By: Polina Šarandina
August 18, 2026 4 min read
Since August 12, the new European Packaging and Packaging Waste Regulation (PPWR) has begun to apply generally. For many companies, however, preparation does not end there. On the contrary. It is only when translating the regulation into practice that one of the biggest problems is revealed: not the packaging itself, but the company's ability to prove what exactly it is placing on the market, who is responsible for it, and whether it has the necessary data and documentation at its disposal.
The first pitfall involves unclear roles and responsibilities. The PPWR operates with the roles of manufacturer, importer, distributor, or producer, and their definition does not necessarily align with the conventional commercial understanding of the supply chain. The situation is particularly complex within multinational groups. A product may be manufactured in one country, its documentation managed by headquarters, and the local company subsequently distribute it, repackage it, add a label, or create promotional packaging. The company must then determine who is responsible for individual packaging streams and who is required to ensure the relevant documentation.
The second pitfall is data. Naturally, many companies manage their portfolio by products and SKUs. However, the PPWR requires working with packaging and its specific type. Consequently, thousands of product items do not automatically translate into thousands of different packaging types or thousands of separate documentation sets. Without a proper methodology for grouping packaging, companies risk falling into opposite extremes—either generating an unnecessarily massive amount of documentation or, conversely, combining packaging items that should be assessed independently.
The third pitfall is technical documentation. Information needed to prove conformity is frequently scattered across multiple systems. Part of it is held by procurement, part by quality assurance or production, while other data must be provided by the packaging manufacturer or another link in the supply chain. In practice, therefore, simply creating a declaration of conformity template is insufficient. First, it is necessary to establish an evidentiary trail upon which such a declaration can be responsibly issued.
The supply chain thus becomes one of the critical bottlenecks of implementation. Companies are discovering that they receive documentation of varying formats and quality from different suppliers. Some provide detailed technical data, others a generic statement, and in some cases, the necessary information is missing entirely. Consequently, the PPWR is not merely a task for sustainability or compliance teams; it impacts procurement, quality control, production, IT, legal departments, and sales.
The situation is further complicated by the fact that the European regulatory framework is not yet fully complete in all its details. While the European Commission has already published extensive guidance and FAQs on the practical application of the PPWR, the regulation itself also relies on a series of upcoming implementing and delegated acts as well as technical rules. In certain areas, companies are thus implementing requirements within an environment that will continue to be refined.
On the contrary. The largest share of the work we currently see companies undertaking does not depend on the final technical detail of a future implementing act. Companies can already determine their roles, map packaging streams, consolidate packaging data, establish a methodology for packaging types, ascertain what documentation exists, identify gaps, and systematically begin collecting missing information from suppliers.
This is precisely where perspective on the PPWR is shifting. It is not merely an environmental regulation on packaging; it is also a data management and supply chain project. A company may have packaging that physically complies with the rules, but if it cannot prove its characteristics and does not know who is responsible for its conformity, a problem arises all the same.
Currently, the most important question is not whether a company knows about the PPWR. The more critical question is whether it can also demonstrate its preparedness.
The PPWR is not merely a legislative obligation; it is becoming a business condition that your partners will demand. We will guide you through the transition in a structured manner and well in advance.
This text was translated by AI.
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