PPWR is EU Regulation 2025/40, the Packaging and Packaging Waste Regulation. It replaced the previous Packaging and Packaging Waste Directive, turning a patchwork of national rules into one directly applicable regulation. It entered into force on 11 February 2025 and its general application began on 12 August 2026. Scope is broad: any economic operator placing packaging on the EU market is covered. That includes manufacturers, importers and distributors of packaged products; final distributors such as retailers, brands and HORECA businesses; online platforms and fulfilment services shipping packaged goods to EU consumers; and any EU supply chain business that fills, uses or unpacks packaging. Micro-enterprises under 10 employees have limited exemptions. Most EU businesses that touch packaging do not.

Requirements vary by product category, but a complete file covers eight things: recycled content percentage by material type and weight; Recyclability Performance Grade (A,B,C) per CEN harmonised methodology; packaging-to-product volume ratio, meaning void space limits for specific categories; reuse and refill rate where the category applies; hazardous substance declarations, including SVHC under REACH and PFAS limits for food-contact packaging; material composition broken down by substrate, decoration, closure and adhesive; technical documentation supporting design-for-recycling claims; and an EU Declaration of Conformity for each packaging format. Reporting is annual, at product level, broken down by material composition and weight across formats.

Under Article 39, the manufacturer draws up an official declaration stating that a packaging format meets PPWR requirements. The declaration itself is short. What sits behind it is not. You must hold technical documentation proving minimum recycled content, packaging minimisation against empty-space limits, and compliance with substance-of-concern limits such as PFAS and heavy metals. Where primary supplier data is unavailable and proxy values are used, the documentation should evidence the effort made to obtain primary data. Greenly generates a timestamped log of every data request, reminder and escalation for exactly this purpose, and exports the declaration and its supporting file in one click.

EPR contributions are no longer flat. Under PPWR, what you pay your Producer Responsibility Organisation is modulated by your packaging's recyclability performance grade and its recycled content. Better-performing packaging costs less to put on the market; poorly recyclable formats cost more. The practical consequence is that a packaging design decision is now a cost decision, and it is one most teams make blind because the grade and the recycled content figure sit with suppliers. Greenly surfaces the recyclability grade and recycled content figures your Producer Responsibility Organisation uses to set that fee, so your team works from verified numbers rather than supplier estimates when assessing a reformulation.

Two categories. Market exclusion: under Articles 58 and 61, customs authorities can identify and block non-compliant packaging at external EU borders, and authorities can mandate immediate withdrawal or recall of products lacking an EU Declaration of Conformity or proper digital tracking. Administrative fines: under Article 68, member states are required to implement penalties for failing to meet EPR, reporting or minimisation obligations, and those penalties must be effective, proportionate and dissuasive. Fine levels are set nationally and vary by member state. For most companies with meaningful EU revenue, the commercial exposure is not the fine - it is the market access ban and retailer delisting that follow it.

Yes. Food-contact packaging containing PFAS above specified limits is prohibited. PPWR also restricts other substances of concern, and requires declarations covering SVHCs under REACH. Compliance here depends entirely on the accuracy of material composition data from converters and material suppliers, which is why substance declarations are built into Greenly's supplier collection workflows rather than handled separately. The platform tracks chemical composition and PFAS content across the supplier base and flags anything that breaches PPWR limits.

Yes, and this is where most of the time saving comes from. Existing LCA studies, EPDs and PEF assessments can be uploaded and mapped to PPWR data fields automatically. Greenly's methodology is aligned with ISO 14040/44 and PEF, the same standards behind your existing LCA work, so prior work counts towards PPWR instead of being redone. The output is a gap list: which fields are already covered, and which SKUs still need primary data from a supplier. Companies that have invested in packaging LCA typically start PPWR compliance with a substantial share of the file already populated.

Under Article 12, packaging will require standardised, open digital data carriers - in practice, often QR codes. These codes verify EPR compliance, provide consumers with sorting instructions, and track trips and rotations for reusable packaging systems. Recyclability grade labelling is also mandatory. The underlying dataset is the same one used for annual reporting and the Declaration of Conformity, which is why it is worth collecting once, at product level, rather than assembling separately for each obligation.

Yes, and that is the point of collecting it once. The packaging inventory and supplier data gathered for PPWR - material composition, weight, recycled content, recyclability grade - is the same input Greenly's LCA engine needs to compute Scope 3 emission factors, and the same data that rolls up into your ESRS E5 disclosures (E5-4, E5-5). PPWR compliance, ESRS E5 reporting and Scope 3 carbon accounting come from the same dataset, in the same place. In practice: you buy PPWR, you get LCA-grade Scope 3 precision and a filled-in ESRS E5 disclosure as part of the same workflow, not as a separate project.