PPWR: When Packaging Data Becomes a Raw Material

Companies usually know the dimensions, weight, and price of their packaging very precisely. But what about the recycled content, additives, or recyclability of individual components? With the new EU Packaging and Packaging Waste Regulation (PPWR), this information becomes a decisive factor. To kick off our three-part series on the PPWR, we’ll show why reliable packaging information is becoming the most important prerequisite for compliance. The Challenge: Reliable Data Throughout the Supply Chain.

With the PPWR (Packaging and Packaging Waste Regulation), the European Union is tightening requirements for packaging and its recyclability. To meet these requirements, companies will need to describe their packaging much more precisely in the future and be able to document the necessary information in a traceable manner. Information ranging from individual components to their recyclability is required.

The PPWR has been in effect since February 11, 2025. Most of the regulation’s obligations and requirements—such as minimum recycled content quotas, recycling standards, and labeling requirements—take effect on August 12, 2026. Starting on that date, various requirements regarding the minimization of empty space, the ban on certain single-use packaging, and the mandatory participation in reuse systems will also take effect in all EU member states.

By 2040, additional requirements under the EU regulation will gradually come into effect, such as reporting obligations for manufacturers (June 2027), new requirements for compostable and reusable packaging (February 2028), and labeling requirements (August 2028).

With the PPWR, uniform packaging requirements will apply throughout Europe in the future. As an EU regulation, it is directly applicable in all member states and replaces numerous existing national regulations governing packaging design. However, the German Packaging Act (VerpackG) remains in effect. It continues to govern, among other things, extended producer responsibility, participation in dual systems, registration requirements in the LUCID packaging register, and take-back and deposit-refund regulations. In the future, national regulations and the directly applicable requirements of the PPWR will coexist and interlock.

The PPWR changes not only how packaging data is handled but also the packaging itself. In the future, there will be a greater focus on recyclability, material savings, and—for selected applications—industrial compostability. At the same time, companies must design and document their packaging in such a way that its properties can be traced throughout the entire supply chain. We’ll explore how this affects packaging development in a subsequent article in this series.

Mandatory minimum recycled content requirements for plastic packaging are a central component of the PPWR. Depending on the type of packaging, different target rates will apply starting in January 2030 (for example, at least 30% for food-contact PET packaging or single-use PET beverage bottles), which will increase further by January 2040.

Importantly, only material that has already been used as packaging by the end consumer (post-consumer recycled material, PCR) counts toward these targets. A company’s own production waste (post-industrial recycled material, PIR) does not count.

Most of the required information already exists. However, it is often scattered throughout the entire supply chain: material data comes from raw material suppliers, while information on coatings, labels, or adhesives comes from various suppliers. Technical specifications are held by the packaging development team, and additional information is managed by purchasing or quality management. Added to this are test reports, certificates, and data sheets—often in different formats and stored in various locations.

The real challenge, therefore, lies in consolidating existing knowledge. In practice, this means identifying data sources, clarifying responsibilities, and preparing information in such a way that it can be used equally effectively for compliance, product development, and supplier management.

This becomes particularly challenging with multi-part packaging. In such cases, material composition, recyclability, and potential critical substances can only be reliably assessed if all individual details are consolidated. This is because, under the PPWR, the circular economy does not begin with recycling, but rather with the exchange and collection of relevant information. This information must be complete, up-to-date, and traceable in order to meet regulatory requirements.

The PPWR is also changing the way brand manufacturers, packaging producers, and suppliers collaborate along the value chain. Furthermore, the more complex a packaging design is, the more companies are involved in providing information. Manufacturers will therefore be increasingly reliant on their partners to provide this information in a complete, up-to-date, and — as far as possible — standardized manner.

Just as important as the availability of information is its quality. Incomplete or contradictory data complicates both the documentation and the evaluation of packaging with regard to regulatory requirements.

Common standards for packaging information are already in the works. They are intended to simplify the exchange of information along the supply chain and ensure that information is available in a format that can be used by all stakeholders. One example is the reporting template developed by Forum Rezyklat in collaboration with GS1 Germany, which is designed to help companies uniformly record relevant packaging information in the future.

Companies should start now to systematically collect their packaging information and identify existing gaps. After all, building a robust information base takes time—especially when multiple suppliers and business units need to be involved.

The initial focus is on fundamental questions: What information is already available? What is still missing? Who is responsible for maintaining it? How can it be exchanged in a structured manner in the future? Only on this basis can digital solutions be implemented effectively.

The PPWR fundamentally changes the significance of packaging information—not only in terms of regulatory compliance. It will also become indispensable for decision-making in product development, procurement, and sustainability management.

This makes it all the more important to establish the necessary systems and interfaces early on to make packaging information available in collaboration with partners along the supply chain. After all, this information will be a vital resource in the near future.

In the second part of our series, we’ll show why, in the future, nearly every design decision will also be a compliance decision—and what conflicting goals this creates for packaging development.