From 12 August 2026, the new EU Packaging Regulation (Packaging and Packaging Waste Regulation, PPWR - Regulation (EU) 2025/40) will apply uniformly in all Member States. It introduces stricter requirements for FMCG companies regarding recyclability, recycled content, labelling, declarations of conformity and substance bans (e.g. PFAS). This article provides a concise overview of what matters now - and how you can use Packa software and digital packaging management to systematically secure your PPWR compliance.
PPWR 2026 at a glance - key changes and deadlines
- Start of application: PPWR enters into force on 11 February 2025, with most obligations applying from 12 August 2026 uniformly across the EU. (environment.ec.europa.eu)
- Conformity assessment & documentation: From August 2026, a binding conformity assessment is required for all packaging, including proof of recyclability and compliance with substance restrictions. (hk-mueller.de)
- Minimum recycled content: For plastic packaging, minimum recycled content quotas will gradually increase until 2030 and beyond, differentiated by application area. (graulaw.eu)
- Harmonised labelling: By 2028, harmonised symbols for material types, disposal and reuse will be introduced across the EU; the underlying implementing acts are expected by 2026. (globalnorm.de)
- Substance bans & PFAS limits: For food contact packaging, strict PFAS limits and further substance restrictions will apply from 2026. (v-trust.com)
- Directly applicable EU law: The PPWR replaces the existing Packaging Directive and has direct effect in all Member States - national rules (e.g. the German VerpackG) will be adapted and partly repealed. (eur-lex.europa.eu)
From regulation to roadmap - how to tackle PPWR 2026 pragmatically
1. Clarify roles and define responsibilities
The PPWR defines clear roles along the lifecycle of a packaging - including manufacturers, importers, producers placing product on the market, distributors and online platforms - each with its own obligations, for example under extended producer responsibility (EPR). (recycling.de)
For FMCG companies this means:
- You must clearly assign in which role you act for which packaging (private label, contract filling, import, retail).
- From August 2026, you need clear internal responsibilities for each role (e.g. packaging, procurement, legal, sustainability).
- Incorrect role allocation can lead to under- or over-fulfilment of obligations and thus to risk of fines.
With a packaging management SaaS like the Packa software, you define these allocations directly in the system: each packaging unit receives a unique role assignment that you can later use automatically for EPR fees, conformity assessment and reporting.
2. Digitise packaging data in a structured way - move away from Excel
Most companies still manage their packaging portfolio using distributed Excel sheets, PDF specifications and email attachments. These siloed solutions are no longer sufficient for PPWR compliance:
- Recyclability must be demonstrable according to uniform criteria.
- Recycled content, material mixes, additives, layer structures and other parameters must be complete and consistent in the documentation.
- For declarations of conformity and EPR fees, you need centrally available, audit-ready data.
This is where digital packaging management comes in:
- With Packa software, you digitise specifications from Excel, CSV, PDFs or ERP exports and transfer them into central, structured packaging data management.
- AI-based specification digitisation extracts technical details from existing documents, flags data gaps and significantly reduces manual data entry.
- Typical data gaps of 30-70% (e.g. missing material shares, recycled content, additive information) become visible automatically and can then be systematically closed.
For Heads of Packaging, Procurement and Sustainability, this creates for the first time a single "single source of truth" across all packaging, which you can use for PPWR compliance, EPR fees, Digital Product Passport and EUDR-relevant evidence.
3. Map PPWR compliance systematically - from conformity assessment to declaration
With PPWR, conformity assessment for packaging becomes a mandatory process: manufacturers must prove that their packaging fulfils all applicable requirements - and document this via a declaration of conformity. (v-trust.com)
Practical implications for FMCG packaging:
- Every packaging requires a PPWR-compliant assessment (design for recycling, material composition, recycled content, volume/void space limits, etc.).
- Declarations of conformity must be complete, up to date and audit-ready - and must be retrievable at short notice at the request of authorities.
