PLMV-KB-012 · Regulation & Compliance · Reviewed 2026-10-16
PPWR Data Requirements: Product and Packaging Data You Need
PPWR data requirements are the packaging attributes a company must hold to prove compliance with Regulation (EU) 2025/40. They include component-level materials and weights, heavy metal and PFAS data, recycled content, recyclability grade, reuse properties, a declaration of conformity per packaging type, EPR registrations and sales volumes per Member State, and harmonised label content.
Key takeaways
- PPWR compliance is evidenced at packaging component level, so a packaging bill of materials linked to each product is the core data structure.
- From 12 August 2026 companies need substance data, technical documentation and a declaration of conformity for each packaging type.
- Recycled content, recyclability grade and empty-space data become mandatory design attributes for the 2030 requirements.
- PLM typically owns packaging specifications and evidence, while PIM and ERP distribute label data and sales volumes.
Why PPWR is a product data problem
PPWR requires manufacturers to demonstrate conformity for each packaging type and to keep that evidence for five years (single-use) or ten years (reusable). Authorities and EPR schemes can request documentation, and producers are expected to provide it within short deadlines. Evidence therefore needs to be structured, versioned and retrievable by packaging type, by component and by market. Spreadsheets maintained by individual packaging engineers rarely meet that standard once a portfolio contains thousands of packaging variants, several suppliers per component and different label versions per market.
Which data does each packaging component need?
The table lists the core attributes, grouped by obligation. Dates refer to when the underlying requirement applies.
| Attribute | Level | Purpose | Applies from |
|---|---|---|---|
| Packaging type and category (sales, grouped, transport, e-commerce) | Packaging unit | Determines which rules apply | 12 Aug 2026 |
| Material and material grade (e.g. PET, PP, HDPE, board) | Component | Recyclability, labelling, EPR fees | 12 Aug 2026 |
| Component weight (g) | Component | EPR reporting, minimisation | 12 Aug 2026 |
| Lead, cadmium, mercury, hexavalent chromium (sum, mg/kg) | Component | 100 mg/kg limit | 12 Aug 2026 |
| PFAS test results and total fluorine | Food-contact component | 25 ppb, 250 ppb, 50 ppm limits | 12 Aug 2026 |
| Substances of concern register and supplier declarations | Component | Technical documentation | 12 Aug 2026 |
| Declaration of conformity ID and version | Packaging type | Conformity evidence | 12 Aug 2026 |
| Contact-sensitive flag | Packaging unit | Recycled content target selection | 2030 |
| Recycled content (%) with evidence | Plastic component | Minimum recycled content | 1 Jan 2030 |
| Recyclability grade (A, B, C) | Packaging unit | Market access | 1 Jan 2030 |
| Empty-space ratio | Grouped, transport, e-commerce | 50% maximum | 1 Jan 2030 |
| Reusable flag, minimum rotations, reuse system | Packaging unit | Reuse obligations | 2030 |
| Label pictogram and data carrier content | Packaging unit | Harmonised labelling | 12 Aug 2028 at the earliest |
Colour, opacity, adhesives, inks, closures and sleeves also affect recyclability assessments, so many organisations capture them now even though the grading methodology was still pending at the latest update reviewed (September 2026).
Conformity documentation and supplier declarations
The technical documentation links the specification to evidence: test reports, supplier declarations of composition, recycled content certificates and the conformity assessment outcome. Each document needs a validity period, an owner and a link to the exact specification version it supports. When a supplier changes a resin or a converter changes an ink, the declaration must be reviewed. This is a classic engineering change management pattern: the change request should trigger re-assessment of substances and recyclability before the new version is released.
Data for EPR reporting and labelling
Extended producer responsibility reporting combines specification data with commercial data: material weight per packaging unit multiplied by units placed on the market in each Member State. PLM usually owns the weights and materials, while ERP owns volumes. The producer also needs registration numbers per Member State and, for non-EU producers, authorised representative details. Fee eco-modulation will increasingly depend on recyclability grade and recycled content, so these attributes have financial as well as regulatory value.
Harmonised labels will carry material composition and sorting information, and data carriers such as QR codes may link to further information. Label content should be generated from the specification, then passed to artwork and to PIM for e-commerce channels, which must show the same information online.
How to structure the PPWR data model
A workable model has four layers:
- Packaging specification: versioned packaging unit with category, dimensions and empty-space ratio.
- Component bill of materials: each component with material, weight, colour, substances and recycled content, linked to the supplier.
- Evidence objects: declarations, test reports and certificates with validity dates.
- Market layer: EPR registrations, volumes and label variants per country.
Packaging specification tools such as Specright and process-oriented suites such as Siemens Opcenter RD&L model this structure natively, while general PLM platforms usually need configuration. Before selecting a tool, map current data ownership and check product data quality on a sample of packaging types; gaps in component weights and supplier declarations are the most common findings in typical PPWR readiness assessments.
Frequently asked questions
Which PPWR data must be available from 12 August 2026?
From 12 August 2026 manufacturers need technical documentation and an EU declaration of conformity for each packaging type, component-level material and substance data covering heavy metals and, for food-contact packaging, PFAS, plus EPR registrations and reporting data per Member State. Recycled content, recyclability grade and empty-space data support requirements that apply from 1 January 2030, so capturing them early reduces later rework.
Should PPWR data live in PLM, PIM or ERP?
Most organisations keep packaging specifications, component bills of materials and compliance evidence in PLM or a specification management tool, because that data changes with design. ERP holds sales volumes needed for EPR reporting. PIM distributes consumer-facing label and sorting information to e-commerce channels. The key requirement is one authoritative source for each attribute, with integrations rather than duplicate manual entry.
How granular must recycled content data be?
Recycled content targets apply to the plastic part of packaging, and the Commission is preparing implementing rules on calculation and verification. In practice companies record recycled content per plastic component, such as bottle, cap and label separately, together with supplier certificates and the mass balance or other method used. Component-level data allows the packaging-level percentage to be recalculated when one component changes.
Sources
- Regulation (EU) 2025/40 on packaging and packaging waste (EUR-Lex)
- European Commission: Packaging waste
Reviewed 16 October 2026 by the PLM Vendors editorial team. Regulatory dates and vendor details change; check the sources for the latest position.