This development has the potential to fundamentally change established business processes. As companies across the country prepare for new materials, supply chains and manufacturing processes, something else is coming their way: an enormous flood of data in the wake of the PPWR.
Our blog post in December focussed on the packaging itself, but today we want to take a look behind the scenes. After all, the PPWR is not just a material regulation, but also a massive driver of digital transformation. Anyone who believes that the changeover is simply about replacing composite films with monomaterials is overlooking the administrative iceberg beneath the surface.
Verification and labelling: the PPWR demands transparency
In the past, it was often enough for the purchasing department to know that film X had been ordered and for the marketing department to know that it looked very sustainable. Those days are over. The PPWR demands transparency at a level of detail that simply overwhelms many of today's IT landscapes.
By 2030, companies will not only have to claim that their packaging is legally compliant in several stages. They will also have to prove this, provide information on the packaging and demonstrate compliance. Seamlessly and legally compliant. And for each individual sales unit or type of packaging, sometimes even in several ways. Pacoon Managing Director Peter Désilets points out that a sales unit or type of packaging can be used in different situations. "And these situations can lead to different requirements that need to be met."
This is where regulatory requirements collide with the harsh reality of outdated ERP systems. In many companies, packaging data is still neglected and often hidden in free text fields or PDF data sheets on local drives. This is now becoming a cost and risk factor. And when the digital product passport (DPP) is introduced later, paperwork will no longer be enough.
The digital transformation is often only just beginning
A recent report by the Landbell Group shows that almost 58% of the companies surveyed in the DACH region consider their ERP and data management systems to be "insufficiently prepared" for the PPWR requirements. SMEs in particular lack efficient digital interfaces and standardised data models for recording and transmitting packaging information.
A study conducted by GS1 Europe in 2025 came to similar conclusions: In a survey of 220 FMCG manufacturers, 65% stated that their IT systems in the area of packaging data require extensive adjustments in order to be able to report the required proofs, recycling percentages and material fractions in a compliant manner.
Another key finding is that only 12% of companies currently have automated processes in place to capture and maintain packaging-specific data such as material type, weight, recycled content or recycling-specific additives. The rest continue to rely on manual or semi-manual processes. This not only harbours the potential for errors, but can also lead to considerable costs and delays in the event of a check or report to central registers.
"In Europe, where discussions about the PPWR have dominated the agenda for years, companies are already lagging behind with their preparations," observes Peter Désilets. "We are travelling around the world and making companies aware of the PPWR, which will require initial declarations of conformity from August 2026. The proportion of companies that are familiar with the PPWR in detail is probably in the single-digit range."
Packaging data must be entered in the master data.
The question is therefore no longer whether ERP systems need to be adapted, but how quickly. In order to fulfil the requirements of the new EU Packaging Regulation, ERP systems must learn to view packaging not just as a cost centre or logistical shell, but as a complex product with its own master data and a new level of detail.
What must a modern system be able to do in future?
- Granular material breakdown: It is not enough to store "plastic". The system must be able to differentiate between PET, PE, PP and their material fractions, including additives, colourants and adhesives that could impair recyclability.
- Weight management from milligrams to tonnes: Calculating royalties and quotas for the use of recycled material requires accurate and consistent weight data for each component of the packaging.
- Tracking recycled content: Where does the material come from? Is it post-consumer recycled (PCR) material? Are the relevant recycling certificates available? This information must be dynamically linked to the batch.
- Interoperability: The data must not be isolated. It must be exportable: to central registers, to customers and, in future, to open platforms for the digital product passport. At the same time, it must also be possible to import external data, as the complexity of data flows continues to increase.
Companies that do not invest in master data management now run the risk of finding themselves in reporting chaos during the first audits.
The "Digital Packaging Readiness Index 2025" also shows the urgent need for action: 82% of participating companies state that they will make significant investments in new software solutions or the customisation of ERP modules within the next 18 months. Nevertheless, 45% complain that the integration of standardised data transfers to partners and authorities is still "in its infancy".