- Changes in design or suppliers must be immediately traceable in the documentation and assessment.
A specialised PPWR compliance software like Packa supports this in three steps:
- Automated rule checks based on your packaging data (e.g. material compliance, PFAS limits in FCM, recycled content quotas, reuse requirements).
- Approval workflows - from initial design through to series approval - with documented decisions and responsibilities.
- Generation and versioning of conformity documentation, which you can use for audits, customer requirements and authority inquiries.
This turns compliance from a one-off project into a continuous, digital process that scales with your portfolio.
4. Proactively integrate recycled content quotas and recycling analysis into development
The PPWR stipulates that plastic packaging must contain binding minimum recycled content from certain key dates - with further tightening until 2030 and beyond. At the same time, all packaging should be fully recyclable by 2030. (echa.europa.eu)
For the development of primary, secondary and transport packaging, this means:
- You need a standardised packaging recycling analysis that already shows in early project phases whether a design can scale PPWR-compliantly.
- Recycled content must be robustly quantified and assigned to the respective components (e.g. bottle, closure, label).
- Design decisions (material mix, colours, barriers) must be data-driven to avoid later rework and redesigns.
The Packa platform offers:
- Integrated recycling analyses based on stored material data and common recycling criteria.
- Packaging data analytics across the entire portfolio - for example to identify systematic "bad performers", highlight items suitable for harmonisation or simulate target quotas for recycled content.
- Transparent dashboards that Heads of Packaging, Sustainability and Procurement can use to derive roadmaps through to 2030.
5. Address substance restrictions (PFAS & more) at an early stage
The PPWR tightens existing chemical restrictions in packaging and extends them, among other things, to PFAS in food contact materials. From 12 August 2026, affected packaging must not exceed certain PFAS limits. (v-trust.com)
Consequences for quality and compliance teams:
- You need complete substance data from suppliers - material names alone are no longer sufficient.
- Limit values and bans must be systematically mappable in packaging data management.
- Changes in substance lists or limits must be entered centrally and automatically applied to the portfolio.
With EUDR compliance software-like approaches within Packa - i.e. structured, traceable data chains - you systematically extend your system with PPWR-relevant substance data and link it directly to each packaging specification.
6. Professionalise supplier communication and smart matching
PPWR compliance is impossible without close collaboration with packaging suppliers, contract packers and service providers. Many critical data points (e.g. exact material composition, recycled content, declarations of conformity) are located outside your company.
Instead of scattered email queries and Excel returns, a digital supplier management solution for packaging is recommended:
- With Packa, you consolidate packaging supplier communication on one platform - from data collection through to approval workflows.
- Through packaging supplier matching (smart matching), the platform automatically assigns incoming offers, specifications and certificates to the correct items and requirements.
- You see at a glance which suppliers provide complete, PPWR-relevant data and where risks or gaps still exist.
The result: data quality increases, manual follow-up questions decrease, and you enable procurement, quality and sustainability to work on the same, up-to-date data sets.
7. Automate EPR fees, Digital Product Passport & reporting
PPWR does not operate in isolation, but is linked to existing and upcoming regulations:
- EPR fees: The level of fees increasingly depends on material type, recyclability and recycled content - without a structured data basis, you risk overpaying or running into compliance risks.
- Digital Product Passport (DPP): For certain product categories, digital product passports will become mandatory, including packaging information.
- EUDR & further sustainability rules: Companies must make supply chain risks transparent - including relevant packaging aspects.
An integrated solution like Packa serves as both EPR fee software and data hub:
- You link packaging data management with country-specific EPR requirements and generate reports at the click of a button.
- Packaging-relevant data for the Digital Product Passport can be fed directly from the system.
- You meet audit and reporting requirements (internal, customers, authorities) from a consistent data base - without manual data chasing.
