One thing has become clear in our workshops: The theory of the EU Packaging Regulation often clashes harshly with organisational practice. It is not enough to want to become more "sustainable" in terms of the circular economy. You have to be data-driven, transparent and radically honest with your own processes.
"The PPWR is complex," emphasises Peter Désilets, Managing Director of Pacoon. "The amount of packaging in the company often seems 'unmanageable'. However, our workshops show that with the right screening and structuring of packaging based on a packaging article list, even tens of thousands of SKUs can be quickly organised." Often, however, the sheer fear of the quantity of articles prevents you from getting started.
Here are 10 important practical learnings from the workshops that you need to know in order to avoid standing in front of closed market doors from August 2026.
1. the role roulette of the PPWR: Who am I actually?
Perhaps the biggest surprise in our workshops is often the realisation that companies misjudge their own role in terms of the PPWR.
Am I a manufacturer? Producer? Importer? Or just a retailer?
The learning:
There is rarely just one role. A company can be a supplier for a component (e.g. the closure), a producer for the transport packaging (pallet + film) and an importer for an accessory at the same time. Each of these roles triggers different obligations: from data delivery to full liability for the declaration of conformity. Those who do not define their role for each usage scenario risk losing compliance.
2 Germany is forging ahead: The Packaging Law Implementation Act sets new standards
Many are waiting for Brussels, but facts are already being created in Berlin. The upcoming Packaging Law Implementation Act anticipates parts of the PPWR for the German market - if it is passed in its current draft form. France also already has many requirements that will apply throughout the EU from 2030 with the PPWR.
The learning:
Don't start planning for the big EU deadlines. Prepare for the fact that Germany will switch on the first packaging requirements from August 2026 (planned) and France already has high requirements. The PPWR is already here, so to speak. If you sleep on this, you will lose your most important sales market even before the EU-wide bureaucracy takes full effect.
3. packaging management vs. category chaos: one-size-fits-all does not work
Sales packaging, transport packaging, e-commerce packaging, HoReCa packaging or beverage packaging? Categorisation is not trivial, but it is crucial for business.
The learning:
The PPWR requirements for packaging differ massively depending on the category and application scenarios within the categories or even across categories. For example, transport packaging will soon be subject to strict reusable quotas that do not exist for sales packaging - unless it is used in exchange with other economic operators. Incorrect categorisation can lead to you setting up expensive reusable systems where none would be necessary - or, conversely, to you ignoring legal reusable obligations and being sanctioned or having to react at short notice. Setting up new systems takes a lot of time.
4 PPWR compliance requires a data diet: radically reduce complexity
In our workshops, we often see Excel lists with 5,000 or tens of thousands of article numbers. The first impulse: panic. How are you supposed to create declarations of conformity for this many articles? Unfortunately, the data requirement for PPWR compliance precedes the ERP systems, which still have gaps.
The learning:
The solution lies in clustering. Thousands of SKUs often become a few hundred or even fewer "packaging types", which we call scenarios. A yoghurt pot remains a yoghurt pot, regardless of whether it contains strawberry or cherry yoghurt. Simplifying structuring in the ERP system is the key to coping with the flood of data.
5 The blind spot of the packaging strategy: transport packaging and recycling
While every material is often identified in primary packaging, there is often a lack of awareness when it comes to transport packaging. Which transport packaging is used, does each transport packaging have an article number, and have transport units been identified and named?
The learning:
There is a massive lack of basic data for tertiary packaging. But the regulation makes no distinction here. Binding data for the declaration of conformity must also be available for the pallet and transport protection. Start the dialogue with your logistics service providers and film suppliers at an early stage and assign article numbers!
6 The ERP illusion: There is no "one-for-all" solution for compliance
Many IT departments promise: "The next update of our ERP system can do this." Our experience says: No, it can't. At least not now and not in the necessary depth. PPWR compliance requires answers that are not available in any ERP system. These data fields first have to be set up and filled with information. How quickly this works also depends on your IT service provider.
