Ensuring EPR Compliance by 2026: Structured Data Capture and Automated Checks for FMCG Companies

EPR compliance is becoming a critical issue for FMCG companies by 2026: rising EPR fees, complex country-specific rules, and parallel requirements from the PPWR and national packaging laws are colliding with fragmented data landscapes. This article explains how structured packaging data, automated compliance checks, and audit-proof documentation can systematically reduce EPR risks and future-proof your organization by 2026.

The new EU Packaging and Packaging Waste Regulation (PPWR) will apply directly in all EU member states after a transition period from 12 August 2026 - and will further tighten requirements for EPR compliance and data quality.

1. EPR 2026 in the Context of the Packaging Act and PPWR

Extended Producer Responsibility (EPR) obliges companies to bear the costs of collection, sorting, and recovery of packaging waste. In the EU, this principle has so far been based on the Packaging Directive, which is implemented differently in each member state.

In Germany, EPR obligations are regulated in the Packaging Act (VerpackG). Producers and distributors must register, report packaging quantities, and pay participation fees to compliance schemes. In Germany, registration in the LUCID Packaging Register is mandatory before placing packaging on the market - failure to do so can result in sales bans and penalties.

In parallel, the PPWR fundamentally reshapes the regulatory framework:

• The PPWR entered into force on 11 February 2025 and will apply after an 18-month transition period from 12 August 2026.
• The regulation is directly applicable - national leeway is significantly reduced.
• It requires article-level data on materials, recyclability, recycled content, and declarations of conformity for each type of packaging.

To ensure robust EPR compliance, EPR reporting must now be tightly linked with PPWR requirements on data, design, and documentation.

Financial risks are increasing. Breaches of the German Packaging Act can be punished with fines of up to €200,000 per individual case - in addition to the risk of market exclusion and reputational damage.

2. Fragmented EPR Systems: Why Structured Data Is Now Essential

There is no single, unified European EPR system. Each country defines its own rules, for example regarding:

• Who is considered the producer or first distributor,
• Reporting obligations for packaging types and materials,
• Reporting processes (formats, deadlines, thresholds),
• Fee calculation and eco-modulation.

Examples from the Packa EPR fee overview illustrate this diversity:

• Austria offers a simplified flat fee for low packaging volumes.
• Belgium separates household and industrial packaging with its own eco-modulation system.
• Germany provides a legal basis for eco-modulation but has not yet implemented it; changes are clearly on the horizon.
• The Netherlands apply high entry thresholds and treat single-use plastics separately.
• Italy uses differentiated fee bands, especially for plastic and paper.

For FMCG companies operating in many markets with thousands of SKUs, consistent EPR compliance is hardly achievable without harmonized, structured packaging data.

2.1 Eco-Modulation as a Cost Driver from 2026 Onward

Eco-modulation links EPR fees directly to the environmental performance of packaging. Fees increasingly depend on:

• Sorting and recyclability,
• Use of mono- or multimaterial structures,
• Coatings, colors, and labels,
• Recycled content and ease of separation.

France, Italy, and Belgium already apply detailed eco-modulation rules - other countries will follow as they implement the PPWR.

Design decisions such as plastic windows in cartons or inseparable adhesive layers will directly influence fee levels in the future. EPR compliance becomes a question of both product design and cost control.

2.2 Typical Data Gaps in Packaging Management

In many companies, the following still dominate:

• Legacy Excel spreadsheets that have grown over time,
• Isolated PDF specifications,
• Email communication with suppliers without central archiving,
• Missing or outdated certificates.

Analyses show how significant these data gaps are: Gap analyses using the Packa software show that 30-70% of packaging data relevant for compliance is missing.

Under these conditions, it is nearly impossible to meet country-specific EPR obligations properly, optimize costs, or demonstrate compliance with PPWR and national packaging laws.

2.3 What Packaging Data EPR Systems Require

For reliable EPR compliance, you need at minimum the following for each packaging item:

• Unique identification (SKU, item number, description),
• Classification as B2C or B2B use,
• Countries where it is placed on the market,
• Detailed material structure (layers, components, labels, closures),
• Weights by material and component,
• Status as single-use or reusable, deposit system if applicable,
• Recyclability assessment and methodology,
• Evidence of recycled content,
• Allocation of the responsible organization in each country,
• Linked certificates and declarations of conformity.

This structured data foundation is required for:

• Accurate EPR reporting and fee calculation,
• Assessing and managing eco-modulation impacts,
• PPWR declarations of conformity and technical documentation,
• Reliable sustainability and ESG reporting.

3. From Excel to Automated EPR Checks: Process Comparison

Many teams still manage EPR obligations manually. This creates heavy workloads and a higher risk of errors - especially for companies selling across Europe with broad portfolios.

Many FMCG companies already manage more than 1,000 packaging items for which detailed, article-level data and documentation will be required in the future

3.1 Weaknesses of Manual EPR Compliance

Typical issues with Excel-based processes include:

• Multiple versions of the same specification,
• Missing mandatory information (e.g., weights, country allocation, B2C/B2B classification),
• No traceable change and approval history,
• Certificates scattered across emails with no expiry tracking,
• High manual effort for country-specific aggregation,
• Risk of incorrect quantity reporting and missed deadlines.

With the tightened PPWR requirements on recyclability, recycled content, and declarations of conformity, this approach becomes a driver of both compliance risk and cost.

3.2 Digital Packaging Management and Automated Checks

Platforms such as the Packa software consolidate specifications, supplier data, and compliance rules in one place and enable automated EPR and PPWR checks.

Core capabilities of such setups include:

• AI-based digitization of specifications from Excel, PDFs, and ERP data,
• Structured data capture covering the full material construction,
• Automated checks for mandatory fields and plausibility,
• Integrated assessment logic for recyclability, PPWR, and EPR,
• Central certificate management with automatic expiry alerts,
• Audit-ready reports at the click of a button.

