click Discard at any point to leave without saving.

After you complete a check

• The company shows Yes (or the not-affected result) in the Applicability table, with its obligation chips.
• View obligations reopens the saved result at any time.
• The Legal Background setup step 1 counts the company as checked.
• If the company is affected, continue with its packaging items in the Packaging section.

Tips

• Answer for the legal entity you are checking, not for the group. Different entities of the same group can get different results.
• Involve the people who know the operations: production, logistics, and sales for the country questions.
• When facts change, re-run the check rather than mentally adjusting the old result.

ℹ️ Regulatory context. The five sections mirror how the regulation assigns duties: roles from activities (Article 3), duties from roles (Chapter IV, Articles 15, 18, 19), registration and EPR from countries (Articles 44 and 45), and later waves from packaging categories (for example Articles 24(1) and 29(1)). See Regulation (EU) 2025/40.

Common Questions