PPWR: Why digital infrastructure is becoming a competitive advantage

This is the third and final part of our series on the new EU Packaging and Packaging Waste Regulation (PPWR). After looking at packaging information and then at the impact on packaging development, we now turn to the question of how companies can manage the new requirements in their day-to-day operations.

The PPWR is changing not only packaging itself, but also the way companies handle the information associated with it: from material composition, recyclability and recycled content to labelling and conformity. For companies with large packaging portfolios, the amount of information involved can quickly become difficult to manage reliably using manual processes alone.

Many companies store packaging information across different systems. Technical specifications may sit with development teams, material data with procurement and test reports with quality management. Supplier data, certificates and other supporting documents add further layers of information. All of these details need to be up to date and traceable. If a material or packaging component changes, several documents and supporting records may be affected.

This means that PPWR compliance involves more than packaging development. Procurement, quality, sustainability, regulatory affairs, IT and master data management all have a role to play. The first step is to determine the company's role in relation to a particular package and the obligations that follow from it. Who needs which information? Who provides and verifies it? And who keeps it up to date?

Coordination with external partners is also becoming more important. Suppliers of packaging or packaging materials must provide the information and documentation required by the company responsible for conformity.

Under the PPWR, a package is associated with a wide range of information, including material, weight, recyclability, recycled content and individual components. Labelling information, technical documentation and evidence of conformity may also be required.

In this sense, the physical package is acquiring a digital counterpart. If a material or component changes, companies need to be able to trace what this means for the assessment and documentation of the packaging.

The PPWR has generally applied since 12 August 2026, with numerous requirements taking effect in stages over the coming years. As these requirements become applicable, the amount of information and documentation that companies need to manage will continue to grow.

There is no general Digital Product Passport (DPP) requirement under the PPWR for every package. The DPP originates in particular from the EU Ecodesign for Sustainable Products Regulation (ESPR). For certain product groups, it is intended to make specified information digitally accessible.

The concept is nevertheless relevant to the packaging industry. The DPP and PPWR present companies with a similar practical challenge: data needs to be clearly assigned, kept up to date and made usable across company boundaries.

There is no central EU software application that generates a DPP from product information entered by companies. The system is decentralised. Among other things, the ESPR provides for registry services for identifiers and a public web portal.

Not everyone involved needs to use the same software. Existing ERP, PLM or PIM systems can be connected to supplier portals and compliance applications. Standardised data templates and interfaces can help prevent information on materials, components or recycled content from having to be transferred manually time and again from PDFs, emails or spreadsheets.

AI can also provide support. It can extract information from technical data sheets, organise supplier information, identify missing data or highlight differences between document versions. Rule-based systems can then check whether the required data fields and supporting documents are available.

This does not eliminate the need for expert review. Software cannot determine whether information supplied by a vendor is actually correct or whether packaging is compliant. Responsibility remains with the respective economic operator.

The EU has already defined technical parameters for national EPR registers: registration and reporting formats are to be interoperable, based on open standards and use machine-readable data. However, there is no general PPWR data standard governing the exchange of all packaging information between companies.

Although the PPWR applies throughout the EU, Extended Producer Responsibility is organised through national producer registers. Companies classified as "producers" under the EPR rules generally need to register in the relevant Member States. There is no single PPWR registration number covering the entire EU internal market.

In Germany, the Central Agency Packaging Register (Zentrale Stelle Verpackungsregister, ZSVR) operates the LUCID Packaging Register. Companies need to check whether they are required to register in LUCID and whether the information they have provided still meets the new requirements. Companies that are already registered do not need to register again solely because of the PPWR.

The LUCID registration number applies only to Germany. Technical documentation and EU Declarations of Conformity are currently not filed in LUCID; companies must retain these documents themselves.

Primary responsibility for the conformity of packaging lies with the manufacturer – "manufacturer" being the term used in the English version of the regulation. Before placing packaging on the market, the manufacturer must carry out, or have carried out, the required conformity assessment procedure and prepare the technical documentation.

Once compliance with the applicable requirements has been demonstrated, the manufacturer issues the EU Declaration of Conformity. Depending on the packaging and the requirements concerned, the technical documentation may include information on design and materials as well as assessments and test reports.

For single-use packaging, the technical documentation and EU Declaration of Conformity must be retained for five years after the packaging has been placed on the market; for reusable packaging, the retention period is ten years. Digital systems can provide a clear record of which packaging version was linked to which material information and supporting documentation.

For many companies, the PPWR may initially be the reason to further digitalise their packaging information. But the benefits extend beyond compliance.

A shared data base makes material changes, product modifications and customer enquiries easier to manage. Development and procurement can use the same information that is later required for sustainability management or regulatory documentation. The data does not have to be collected again for every new task.

Companies with a clear overview of their packaging portfolio can also identify more quickly which products would be affected by a change of material or supplier.

The PPWR increases the requirements for documentation, registration and supporting evidence. For large packaging portfolios, managing all of this solely with spreadsheets, individual documents and manual processes is hardly practical.

Software, structured supplier data and AI can reduce the workload – provided that the underlying information is reliable and responsibilities are clearly defined.

The benefits are not limited to PPWR compliance. The same data can be used by development, procurement, sustainability management and quality teams. This turns a regulatory requirement into a better information base for day-to-day business.