Companies preparing for the EU Packaging and Packaging Waste Regulation (PPWR) often start from the assumption that compliance is primarily a matter of understanding the legal requirements and applying them to existing packaging.
In reality, the PPWR is, for most organisations, less a problem of legal interpretation than a data management problem – more specifically, a supplier data problem. This distinction is important when developing internal processes or selecting PPWR software.
What are the key steps?
The key steps are:
- The collection of relevant information from suppliers about the ingredients in the packaging. Important: whether or how evidence is required – e.g. regarding the recycled content share – is not specified in the regulation.
- The conformity assessment procedure is the technical review process used to demonstrate that packaging meets PPWR requirements (see below, e.g. recyclability, labelling, traceability).
- The declaration of conformity is prepared after completion of the assessment procedure and officially confirms conformity.
The declaration of conformity does not need to be filed, but must be available at any time upon request – for example from authorities – together with the technical documentation. Retention periods are 5 years for single-use packaging and 10 years for reusable packaging.
What does the declaration of conformity contain?
The declaration of conformity under Article 39 of the PPWR is a written self-declaration by which operators confirm and demonstrate that their packaging meets all requirements of the new EU Packaging Regulation. It is mandatory for all packaging from 12 August 2026.
The requirements for the declaration itself are kept relatively lean in the regulation. Sensibly, it contains – in addition to confirmation that the PPWR criteria and limit values are met – the ingredients of the packaging. However, this is not legally prescribed.
What needs to be assessed?
With varying transitional periods, the following requirements in particular apply under the PPWR:
- Conformity of packaging
- Restriction of hazardous substances
- Recyclability
- Minimum recycled content in plastic packaging
- Minimisation of packaging
- Information obligations, labelling and reporting obligations
- Prohibition of certain packaging formats and 'slack fill' packaging
- Extended producer responsibility
- Reduction of packaging waste
Who has which responsibilities?
Suppliers must provide the necessary information. Manufacturers and importers (= operators) must carry out the assessment.Operators are the companies that import, manufacture or have manufactured a packaging item or packaged product under their own name or brand – regardless of whether they hold the brand themselves;
- Suppliers are responsible for providing the facts. They must supply manufacturers with material information and supporting documents so that compliance can be demonstrated.
- Manufacturers are responsible for demonstrating conformity. They may not place packaging on the market until the technical documentation has been collected, the conformity assessment carried out and a declaration of conformity can be presented.
- Importers are treated the same as manufacturers (operators). Before placing packaging on the market, importers must ensure that the conformity assessment and documentation are in place and that packaging is correctly labelled.
- Distributors must act with due diligence. They are not required to re-verify packaging, but must check that essential compliance conditions are met, such as proper registration, labelling and upstream conformity.
- Brand owners and modifications change everything. If an importer or distributor sells packaging under their own name or modifies it in a way that affects compliance, the PPWR treats them as a manufacturer. This means full responsibility.
How can I implement the PPWR in a lean way?
The PPWR introduces requirements around packaging materials, design characteristics, recyclability, reuse and documentation. While the legal framework is complex, compliance in practice breaks down at something more fundamental:
- Packaging information is distributed across suppliers
- Data is provided in varying formats and levels of detail
- Evidence is scattered across files, emails and folders
- Audit expectations go far beyond a one-off submission
As long as the PPWR affects only a handful of products, spreadsheets may seem sufficient. As portfolios grow, they become unreliable.
At this point, companies begin looking for PPWR software – often after an internal audit, a customer request or a regulatory review has exposed gaps.
What PPWR software should deliver
You should not evaluate PPWR software purely as document repositories or reporting tools. This approach overlooks where compliance actually breaks down.
Effective PPWR software supports four core capabilities:
1. Structured supplier data collection
PPWR-relevant data comes from packaging suppliers, processors and material producers. Software must support supplier-friendly inputs that reflect how packaging data actually exists in practice.
This means capturing:
- Materials and components
- Coatings, laminates and composite materials
- Food contact relevance
- Recycled content and reuse characteristics
without requiring suppliers to interpret legal texts.
2. Centralised regulatory interpretation
Suppliers provide facts. Regulatory applicability and interpretation must be handled centrally.
A PPWR compliance platform should translate material and design data internally into regulatory assessments, ensuring consistency across products, suppliers and regions.
This separation is critical for data quality and auditability.
3. Evidence-based documentation
PPWR compliance is not based on declarations alone.
Auditors and authorities expect:
- Supplier declarations
- Specifications and test reports
- traceable links between data and documents
Software must bind evidence to data points and preserve them over time.
4. Audit-ready versioning
Packaging portfolios change. Suppliers change. Assessments change.
PPWR software must support:
- timestamped records
- frozen compliance states
- historical views
Without this, companies cannot reliably explain what was known and validated at a specific point in time.
PPWR tools should not be a silo solution
Many organisations view PPWR as a standalone project and look for a narrowly scoped PPWR solution. This often leads to duplicated effort later.
PPWR follows the same structural pattern as other supply chain regulations:
- supplier-provided data and documents
- evolving rules
- increasing audit depth
Tools built purely for PPWR reporting rarely adapt well when requirements change or new regulations are added. The result: companies rebuild processes from scratch.
A more sustainable approach: a compliance-oriented process and workflow solution
Instead of asking 'Which PPWR tool should we buy?' the first question to answer should be:
How do we manage regulatory supplier data in a way that scales across regulations?
Internal operational data is usually well covered by existing document and ERP systems, which can also fulfil reporting functions in combination with the compliance system. But data from suppliers is where things typically fall short. This is where supplier compliance platforms come in. They are designed to:
- manage supplier inputs
- standardise data structures
- attach and preserve evidence
- apply regulatory logic centrally
- generate audit-ready outputs
PPWR becomes one application of a broader system, not a one-off exercise.
Using supplycanvas for PPWR compliance
supplycanvas was built to manage compliance where it most often breaks down: at the supplier interface and supply chain. The foundation of this information remains the same across different requirements. The 'PPWR' workflow applies it in a targeted way.
For the PPWR, supplycanvas enables companies to:
- collect structured packaging data directly from suppliers
- ensure that suppliers are asked for the relevant legal information and classifications
- link material data to supporting documentation
- track compliance status across portfolios
- generate audit-ready inspection reports and declarations of conformity
Because the same supplier data infrastructure can be reused, companies are not dependent on rebuilding processes when PPWR requirements evolve or additional regulations are added.
Selecting PPWR software: what to look for
When evaluating PPWR software or tools, companies should prioritise solutions that:
- are supplier-centric, not document-centric
- separate factual data collection from legal interpretation
- preserve evidence and compliance history
- scale across products, suppliers and regulations
PPWR compliance is an ongoing process. The supporting software should be designed accordingly.
Conclusion
PPWR is primarily a process and system challenge. Companies that invest in structured supplier compliance platforms are better positioned to manage PPWR today – and whatever regulatory requirements come tomorrow.
Which software should you use for PPWR management?
Use a process-oriented compliance platform that queries packaging data from suppliers, links it to evidence and maintains audit-ready records – rather than a reporting-focused approach, spreadsheets or document folders.
Packaging and Packaging Waste Regulation [Regulation (EU) 2025/40]