PPWR in practice: conformity, materials and recyclability
In previous blogs, we looked in more depth at the impact of the PPWR and the division of roles across the chain. But once your role is clear, the real work only just begins.
Ruben Haleydt
The biggest challenge for companies today isn't understanding the regulation, but getting compliance up and running operationally.
What do you actually need to do? Where do the difficulties lie? And where are companies already getting stuck today?
Conformity assessment: the underestimated workload
The obligation to carry out a conformity assessment looks logical on paper. In practice, it turns out to be a structural challenge for many companies.
Why? Because this assessment isn't based on a single source, but on a combination of data from different links in the chain.
For a single piece of packaging, you need to gather information on:
- material composition
- additives and coatings
- inks and adhesives used
- production processes
This information is rarely held by a single party.
In practice, this means approaching multiple suppliers, interpreting data and actively requesting missing information. The complexity, then, doesn't lie in the obligation itself, but in bringing together and validating the right data.
Transport packaging: the blind spot
One of the most underestimated elements within the PPWR is transport packaging. Many companies focus today on primary packaging (food contact), but forget:
- pallets
- stretch film
- strapping bands
- pallet collars
Yet these are fully subject to the same conformity obligations. This creates a double challenge:
- this packaging is often less well documented
- and is managed outside the quality system (logistics, procurement)
This is where, in practice, we see the biggest gaps arise.
The EUNR (European Union Network of Registers), the cooperation network of 16 national packaging registers, has recently brought additional clarity on this: rigid transport packaging such as pallets, crates and boxes falls under producer responsibility from the moment the packaging is empty, while flexible transport packaging such as stretch film and strapping only does so at the point of filling or use. You can read more about this in our article on manufacturer versus producer under the PPWR.
Materials: from "we think it's ok" to demonstrable compliance
The PPWR marks a clear shift: assumptions are no longer enough.
For substances of concern and heavy metals, you not only need to be compliant, but also need to be able to prove it.
The difficulty here lies in:
- the lack of complete material specifications
- limited transparency in the chain
- differences between suppliers
For PFAS, it becomes even more complex.
The assessment is based on the total fluorine content of the entire packaging. This means you can't look at partial aspects, but must understand the whole.
This requires in-depth knowledge of the materials used, correct analysis methods and consistent interpretation of results.
Recyclability: not a checklist, but an interpretation
Although the recyclability obligation seems clear, its practical implementation is not.
Until the further development of the European criteria (expected by 2028), companies must rely on existing standards such as EN 13430.
But the standards in EN 13430 leave room for interpretation, aren't always applicable in a uniform way, and also differ by material stream. This means companies already need to make choices today, without a fully harmonised framework.
So the question isn't just: is my packaging recyclable? But also: can I demonstrate this in a way that holds up under inspection?
The real challenge: fragmented responsibility
What these three domains have in common is that they're rarely owned by a single department. The quality department is involved for compliance and documentation. The procurement department selects suppliers and materials. Logistics is often responsible for the choice of transport packaging.
Without clear alignment between these departments, fragmentation quickly arises, with an increased risk of incomplete information and non-compliance.
In practice, we see the same bottlenecks recur:
- no complete overview of all packaging
- data that's missing or not validated
- uncertainty about how to interpret requirements
- no clear owner of the process
This leads to delays, frustration and increased audit pressure.
Companies making progress today approach it fundamentally differently: they don't build a one-off compliance exercise, but a structured and integrated system. They do this by centralising packaging data, standardising documentation, establishing clear internal responsibilities, and seamlessly integrating everything into their existing quality processes.
Where do you stand today?
Do you have a clear view of all your packaging, including transport packaging? Do you have the right data to demonstrate compliance? Are responsibilities clearly established internally?
If not, now is the time to tackle it.
AMNorman helps you bring structure to complexity and turn compliance into control.