Conclusion: Build structures now - use PPWR 2026 as a driver of efficiency and transparency
The new EU Packaging Regulation (PPWR) makes one thing clear: manual, fragmented processes in packaging management will no longer be viable from 2026 onwards. Companies that want to ensure PPWR compliance need central, digital and automated workflows.
Key action steps for the next 12-18 months:
- Clarify roles and obligations: Analyse in which roles your company places packaging on the market and which PPWR requirements apply in concrete terms.
- Digitise packaging data: Consolidate all specifications in digital packaging management with clear data models.
- Close data gaps: Use AI-based specification digitisation and structured supplier communication to capture missing material, substance and recycled-content data.
- Implement compliance workflows: Establish standardised processes for PPWR conformity assessment, recycling analysis and declarations of conformity.
- Automate reporting: Link packaging data with EPR fees, Digital Product Passport and EUDR-relevant requirements to minimise reporting risks.
- Start with a core portfolio pilot: Begin with a representative selection of packaging (e.g. top items, critical materials) and then scale to the entire portfolio.
With Packa software, you implement these steps in an integrated packaging management SaaS solution - from data capture through compliance checks to data-driven packaging data analytics. In this way, PPWR 2026 becomes not just an obligation, but a lever for efficiency, transparency and competitive advantage.
Frequently asked questions about PPWR 2026 and digital packaging management
What is PPWR and from when is it binding?
The PPWR (Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40) is the new EU Packaging Regulation. It has been in force since 11 February 2025 and applies from 12 August 2026 as binding law in all Member States. From this date, companies must meet the key requirements - including recyclability, substance restrictions, labelling and conformity assessment. (environment.ec.europa.eu)
Which data do I need to prove PPWR-compliant packaging?
For robust PPWR compliance, you need, among other things:
- complete material composition, including layer structure and weight shares,
- details on recycled content per component,
- information on restricted substances (e.g. PFAS in food contact packaging),
- data on recyclability and intended disposal routes,
- associated declarations of conformity and certificates from your suppliers.
A digital packaging data management solution like the Packa platform helps you collect and maintain this information in a structured way and use it for conformity assessments, audits and EPR reports.
Why are Excel sheets no longer sufficient for PPWR compliance?
Excel sheets reach their limits for three reasons:
- Data complexity: PPWR-relevant data points (materials, additives, recycled content, roles, countries, EPR rules) are difficult to map consistently in spreadsheets.
- Change and approval processes: Versions, approvals and responsibilities are hardly traceable in files - a risk during audits and authority inquiries.
- Automation: Automated compliance checks, recycling analyses or EPR calculations are barely feasible with static spreadsheets.
A packaging management SaaS like Packa, by contrast, enables structured data models, automated rules and transparent workflows - a central prerequisite for implementing PPWR 2026 efficiently.
How does Packa specifically support PPWR, EPR and DPP requirements?
Packa software combines several critical functions on one platform:
- Digital packaging management with central packaging data management and AI-based specification digitisation.
- Automated compliance checks for PPWR requirements (e.g. recyclability, substance bans, recycled content quotas).
- Functions as PPWR compliance software and EPR fee software: country-specific reporting and fee logic can be modelled based on your data.
- Support for Digital Product Passport preparations by providing relevant packaging data in a structured and exportable format.
- Optimised packaging supplier communication and packaging supplier matching to quickly and systematically close data gaps.
This creates the foundation to map PPWR, EPR and future sustainability requirements in an end-to-end digital process.
When is the right time to start the transition?
Given the application date of 12 August 2026 and the wide range of requirements, it is advisable to start within the next 3-6 months. A typical roadmap:
- Status check: Where do you stand today in terms of data, processes and IT landscape in packaging management?
- Pilot with Packa on a partial portfolio to set up data structures, workflows and compliance checks.
- Rollout across the entire packaging portfolio, including supplier onboarding and EPR/DPP-relevant processes.
The earlier you start, the sooner PPWR 2026 will turn from a regulatory challenge into a strategic advantage in cost, risk and sustainability management.

