What applies – and why this product group is prioritised
Unlike product groups regulated solely under ESPR, packaging is governed by the Packaging and Packaging Waste Regulation – PPWR (EU) 2025/40. The regulation applies from 12 August 2026, with phased milestones running through 2028 and 2030. Read our detailed breakdown of what PPWR requires from 12 August.
PPWR mandates that packaging placed on the EU market is backed by formal technical documentation (Annex VII) and an EU Declaration of Conformity (Annex VIII). It also introduces harmonised material sorting labels, QR codes / digital data carriers for reusable packaging and substance tracking, and strict Design for Recycling performance grades (A/B/C).
Product data and documentation to map now
A digital product passport relies on verifiable master data and traceable supplier evidence. For this product group, you should structure data across four core domains:
Packaging components and weight minimisation
- Breakdown into main body, closure/lid, label, adhesive, inks and barrier layers
- Exact material identification code and polymer/fibre type per separable component
- Weight per component and empty-space ratio (packaging minimisation evidence)
- Classification across sales, grouped and transport/e-commerce packaging
Recyclability and post-consumer recycled content
- Design for Recycling assessment (recyclability performance grades A/B/C ahead of 2030)
- Verified percentage of post-consumer recycled (PCR) plastic per packaging format
- Compatibility of sleeves, adhesives and inks with established recycling streams
- For reusable packaging: rotation system, trip counter and reconditioning instructions
Heavy metals, PFAS and food contact safety
- Compliance evidence for the < 100 mg/kg sum limit on lead, cadmium, mercury and Cr(VI)
- Verification of the PFAS restriction in food-contact packaging (applicable from 12 Aug 2026)
- Declaration of Substances of Concern (SoC) that impede recycling or reuse
- Food Contact Material (FCM) declarations and migration test reports where applicable
EU Declaration of Conformity and QR carriers
- Formal EU Declaration of Conformity (DoC) structured per PPWR Annex VIII
- Data backing harmonised consumer sorting symbols
- Digital data carriers (QR codes) showing component separation and reuse instructions
- Structured data for Extended Producer Responsibility (EPR) eco-modulated fee reporting
Typical data challenges – and how to avoid data debt
When PPWR requires a traceable technical file and EU Declaration of Conformity for every packaging format, reporting annual tonnage totals to a producer responsibility organisation is no longer enough. You need component-level specifications, PFAS/heavy metal declarations and verified PCR shares linked directly to each packaging SKU and packaged product.
With Original Creation, you collect specifications and certificates directly from your packaging suppliers and link them to your products – meeting PPWR compliance while feeding packaging data straight into your finished product's own digital product passport.
How to get started in 3 practical steps
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1
Catalogue your packaging portfolio by component
List your primary, secondary and transport packaging formats and link each separable component (tray, film, cap, label) to its supplier.
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2
Collect heavy metal, PFAS and material specifications
Request structured material breakdowns, PCR certificates and chemical declarations from suppliers to build your Annex VII technical file.
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3
Generate EU DoCs and digital packaging passports in OC
Keep packaging master data, conformity declarations and QR links centralised and audit-ready in one platform.