The PPWR is not a law that can be ‘worked through’ on the side. From August 2026, there will be no escape. Anyone who cannot present a complete declaration of conformity at that point risks severe penalties, including a ban on the sale of their products. Many companies are lulled into a false sense of security, convinced that they know their role in the supply chain and have their data under control. The controversial truth is that many companies play multiple roles rather than just being ‘suppliers’ or ‘manufacturers’. On the one hand, this lack of knowledge poses a threat to the compliance and marketability of your products and, at the same time, can lead to over-compliance.
A workshop on PPWR is therefore not a nice extra service. It is the beginning of a survival strategy. It is the moment when the interdisciplinary team sits down at the table, the product lists are laid out on the table, and the supposedly clear world of packaging is broken down into its complex individual parts. We take you on such an expedition.
Day 0: Getting your data in order
The most efficient expedition begins long before departure. The biggest enemy of a successful workshop is searching for data on site. Minutes spent hunting for item numbers or material specifications are wasted time.
That's why our journey begins on Day 0 with a clear mission for the company: collect your data!
The goal is to create a centralised list that includes all products, sales packaging and transport packaging. Ideally, it should contain:
- Item numbers and descriptions
- Material descriptions that are as accurate as possible
- Associated transport units (pallet, carton, film)
Of course, this list is rarely perfect. Sometimes the transport packaging is only recorded as ‘pallet miscellaneous’ in the ERP system, sometimes the exact material fraction of the film is missing. But even an incomplete list is better than none at all. It is the map with which we start the expedition the next day.
Day 1: Deciphering the map
Morning: Theory and paragraphs
We start deep in the thicket of the PPWR. It's all about definitions. Who is a ‘manufacturer’? Who is an ‘importer’? Who is a ‘supplier’ or “distributor”? And what does it mean to be a ‘producer’? Most participants are surprised by the complexity. A company can play several roles simultaneously for the same product, which triggers different obligations. Anyone who produces empty bottles and delivers them to a bottler is a ‘supplier’ for the bottle. However, when it comes to the pallet and stretch film used to transport the bottles, they suddenly become a ‘producer’. This distinction is crucial because it determines who has to issue the declaration of conformity.
Afternoon: A tour of the hallowed halls
Theory is followed by practice: a tour of the factory. We walk through the production, filling and storage areas. Here, between machines and metre-high pallet racks, the PPWR becomes tangible. We see the customer-specific transport packaging that does not appear in any parts list. We discover the promotional campaign with the additional sleeve that was never recorded in the data. The tour of the premises is not sightseeing. It is a reality check that ruthlessly exposes the gaps between the ERP system and actual practice.
Day 2: The big clustering
With the insights gained from the tour, we return to the workshop room. Now the real detailed work begins: clustering. A portfolio of thousands of packaging SKUs paralyses any initiative. The quick way to master the complexity is to form meaningful packaging type groups.
We divide the entire range into 4 packaging categories©, which we have derived from the PPWR and each of which has its own specific requirements:
- Sales packaging
- Transport packaging
- E-commerce packaging
- HoReCa packaging
- Beverage packaging
We form clusters within these categories. An example: the PS yoghurt pot, which is used for 20 different fruit varieties, forms a single cluster. The declaration of conformity can be created for this entire cluster, as only the print image differs, not the packaging-related properties. This approach allows us to reduce a portfolio of thousands of items to dozens of manageable scenarios.
Then comes the moment of truth: clarifying the roles for each cluster in a matrix. To do this, we ask critical questions:
- Do you import this packaging from a third country?
- (-> Importer obligations!)
- Do you modify the packaging before reselling it?
- Do you market it under your own brand?
- Is your customer a micro-enterprise that is exempt from certain obligations? (-> Then the obligations fall back on you!)
This work is tedious. But it is the indispensable basis for being able to operate in a legally compliant manner.
Day 3: Digital tools and the path to declaration
The morning is devoted to transport units. What exactly is on a standard pallet? Which outer cartons, which stretch film, which strapping bands are used? Often, this information is in the minds of warehouse staff, but not in the system. We document these units and link them to the product clusters.
In the afternoon, technology comes into play. To prepare the declaration of conformity efficiently, we use our web tool ‘PPWR Check©’. The previously created cluster data and scenarios for packaging types by packaging category are uploaded in seconds using Excel templates. The tool analyses the data and provides a clear list of the staggered requirements for 2030, 2035, 2038 and 2040 for each scenario.
The result is a report that serves as the basis for the declaration of conformity. All relevant information is queried here: substances of concern, evidence of recyclability, recycled content, minimisation, etc. We run through example cases of how to fill in this information so that the team can then work independently. Often, the data first has to be requested and collected, but we can give a broad indication of some results, such as recyclability and the risk of a ban or failure to meet targets.
We then link the information from the status quo heat maps and other documents via our own server platform to create declarations of conformity that can be digitally signed and filed. This will be the case from around the beginning of the second quarter of 2026, so that the final, digitally signed declarations of conformity are available by the deadline at the latest and the information can be forwarded to customers.
Day 4: Art and the future
The PPWR is not the only law that requires labelling. Empowering Consumers to the Green Transition (EmpCo) will also impose strict rules on environmental claims from September 2026. To avoid the need for costly changes to artwork, we are reviewing existing designs as examples. What can stay? Where do ‘recyclable’ claims have to go? Which mandatory labels need to be added? Which claims should be reviewed by a solicitor in case of doubt?
At the end of the expedition, we look to the future. We provide a detailed outlook on upcoming requirements such as reusable obligations, recyclability certificates and minimisation targets. As many details will only be clarified by secondary legislation from the European Commission, this outlook is a living document.
Ready for the new world?
After four intensive days, the team is exhausted but relieved. The foggy monster that is PPWR has become a clear roadmap, and the product range has been clustered and reduced to a manageable size. The participants understand their roles, know their data gaps and have a process in place to manage compliance for their entire product range. Individual detailed questions will arise again and again.
The expedition shows that PPWR compliance is not an IT project and not purely a task for the sustainability department. It is an interdisciplinary team effort that requires strategic preparation, detailed operational work and the right digital tools.
Those who do not start now will find in August 2026 that their ship will unfortunately have to remain in port.
Are you ready for your expedition?
Contact us. We will help you draw your map and guide your crew safely through the PPWR jungle.