"We are currently receiving more and more enquiries from people who are looking for the IT equivalent of a goose that lays golden eggs," says Peter Désilets. "As far as we know, apart from our PPWR Check© web tool, there is no other software that can check PPWR requirements and automatically digitise the data. Even ERP systems cannot perform these checks with today's data, as essential information has never been captured. We want to remedy this shortcoming in the future and link the data to ERP systems. Until then, we are preparing our own external platform to store all data and documents and to create and provide the declarations of conformity."
A new job profile is emerging
This new complexity requires a new responsibility. A new job description is already emerging among the industry pioneers: the packaging data manager.
This role is the link between packaging development, purchasing, IT and sustainability management. Packaging data managers are not the ones who design packaging. They are the architects of data flows. Their tasks include
- Ensuring data quality: validation of technical data sheets from suppliers.
- System maintenance: transferring physical properties to digital twins in the ERP system.
- Compliance monitoring: Monitoring the achievement of recycling percentage targets based on real data, not estimates.
- Interface management: Preparation of data for EPR (Extended Producer Responsibility) reports. .
For HR departments, this means that the requirements profile for packaging engineers is shifting. IT affinity and an understanding of data are becoming core competences.
"However, the connection to packaging must remain, and it is important to understand what requirements the future will bring," emphasises Désilets. "Where is the market heading? What new types of packaging are we facing? What data will need to be integrated in the future and what will the legislation bring? Do I view my packaging as an island or as part of an overall data network? For example, the warehouse data, the pending reorders, linked to my packaging supplier, who places material orders to prepare his production so that he can directly replenish his short-term interim stock?"
This area is also still growing: according to the GS1 study, only around eight per cent of the companies surveyed currently have a dedicated packaging data manager or are at least planning to hire one. However, this proportion is likely to increase significantly by 2027 in order to meet the increasing regulatory and sustainability requirements.
Different packaging, different supply chain
Perhaps the biggest obstacle to PPWR compliance lies outside your own four walls: in the supply chain. How can I get reliable data from my upstream suppliers?
Until now, much has been based on trust and static certificates sent once a year or by email on request. The PPWR forces the digital integration of the supply chain. Companies need to strengthen collaboration with suppliers across the entire value chain in order to receive data in standardised formats. And which supplier is willing to reveal their trade secrets, such as upstream suppliers or overly detailed material specifications? And who will check the data for accuracy?
This leads to an exciting dynamic:
- Smaller suppliers are under pressure: those who cannot provide digital data may be categorised as high-risk suppliers and could be removed from the list.
- Platform economy: More and more cloud-based platforms are emerging where suppliers upload their packaging specifications, which then flow directly into brand owners' ERP systems.
- Auditing: Simply stating that something is "recyclable" is no longer enough. Proof in accordance with recognised standards is required.
A Landbell Group survey of leading packaging manufacturers shows that 72% of companies see the lack of standardisation of supplier data as an obstacle to PPWR compliance. 51% have already launched initiatives to significantly increase transparency in the supply chain.
Challenges, best practices and the sustainable path to compliance
The figures and studies collected clearly show that the industry is on the right track, but has not yet reached its goal. Many companies are still at an early stage of transformation and in some cases underestimate the complexity and depth of the new data requirements.
Best practices such as the introduction of standardised exchange formats, targeted training for employees, the establishment of cross-functional data management teams and close coordination with IT and sustainability departments are considered key factors for successful PPWR compliance.
Digitalisation as a survival strategy
The PPWR is much more than an ecological regulation in the sense of the circular economy. It is a catalyst for digitalisation in the FMCG and packaging industry. The invisible change is also taking place in the server rooms.
For companies, this means that those who view sustainability solely as a material issue are falling short. The winners of the PPWR era will be those who value their packaging data as much as the product itself. Because in the end, no data means no compliance. And that means no more market access.