The future of your packaging compliance starts with PPWR

Packaging compliance in the European Union is nothing new. What has changed is how you must structure your data. For many organisations, packaging has historically been treated as an accessory to the product. Under the Packaging and Packaging Waste Regulation (PPWR), that changes. Packaging becomes a compliance object in its own right, requiring a formal Declaration of Conformity supported by verifiable data.

Contact us
PPWR Is not a new starting point
Building on existing EU rules

PPWR is not a new starting point

EU packaging regulation has existed for decades. The 1994 Packaging and Packaging Waste Directive already introduced:

  • Essential requirements.
  • Heavy metal limits.
  • Recovery and recycling obligations.

Over time, this framework evolved through national implementations, Extended Producer Responsibility (EPR) schemes, the Circular Economy Action Plan and the European Green Deal. PPWR does not create regulation from scratch. It consolidates, harmonises and intensifies it. What changes is not the existence of rules. It is  the level of data precision, cross-border consistency and performance-based compliance that changes. Compliance is shifting from being merely documentation-driven to becoming strictly data-driven.

Contact us

The regulatory transition

PPWR introduces phased obligations. These include:

  • Mandatory Declaration of Conformity for all packaging.
  • Mandatory recycled content targets for specific formats.
  • Design-for-recycling criteria and recyclability grading.
  • Increasing transparency towards EPR systems.

Organisations must be able to demonstrate compliance through a Declaration of Conformity supported by structured data. Waiting until the final deadlines will face operational friction; structuring data now creates control.

Want to learn more?
PPWR introduces phased obligations.
Key milestones in EU packaging law

The timeline of PPWR

EU packaging regulation has existed for decades. The 1994 Packaging and Packaging Waste Directive already introduced:

Phase 1 (1994)

Foundation (1994)

The Circular Economy Action Plan and the European Green Deal strengthened EPR schemes and reporting expectations across Member States.

Phase 2 (2018–2020)

Deepening

The Circular Economy Action Plan and the European Green Deal strengthened EPR schemes and reporting expectations across Member States.

Phase 3 (2022–2024)

Transition to PPWR

The Packaging and Packaging Waste Regulation was adopted, aiming for harmonisation across the Member States.

Phase 4 (2025–2026)

Concrete obligations

Stricter requirements emerge. From 12 August 2026, companies must support their Declaration of Conformity with verifiable compliance data. This is a critical milestone in making compliance operational.

Phase 5 (2026)

Single-Topic-Files

Packaging becomes the first Single-Topic-File, introducing a new way of organising compliance documentation in ProductIP.

Phase 6 (2030)

Structural Impact

  • Minimum recycled content targets.
  • Design-for-recycling criteria.
  • Recyclability grading (A/B/C concept).
  • Performance-based compliance.
Treat packaging separately

Packaging as a single topic file

At ProductIP, packaging is managed as a Single Topic File. Why? Because packaging:

  • Has its own compliance logic.
  • Has its own Declaration of Conformity.
  • Has its own recycled content requirements.
  • Has its own design-for-recycling criteria.
  • Has its own EPR implications.

Packaging cannot live as a paragraph inside a product file. It requires dedicated structure to meet the 2026 data requirements.

Want to learn more?
Collecting packaging data at source

Structured data collection from your supply chain

Packaging data originates in the supply chain. Often across:

  • Multiple suppliers.
  • Multiple tiers.
  • Multiple material conversions.

Using Verifeyer Smart Forms, structured packaging data is collected directly from suppliers. Not as static PDF documents, but as validated datapoints. These datapoints serve two purposes:

 

  1. Building and maintaining the packaging Declaration of Conformity.
  2. Collecting structured data required for EPR participation.


This avoids duplicate requests and parallel spreadsheets.

Structured data collection from the supply chain
Compliance
Connecting systems and reporting

From compliance data to operational data

Through the Datapoint Manager, structured packaging data can be transferred to Enterprise Resource Planning (ERP) systems and Product Information Management (PIM) environments.


This allows your organisation to:

  • Support EPR reporting.
  • Monitor recycled content percentages.
  • Manage internal sustainability key performance indicators.
  • Prepare for recyclability grading requirements.

Compliance data becomes operational infrastructure.

Want to learn more?
Managing complex packaging structures

The real challenge is complexity

For many organisations, the variety of packaging combinations feels overwhelming. That complexity is rarely caused by regulation itself.


It is the consequence of:

  • Broad supplier bases.
  • Deep tier structures.
  • Frequent material changes.
  • Historic lack of structured modelling.

In the past, packaging changes had limited regulatory consequences. Under PPWR, they do. Material substitutions. Supplier shifts. Recycled content claims. Each can have compliance impact.

