Why you need to know your (packaging) suppliers better

The PPWR requires you to be able to demonstrate what your packaging contains and that it meets the applicable requirements. Traceability is therefore no longer an administrative exercise. It is a structural part of your operations.

In ‘What is the PPWR and what does it change for your business’, you can read what the PPWR entails and which businesses it applies to.

Raw materials and circular economy
Supply chain

What exactly do you need to be able to demonstrate?

The PPWR requires you to demonstrate that your packaging meets various criteria, including:

  • recyclability (via the forthcoming D4R criteria)
  • recycled content (PCR)
  • presence of regulated substances (such as PFAS)
  • conformity through supplier documentation

This goes beyond isolated data points: you must be able to collect, substantiate and present this information in a structured way at any time. Evidence must be available per packaging type and retained for several years, depending on the specific obligation and national requirements.

Most importantly, you cannot do this alone. You depend on data from your entire supply chain.

The 5 key things you need to demonstrate

To be compliant, you must in practice be able to substantiate at least the following:

  • Origin of recycled material (PCR)
    You must be able to demonstrate where the recyclate comes from. Certification (such as ISCC PLUS) is often best practice but is not legally required in all cases.
  • Information on materials and substances used
    You must be able to demonstrate that your packaging meets the limits for hazardous substances (such as PFAS), including coatings, inks and additives where relevant.
  • Declaration of conformity per packaging type
    The manufacturer must draw this up. As an importer, you bear responsibility if it is missing.
  • Recyclability score (D4R)
    You must be able to substantiate how your packaging scores on recyclability, based on the forthcoming European criteria.
  • Systematic document management
    All documents must be centrally available, correctly stored and accessible during inspection.

Overlap with other European legislation

The PPWR does not stand alone. Several other European regulations impose strongly overlapping information requirements under the due diligence framework. It therefore makes sense to put in place a single system that supports multiple due diligence obligations at once:

  • CSDDD (phased introduction) – supply chain due diligence: large companies must demonstrate that their entire chain has no negative impact on people or the environment. Do you supply to large customers? Then they will ask you for data on your suppliers, materials and risks. Even if you are not directly subject to the law, you will be indirectly affected by it.
  • EUDR – deforestation-free raw materials: when you use paper, board or wood in your packaging, you must be able to demonstrate that these materials do not originate from deforested areas. Geolocation data is often required. Certificates (FSC, PEFC) help but are not always sufficient on their own.
  • Sustainability claims (EmpCo and future Green Claims rules): claims such as “100% recyclable” or “30% recycled material” are only permitted where they can be objectively substantiated. Under current rules (such as EmpCo) scrutiny is already tightening, and the forthcoming Green Claims legislation will tighten it further. The data you collect for the PPWR is therefore also your evidence against greenwashing.

The PPWR is one of the concrete applications of broader due diligence legislation. In our due diligence hub, we explore how these different rules interact and what that means for your organisation.

One system for everything

The most strategic and efficient approach is a single integrated system rather than separate workstreams for each regulation. The building blocks of such a traceability system are:

  • Supplier register
    Not just your direct suppliers, but also recyclers, coating suppliers and other relevant links in the chain.
  • Central document storage
    Certificates, test results and declarations, with monitoring of expiry dates.
  • Packaging data library (extendable to all raw materials)
    Per packaging type: materials, D4R assessment, PCR percentage, documentation.
  • Contractual arrangements
    Make compliance a requirement in your purchasing terms.
  • Periodic verification
    Internal check or external audit to keep your system reliable.

What if you are a smaller business?

Even though the CSDDD due diligence obligation applies only to the very largest companies, ensuring traceability also has an impact on medium-sized businesses and SMEs. In practice, many large businesses pass their obligations down to their suppliers.

This means that SMEs will also receive questions about packaging, will need to be able to provide evidence and must be transparent about their chain. Even if they are not directly obliged by law.

How to start today

  • Map all your packaging and raw material suppliers (including indirect ones).
  • Identify which materials fall under which regulation (EUDR, PPWR, etc.).
  • Set up a central system for document management.
  • Anchor PPWR requirements in your purchasing contracts.
  • Put in place a monitoring and due diligence system.

Businesses that set this up properly now will avoid four separate compliance exercises later.

Do you have a full overview of all the data in your packaging chain today?

The PPWR demands more than isolated documents – it requires a structured system.

Do you need help setting up your packaging data and supplier structure in a targeted way? Schedule a no-obligation consultation at mail@pantarein.be.