Comparison: Excel-based approach vs. digital packaging management:

Automation is a direct response to regulatory pressure: The PPWR will require detailed, article-level packaging data and complete documentation along the value chain. Without a digital platform, these requirements cannot be met efficiently.

4. EPR Audit Readiness: Roles, Evidence, Documentation

EPR compliance does not end with the annual quantity report. Authorities, compliance schemes, or retail partners can request evidence at any time - essentially in the form of an audit.

4.1 What an EPR Audit Involves

In an audit situation, companies must be able to demonstrate:

• Which packaging was placed on the market in which period and in which country,
• Quantities per material, format, and type of use (household, commercial, industrial),
• The data sources (specifications, supplier data, measurement methods) underlying the reported values,
• How recyclability and recycled content were determined,
• Responsibilities along the supply chain.

The PPWR tightens these requirements because it mandates technical documentation and declarations of conformity for each packaging item. From 12 August 2026, declarations of conformity and technical dossiers will be mandatory for every packaging item.

EPR reporting, PPWR conformity, and national packaging law requirements are therefore interlinked: packaging data must be consistently available across all regulations.

4.2 How Packa Systematically Reduces EPR Risks

As a specialized system for digital packaging management, Packa offers key advantages:

• Centralized specifications: Complete material structure, weights, and roles (producer, importer, distributor) for each item,
• Standardized supplier data: Digital workflows ensure that missing information and certificates are followed up systematically,
• Integrated compliance checks: EPR, PPWR, and recyclability requirements are assessed on a shared data foundation; anomalies are flagged automatically,
• Linked declarations of conformity: Direct mapping of items to their PPWR declarations of conformity and technical dossiers,
• Audit-ready documentation: Versioned traceability of all histories and approvals - a complete EPR audit dossier without manual searching.

This turns reactive reporting into a proactive management tool for risk and cost control.

5. Roadmap for FMCG Companies Through 2026

FMCG companies should not view EPR 2026 as just another reporting obligation, but as an opportunity to build a sustainable data and process foundation.

5.1 A Three-Step Approach to EPR Compliance 2026

1. Status quo analysis of packaging data

• Create transparency across all packaging items, markets, and roles (producer, importer, distributor).
• Identify data gaps and system breaks (Excel, PDF, email).
• Assess which EPR reports are already supported by automation - and where manual work is still required.

2. Define the target state for digital packaging management

• Clarify critical regulatory requirements for the coming years (PPWR, national packaging laws, EPR fees including eco-modulation).
• Prioritize: identify countries, packaging types, and materials with high risk or major cost impact.
• Design the architecture: how should ERP, PIM, LUCID, EPR systems, and the packaging data platform interact?

3. Build automation and governance

• Implement specialized packaging management software with EPR and PPWR checks, such as the Packa software.
• Define clear roles and responsibilities across procurement, engineering, sustainability, legal, and IT.
• Integrate suppliers digitally and with binding requirements.
• Test reporting and audit processes - ideally using realistic EPR audit scenarios.

5.2 Actively Using the Data Foundation for EPR Cost Management

With complete data, EPR becomes a lever for innovation and cost optimization:

• Identify eco-modulation surcharges early and reduce them through packaging design.
• Compare country markets and target optimizations where fees or regulations have the strongest impact.
• Run scenarios: how do EPR fees change with different materials or higher recycled content?

You can find the free EPR fee guide with a detailed market overview here.

Frequently Asked Questions

What is EPR and how is it linked to the Packaging Act?

EPR obliges producers and distributors to cover the costs of disposal and recovery of packaging. In Germany, this is governed by the Packaging Act (VerpackG) through LUCID registration, participation in a compliance scheme, and reporting obligations. EPR compliance means submitting legally sound, traceable reports backed by consistent packaging data.

Why will EPR compliance become more complex from 2026?

Key developments from 2026 include:

• The PPWR requires article-level data, declarations of conformity, and technical dossiers,
• More countries are introducing detailed eco-modulation rules,
• National systems such as the Packaging Act are being adjusted and will still remain separate.

Structured packaging data and clear governance are essential - blanket or approximate quantity reports will no longer be sufficient.

What data do I need for an EPR audit?

At a minimum, you will need:

• A complete list of packaging placed on the market, including country and time-period allocation,
• Weights of all materials and components per item,
• Classification of packaging types (household, commercial, industrial),
• The basis for assessments (e.g., recyclability, date of specification),
• Linked certificates and PPWR declarations of conformity,
• Documented approvals with named responsible persons.

With digital packaging management, this information is centrally available, versioned, and ready for audits.

When should I start automating EPR processes?

For larger portfolios, the transition period until August 2026 is tight. You will need time to achieve data transparency, consolidate sources, integrate suppliers, and establish new processes. Experience from PPWR projects shows that collecting and cleansing packaging data alone often takes months. Plan for 2025 as the implementation and testing year for digital packaging management and automated EPR processes.

How does the Packa software support my EPR compliance?

Packa combines digital packaging management with compliance assurance:

• AI-based digitization and structuring of packaging specifications,
• Standardized, versioned supplier data,
• Automated EPR, recyclability, and PPWR checks,
• Linking of declarations of conformity and technical documentation,
• Audit-ready reports for different stakeholders.

You can learn more about the interplay between packaging data and compliance in the Packa webinar on packaging data and regulatory compliance.

With structured packaging data, clear roles, and automated compliance checks, EPR Compliance 2026 shifts from an annual stress factor to a manageable, data-driven process. Those who invest now not only reduce risk but also gain transparency over packaging costs and sustainability - creating a real competitive advantage.