Start with a clear structure

Simplify before solving

Don’t start with tools. First, you need to rethink your packaging architecture. Think modularly. Focus on packaging concepts and group your suppliers into clusters.

 

A product may contain:

  • Primary packaging.
  • Secondary packaging.
  • Transport packaging.

Each may be sourced from different suppliers and different tiers in the supply chain. First, you must organise your packaging data and supplier clusters into a clear system. Once that structure is solid, you can start using tools to automate your compliance.

What the market is already experiencing

PPWR readiness snapshot

During a recent ProductIP Compliance Tuesday session on PPWR, participants confirmed what many compliance teams already feel: retail and trade is not ready yet. The strongest signal was about Extended Producer Responsibility (EPR) data. It helps with reporting, but it is not enough to build a packaging technical file. The main concern was supplier data collection. Participants pointed to data quality and supply chain complexity as key operational challenges.

Watch the PPWR webinar

PPWR
Readiness Confidence

48%

Is EPR data sufficient for packaging compliance?

32%
Visiting from China? Watch the video here.
Practical guidance on packaging data, suppliers and PPWR readiness

Prepare your packaging data for PPWR

PPWR is not just another compliance update. It changes how organisations need to manage packaging data, supplier evidence and technical files. In this ProductIP webinar, we explain why packaging is becoming a regulated product layer and what this means for your organisation. You will learn why Extended Producer Responsibility (EPR) data alone is not enough, why supplier data collection is becoming more complex and how structured packaging files help you prepare for PPWR. For more detailed information visit our Packaging and Packaging Waste Regulation (PPWR) resource page.

Talk to a PPWR expert
Download PPWR readiness slides
Designed for structured compliance

Why ProductIP is built for PPWR

ProductIP provides the structured compliance environment required under PPWR. PPWR does not create complexity. It exposes it. Without system structure, compliance becomes reactive. Inside a structured Product Compliance Management System environment, packaging compliance becomes manageable, measurable and scalable. With structured Single Topic Files and validated supply chain datapoints, organisations gain control across products and markets. For organisations managing multiple products and multiple markets, packaging compliance is no longer a document exercise. It is a system decision.

Why ProductIP is built for PPWR

Frequently asked questions about PPWR packaging compliance

No. Extended Producer Responsibility (EPR) data is useful, but it is not enough on its own.

Under the Packaging and Packaging Waste Regulation (PPWR), packaging needs a technical file and a Declaration of Conformity. That requires more than reporting data. You need structured packaging information, reusable datasets, component-level visibility and evidence for topics such as recyclability and recycled content. EPR data can support this process. It cannot replace a structured packaging compliance file.

PPWR turns packaging into a regulated product layer. That means you may need data from parties you do not actively manage today. Think of packaging manufacturers, printers, fillers, converters, raw material suppliers, wholesalers and co-packers. You are not just adding documents. You are adding operational relationships. That is why supplier data collection is becoming a real challenge. It includes supplier onboarding, evidence updates, packaging changes and market-specific requirements.

Many organisations still think PPWR can be managed with questionnaires, spreadsheets, declarations and annual updates. That is not enough. PPWR creates an operational data challenge. Packaging data needs to move from PDFs to structured data. You need reusable datasets, component-level visibility and connected evidence. The scale grows fast when you multiply this across SKUs, packaging layers, suppliers, markets and update cycles.

Yes. Packaging should be managed as a separate technical file. It has its own compliance evidence, its own risk assessment, its own supply chain partners and its own Declaration of Conformity. That means packaging should no longer be handled only as a question inside a product technical file. A packaging technical file can still be connected to the product technical file, for example through a Bill of Material. But the compliance structure needs to be separate.

Often, yes. Important packaging data may sit beyond your first-tier supplier. For example, with vendors, converters, raw material suppliers or other supply chain partners. For private label packaging, this can mean that suppliers and their vendors need to work together on packaging files. Without this visibility, it becomes harder to verify evidence, risk assessment data and packaging claims.

Yes. ProductIP supports packaging as a dedicated compliance topic. You can create technical files for packaging and generate a Declaration of Conformity. You can also work with suppliers through Document Request or File Request workflows. A lighter start is possible too. You can collect supplier declarations and generate a Declaration of Conformity without using the full Verifeyer Risk Assessment workflow.

Do you want to use the PPWR smart form for risk assessment and EPR data collection? Then the PPWR module can be activated separately. Contact ProductIP to discuss the right setup for your organisation.

Contact

Is your packaging ready for PPWR?

This field is for validation purposes and should be left unchanged.
Toestemming*

Your organisation is facing new packaging obligations under the Packaging and Packaging Waste Regulation (PPWR). ProductIP provides the system structure to manage packaging as a dedicated compliance object. Discover how your organisation can gain clarity and control over packaging compliance across products and markets.

packaging ready for PPWR?