Do you run a wholesale business, a B2B shop or a distribution company with several thousand SKUs from dozens of suppliers in your catalogue?
Most of what has been written about the PPWR assumes the reader is a manufacturer designing packaging from scratch. A distributor, however, starts from a completely different place. You don't design packaging – you resell other companies' products, often under multiple brands, in multiple markets and through several B2B sales channels at once (an online shop, EDI, marketplaces, a sales rep with a PDF catalogue).
And it is precisely this multiplicity that poses the biggest challenge. The problem isn't the regulation itself, but the fact that you have to apply it to thousands of products that aren't yours, yet for which you still bear part of the responsibility. Let's break it down from the point of view of someone who trades rather than manufactures.
The PPWR (Packaging and Packaging Waste Regulation) is the EU regulation on packaging and packaging waste – formally Regulation (EU) 2025/40 of 19 December 2024. It entered into force on 11 February 2025, but most of its key provisions only began to apply on 12 August 2026, following an 18-month transition period.
This is a regulation, not a directive. Until now, the rules were set by Directive 94/62/EC, which each Member State transposed in its own way – hence the differences between national markets. A regulation applies directly and uniformly across the entire EU, with no need to be transposed into national law.
And it really does apply to everyone – manufacturers, importers, distributors, own-brand retailers, online shops and logistics companies. There are no concessions for smaller businesses. The regulation covers the entire life cycle of packaging: from what it's made of, through labelling and documentation, to what happens to it once it has been used.
A catch worth knowing about from the outset: a company that currently sees itself as an "ordinary" importer or distributor may, under the PPWR, turn out to be the "manufacturer" of the packaging. All it takes is selling a product under its own brand or modifying, in any way, packaging that has already been placed on the market (Article 21 PPWR). The company then takes on the full set of obligations – conformity assessment, technical documentation and the EU declaration of conformity.
How much work a given company faces depends mainly on the role it plays in the supply chain.
You design the packaging or sell the product under your own brand. You're responsible for everything: the technical documentation and the EU declaration of conformity.
You bring in goods from China, Turkey or the UK. You check that the manufacturer has carried out the conformity assessment and that the packaging is correctly labelled, and you keep a copy of the declaration of conformity.
Things are simpler here – you check that the producer is registered, that the packaging is labelled and that the documents are complete. You don't have to draw up a declaration from scratch.
The difference becomes financially painful when a non-EU supplier simply doesn't have the required documentation, but the company still wants to sell the goods. In that case, it's the company that has to commission material composition tests and check PFAS and heavy metal limits – and foot the bill.
Fortunately, Article 16 PPWR works in your favour: every packaging supplier is obliged to provide the information and technical documentation needed to demonstrate conformity.
Behind each of these obligations lies a specific list of information you need to have to hand. The technical documentation required under Annex VII to the PPWR must include, among other things:
Then there's the issue of "empty space" in parcels – for grouped, transport and e-commerce packaging, the target limit is 50% from 1 January 2030 (the European Commission is due to publish the exact calculation methodology by February 2028). However, a simpler rule already applies from August 2026: packaging must be no heavier or bulkier than is actually needed to protect the product.
This is far from a purely theoretical problem – in many e-commerce segments, empty space is estimated to account for as much as 30–60% of a parcel's volume today.
From August 2026, every piece of packaging must also have a recyclability performance grade stated in the declaration of conformity, and from 2028 it must carry harmonised material labelling that is the same across the entire EU.
With a few dozen products in your range, all of this can be handled manually. The trouble starts when a company has thousands of SKUs, dozens of suppliers and several packaging variants per product (sales, grouped, transport), and also sells in several markets with different labelling requirements. The documentation has to be linked to a specific SKU, a specific supplier and, ideally, a specific production batch too.
If something is missing or there's an error in the declaration, the product could be banned from sale across the entire European Union. On top of that, the documents must be kept for 5 years (single-use packaging) or 10 years (reusable packaging).
In other words, the PPWR isn't primarily a legal problem. It's a question of whether a company has its product data in order at all – because today that data usually lives in Excel spreadsheets, sales reps' inboxes and separate PDFs from each individual supplier.
A PIM (Product Information Management) system wasn't built with compliance in mind, but the way it works is an excellent fit for the problem the PPWR creates. So what does that look like in practice?
For each product, you can see what the packaging is made of, how much it weighs, its recyclability grade, its recycled content, which documents the supplier has sent and which market it's destined for.
B2B shop, marketplace, catalogue, ERP – data is distributed from one place instead of being pasted manually into several systems, which sooner or later leads to inconsistencies.
You can immediately see which products are missing material composition, packaging weight or a recyclability grade – before it comes to light during an inspection.
Since suppliers are obliged to provide the data (Article 16 PPWR), the PIM shows who has been asked for what, by when, and whether they've replied – no more digging through an inbox from six months ago.
The PIM records who entered a given attribute, when, and on what basis – whether the data came from the supplier, a laboratory test or the company's own assessment.
And finally – integration. Packaging data rarely originates in a single system: some of it comes from the ERP, some from suppliers via email or portals, and some from the sales platform. A PIM brings all of this together into a single, consistent product record, rather than leaving it scattered across separate, unconnected sources.
A few things worth starting with if you're planning to use a PIM to prepare for the PPWR.
Keep it alongside the standard product information (name, description, price, category). This covers things such as packaging type (sales / grouped / transport / e-commerce), material and its percentage share, weight, dimensions, empty space ratio, recyclability grade, recycled content, presence of substances of concern, target market and documentation status – "complete", "declaration missing" or "under review".
Material composition should be linked to a specific source document – a declaration of conformity, a technical data sheet or a test report. That way, the documentation is genuinely tied to a given SKU and supplier, rather than being "somewhere, but nobody knows where".
Your product range and suppliers change, and further PPWR requirements will be phased in right up until 2040. It's better to have a repeatable mechanism than to start from scratch every year in a last-minute panic before an inspection:
Labelling and classification may differ depending on the country of sale, so your PIM data structure should allow different values to be assigned to different markets for the same product from day one.
No system can replace a clearly designated person or team who keeps the data complete, approves new entries and follows up when a supplier doesn't respond.
You could treat the PPWR as just another box to tick – a folder full of PDFs, an Excel spreadsheet and an annual panic before the audit. With a small product range, that might even work. But at the scale typical of B2B distribution – thousands of SKUs, numerous suppliers and sales in several markets at once – a manual approach will break down sooner or later. And the stakes are high: an error in the declaration could mean a ban on sales across the entire EU, not just in one market.
What's more, this isn't a project you can complete once and forget about. Further PPWR requirements will come into force gradually over the next decade:
Companies with an extensive product range therefore need not so much one-off compliance as continuous operational readiness (Deloitte Poland).
This is where a PIM stops being merely a tool for attractive product descriptions in your online shop and becomes part of your compliance infrastructure – the place where packaging data is complete, up to date and ready to show whenever a market surveillance authority asks for it. Rather than building a separate, parallel process "for the PPWR", you can use this requirement as an excuse to do something that was needed long ago anyway: get to grips with how your company manages information about its products.
We implement PIM systems for wholesalers and B2B distributors. Instead of Excel, inboxes and PDFs from every supplier – a single product page showing the packaging material, weight, recyclability grade, linked documents and anything that's still missing. So that an inspection is a formality, not a frantic search for an email from six months ago.
See how we implement PIM
