PPWR raises the bar for packaging data. Manufacturers will need robust, structured and evidence-based information to complete technical documentation and the EU Declaration of Conformity, while producers will also need detailed registration and reporting data to meet their Extended Producer Responsibility (EPR) obligations.
This article outlines the main categories of data businesses should be preparing to collect, from packaging composition and recyclability to reuse, labelling and reporting.
The main categories of data businesses should collect
1. Packaging identification and traceability data
Businesses need a clear record of the packaging they place on the market.
Annex VII requires technical documentation to include a general description of the packaging and its intended use. Annex VIII requires the Declaration of Conformity to include a unique identification of the packaging, the manufacturer’s details, and information that allows traceability.
In practice, businesses should be collecting:
- Packaging description
- Packaging type or format
- Intended use of packaging
- Internal product or SKU reference
- Manufacturer details
- Traceability information linking the packaging to its compliance documentation
2. Component and material composition data
PPWR requires detailed design and composition data.
Annex VII states that technical documentation must cover, where relevant, the design, manufacture and operation of the packaging. This includes a general description, conceptual design, manufacturing drawings and the materials used in each component.
This level of detail underpins compliance across recyclability, recycled content, labelling and substance requirements.
3. Standards, methodologies and test evidence
PPWR requires businesses to document how compliance has been assessed, not simply confirm that it has been achieved.
Annex VII requires businesses to:
- List the harmonised standards, common specifications or other technical specifications used
- Explain any alternative approaches where those standards have not been applied
- Retain supporting test reports and validation evidence
In practice, this means businesses should retain:
- The standards and specifications applied
- Technical methodologies and assumptions
- Details of any alternative compliance approaches
- Test reports and supporting validation evidence
4. Substance compliance data
Article 5 requires packaging to be manufactured so that the presence and concentration of substances of concern is minimised.
PPWR maintains the existing limit of 100 mg/kg (combined) for lead, cadmium, mercury and hexavalent chromium. It also introduces specific concentration thresholds for PFAS in food-contact packaging from August 2026: 25 ppb (single substance), 250 ppb (sum of PFAS),50 ppm (total fluorine).
Evidence supporting compliance with these requirements should form part of the technical documentation.
Relevant data may include:
- Heavy metal compliance evidence
- PFAS testing data or supplier declarations (where relevant)
- Chemical compliance certificates
- Records supporting substance assessments
5. Recyclability assessment data
Article 6 requires all packaging placed on the market to be recyclable.
In practice, recyclability depends on both:
- Design for recycling
- The ability for packaging to be collected, sorted and recycled at scale
The detailed design-for-recycling criteria and performance grading framework will be further specified by 1 January 2028 through delegated acts. The “recycled-at-scale” condition will become a key compliance requirement from 2035.
Annex VII also requires a qualitative description of how the recyclability assessment has been carried out.
6. Recycled content data for plastic packaging
Under Article 7, businesses must collect data to calculate and evidence the recycled content of plastic packaging.
From 2030 (or later, depending on implementing acts), minimum recycled content thresholds will apply. These must be calculated per packaging type and format, as an average per manufacturing plant and year, using material recovered from post-consumer plastic waste.
In practice, businesses should be prepared to hold:
- Packaging type and format
- Main polymer used
- Whether the packaging is contact-sensitive
- Percentage of recycled content
- Evidence that recycled material is derived from post-consumer waste
- Supplier declarations and supporting documentation
- Calculation records and verification evidence
7. Packaging minimisation data
Article 10 requires packaging, by 2030, to be designed so that its weight and volume are reduced to the minimum necessary while maintaining functionality.
Compliance must be assessed against performance criteria set out in Annex IV, and the supporting evidence must be included in technical documentation.
Businesses should collect:
- Packaging weight and volume data
- Design records explaining minimisation decisions
- Test data, studies, modelling or simulations supporting the assessment
8. Reuse, labelling and digital data
Reusable packaging introduces additional data requirements.
Article 11 sets out criteria that packaging must meet to be considered reusable, including the ability to be used multiple times, meet health and safety requirements, and remain recyclable at end of life. Compliance with these criteria must be demonstrated in technical documentation.
Businesses are likely to need data showing:
- Packaging is designed for multiple uses
- It meets health, safety and hygiene requirements
- It can be emptied, refilled and reconditioned
- It remains recyclable at end of life
Labelling requirements are addressed separately under Article 12. PPWR introduces harmonised labelling and digital data carrier requirements, but the detailed specifications will be defined through future implementing acts.
This means businesses will need accurate material and composition data, once these articles come into effect, to support labelling obligations as they are finalised.
9. Producer registration and reporting data
Producers must also collect data to meet EPR registration and reporting obligations.
Annex IX Part A requires registration information such as:
- Producer name and brand names
- Address and contact details
- Single contact point
- National identification or registration number
- Tax identification number
- Declaration of how EPR responsibilities are met
Annex IX Part B requires reporting of packaging quantities by weight, with simplified requirements for producers placing less than 10 tonnes, per EU state, on the market.
PPWR establishes annual registration and reporting requirements, although further detail on formats and data granularity will be defined through implementing acts and national systems.
The practical takeaway
PPWR sets a clear direction: packaging data will need to be far more detailed, structured and evidence-based than many businesses currently hold today.
At the same time, parts of the framework are still evolving. Many of the detailed rules on recyclability assessment, labelling, reporting formats and verification processes will be confirmed through delegated and implementing acts.
For most businesses, the priority now is to start building the underlying data structure. Those that begin organising packaging specifications, compliance evidence and reporting data early will be far better prepared as the remaining requirements are finalised.
Be prepared for PPWR
PPWR compliance will depend on having the right packaging data in place.
If you need support mapping data requirements, reviewing packaging portfolios or preparing for future reporting obligations, Clarity can help.