The learning:
Most ERP systems are financial and logistics tools, not compliance machines for complex material fractions. Waiting for SAP and co. to deliver a plug-and-play solution for the PPWR check is a bet on time that you could lose. Bridge solutions and specialised tools for the new requirements (like our PPWR Check©) are needed to close the gap between the status quo and compliance in 2026.
"Our web tool is designed to collect and manage the necessary data from suppliers as well," says Peter Désilets. "This data can later be integrated back into the ERP systems once they have been prepared. We don't see ourselves as a new ERP solution, but as a bridge."
7 The conundrum of the declaration of conformity: Which company supplies which data?
Who creates it? The supplier of the empty box or the brand manufacturer who fills it? And what should this document look like?
The learning:
Responsibility in the supply chain is often passed on like a hot potato. One thing is clear: the end result must be a declaration that is as digital and legally valid as possible. Contractually clarify who supplies which data. Don't rely on the upstream supplier "just sending something". Without a valid database, there is no declaration of conformity - and without a declaration, you risk losing the sale of your goods.
8. inbound check of the supply chain: reusability is not a one-way street
The PPWR not only requires you to offer reusable packaging, but also regulates how you receive goods and manage them in the loop.
The learning:
Companies need to scrutinise their inbound processes. Are your warehouse processes designed to accept, store and return reusable transport packaging from suppliers or to clean it yourself? Collaboration along the supply chain is no longer optional, but operationally necessary. And talk to your suppliers to reduce the complexity of the variants in good time and make the effort manageable for you.
Peter Désilets: "In the ENFIT 360 ReUse working group, we are working with experts along the reusable supply chain and companies to develop standards and solutions for reusable containers. Because refilling a container is one thing. Managing and tracing the contents in a contamination-free and hygienic manner is a completely different challenge."
9. the global view of the EU regulation: all markets, all packs
A common misconception: "We're doing this for our top sellers in Germany first." Did you know that transport packaging already has to be registered in every country in the world and that packaging quantities often have to be reported? Regardless of whether you have to pay disposal fees.
The learning:
The new EU Packaging Regulation applies to the entire EU internal market. If you export to France, Italy or Poland, all packaging there must be compliant. Deadlines and registration obligations in the national registers (such as LUCID in Germany and its counterparts in other countries) must be meticulously monitored. And transport packaging must also be registered if it is not to get stuck in customs.
10. packaging artwork at the limit: time is running out
Changes to packaging design take a long time. Anyone who has ever accompanied a relaunch knows that it takes months from the finished design to the shelf.
The learning:
From 12 August 2026, artwork must be adapted to the labelling requirements. This concerns the correct manufacturer labelling and, from September 2026, also the verification of all "green claims" in accordance with the EmpCo Directive (Empowering Consumers to the Green Transition). If you don't start redesigning now, you risk having to destroy tonnes of packaging material in 2026 or pay fines because the printed images are not legally compliant.
Acting instead of hoping
The PPWR is a change project that goes far beyond the sustainability department. It affects purchasing, IT, production, marketing and logistics. Our workshops show time and time again that as soon as all stakeholders sit around a table and the data is made transparent, the monster loses its terror. It becomes a task that can be solved. But you have to start now.
"We are happy to help companies with this and use these ten lessons learnt to go through the packaging portfolios, cluster the packaging and check the information for the declaration of conformity," says Peter Désilets.
The preparatory work lies with the customer, who should prepare an overview of their packaging and the application scenarios. Then, in two to three days of concentrated work, thousands of packaging types can be structured and prepared for the declaration of conformity.
"We then create these via our data server and link the relevant documents. And with cooperation partners such as Jelena Dimitrijevic from RegFocus Consulting on topics such as ingredients, substances of concern, contact sensitivity or REACH, we can also bring more clarity to these topics. Or customise the ERP systems with our data for the declaration of conformity."