PPWR is EU Regulation 2025/40, the Packaging and Packaging Waste Regulation. It entered into force on February 11, 2025 and its general application began on August 12, 2026, replacing the old, country-by-country Packaging and Packaging Waste Directive with one directly applicable rule. Scope depends on where the packaging ends up, not on where the business is based: if a US company ships a packaged product to a customer anywhere in the EU, PPWR applies to that packaging the same way it would for an EU manufacturer. That includes manufacturers, importers, distributors and retailers, HORECA businesses, and online platforms or fulfillment services shipping into the EU. Micro-enterprises under 10 employees get a limited exemption; most businesses that touch packaging don't qualify for it.

Requirements vary by product category, but a complete file covers eight requirements: recycled content percentage by material type and weight; Recyclability Performance Grade (A,B,C) per CEN harmonized methodology; packaging-to-product volume ratio, which sets 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.

Article 39 requires that the manufacturer draws up a formal declaration confirming that a packaging format meets PPWR requirements. The declaration itself is short, but what supports it isn't. That means holding technical documentation showing minimum recycled content, packaging minimisation against empty-space limits, and compliance with substance limits such as PFAS and heavy metals. Where primary supplier data is unavailable and proxy values are used, the documentation has to show the effort made to gather primary data. Greenly logs every data request, reminder and escalation with a timestamp for exactly this reason, and exports the declaration and its supporting file in one click.

EPR contributions are no longer flat. Under PPWR, the amount you pay a Producer Responsibility Organization is set by your packaging's recyclability grade and recycled content. Better-performing packaging costs less to place on the market while poorly recyclable formats cost more, turning a packaging design choice into a cost decision. Most teams miss this because the grade and recycled content figures sit with suppliers. Greenly surfaces the same recyclability grade and the recycled content figures your Producer Responsibility Organization uses to set the fee, so your team works from verified numbers instead of supplier estimates when weighing a reformulation.

There are two categories of penalty. Market exclusion: under Articles 58 and 61, customs authorities can identify and block non-compliant packaging at external EU borders, and can order the immediate withdrawal or recall of products lacking a valid EU Declaration of Conformity or proper digital tracking. Administrative fines: Article 68 requires member states to set penalties for failing to meet EPR, reporting or minimization obligations, with fines that must be effective, proportionate and dissuasive. Fine levels are set nationally and vary by member state. For most companies with meaningful EU revenue, the real risk sits in the market access ban and retailer delisting that follow, well beyond whatever the fine itself amounts to.

Yes. Food-contact packaging containing PFAS above set limits is prohibited, alongside other substances of concern covered by SVHC declarations under REACH. Getting this right depends on accurate material composition data from converters and suppliers. That's why Greenly collects substance declarations as part of the same supplier campaign that gathers everything else, tracking chemical composition and PFAS content across the supplier base and flagging 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. Your LCA work already runs on ISO 14040/44 and PEF, and that's what Greenly's engine builds on here too, so it carries over rather than starting again. 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 standardized, 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 labeling 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, and LCA-grade Scope 3 precision and a filled-in ESRS E5 disclosure come with it, built into the same workflow.