The challenge
How do you create a signed Declaration of Conformity for packaging when every order can be packed differently?
For pre-packed products, the answer is relatively straightforward. The packaging combination is known upfront, repeatable and can be managed as a controlled packaging system.
For order-specific packaging, the situation is different. A B2B wholesaler may pack a mixed horeca order in an outer carton, on a dolly or on a mixed pallet. An e-commerce operation may add a shipping box, void fill, tape and a shipping label around a consumer order. Every shipment can be different.
The PPWR logic is not “one Declaration of Conformity per shipment”. PPWR requires a Declaration of Conformity per packaging type, supported by technical documentation and evidence. In SyncForce, the key is therefore to define the right operational compliance object for each packaging situation.
Why this matters
PPWR turns packaging compliance into an auditable requirement. From 12 August 2026, packaging placed on the EU market must be compliant and compliance must be provable with a Declaration of Conformity, technical documentation, evidence and traceability. The SyncForce PPWR readiness material frames this as a portfolio-wide operational challenge: every Sales Unit and Transport Unit needs an approved packaging system and auditable evidence to support the Declaration of Conformity.
That works well when packaging is repeatable.
It becomes harder when packaging is created dynamically after an order is received.
Without a scalable model, companies risk creating either too few compliance records, which creates audit risk, or too many documents, which creates operational complexity.
Two different packaging situations
In practice, companies need to distinguish between two situations:
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Fixed pre-packed product packaging
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Dynamic order-specific packaging
Both can be compliant. But they should not be managed in the same way.
1. Fixed pre-packed product packaging
For pre-packed products, the packaging structure is normally known before the product is placed on the market.
Examples:
Cup, lid, seal and label for yoghurt sales units.
Tube, cap and printed carton for toothpaste sales units.
Sleeve, glue dots or shrink wrap for a multipack with six sales units.
Outer carton, dividers, tape or glue closure, and case label for standard cases of 12 sales units.
Pallet, layer pads, pallet wrap, straps and pallet label for 48 cases of 12 sales units.
These combinations are repeatable. They can be approved, versioned, linked to evidence and technical documentation, and covered by a signed Declaration of Conformity.
In SyncForce, we model this as a Master Packaging System.
A Master Packaging System is the unique, approved combination of Packaging Masters that defines a packaging configuration. A Packaging Master is the technical base used for one or more packaging variants. A common example is a label master that has multiple décor variants for different flavours, languages or market packs.
A Master Packaging System can be used for sales packaging, grouped packaging and standard transport packaging. SyncForce already uses this logic: packaging elements and material splits sit behind the Packaging System, and the Declaration of Conformity can be generated from that controlled structure.
In many cases, one approved Master Packaging System can apply to multiple Sales Units or Transport Units, linked through their GTINs. The sales units below all have the same Master Packaging System.That avoids unnecessary document duplication while maintaining traceability.
2. Dynamic order-specific packaging
Order-specific packaging is different because the final packaging combination is often not known until the order is picked and packed.
Examples:
A wholesaler receives full pallets from brand manufacturers. A horeca customer orders a mixed set of products. The wholesaler picks the order and packs it in an outer carton, on a dolly, in crates or on a mixed pallet.
An e-commerce fulfilment centre receives a consumer order. The system selects a shipping box or mailer, adds void fill where needed, closes the parcel with tape and applies a shipping label.
In these cases, the packaging is still packaging. But the exact combination can change per order.
The variation can include:
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carton size
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pallet or dolly type
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number of sales units
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void-fill material and quantity
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wrap use
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strap use
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tape use
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label use
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load height
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reusable packaging status
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temperature zone
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route or customer-specific handling rules
This is where a fixed Master Packaging System is often too rigid.
The SyncForce solution: Packaging Patterns
For dynamic order-specific packaging, SyncForce introduces the operational concept of a Packaging Pattern.
A Packaging Pattern defines the approved boundaries for a category of order-specific packaging.
It does not describe one shipment.
It describes the approved way of packing a class of shipments.
Examples of Packaging Patterns:
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e-commerce small parcel
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e-commerce medium parcel
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fragile e-commerce parcel
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insulated e-commerce delivery
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mixed horeca order in outer carton
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mixed horeca order on dolly
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mixed B2B pallet
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back-of-store replenishment pallet
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reusable crate delivery pattern
A Packaging Pattern should define the allowed packaging logic, such as:
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approved carton sizes
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approved pallet, dolly, roll cage or crate types
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wrapping rules
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tape and closure rules
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label rules
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void-fill rules
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maximum load height
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reusable packaging status
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empty-space calculation method where relevant
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packaging components and material composition
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supplier evidence
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technical documentation references
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Declaration of Conformity scope
The Packaging Pattern is the controlled object. The actual shipment is recorded as a Packaging Instance.
Packaging Pattern ID
Each Packaging Pattern should have a unique, stable and persistent identifier.
Example:
Packaging Pattern ID: VTA-SYN-PK-5436BAF32*
Pattern name: E-commerce medium parcel
Pattern type: Order-specific e-commerce packaging
Packaging Instance: the actual packed shipment
A Packaging Instance is the actual order or shipment as packed.
The Packaging Instance should not become a new Declaration of Conformity object. It should link back to the approved Packaging Pattern that defines the boundaries for that type of order-specific packaging.
Examples:
Order 458921
Packed according to Packaging Pattern VTA-SYN-PK-5436BAF32
Pattern: E-commerce medium parcel
Horeca order 77412
Packed according to Packaging Pattern VTA-SYN-PK-7729HRC18
Pattern: Mixed horeca delivery on dolly
Store replenishment order 98221
Packed according to Packaging Pattern VTA-SYN-PK-8891SRP04
Pattern: Back-of-store mixed pallet
This is the key point:
The order records what happened. The Packaging Pattern defines what was approved. The Declaration of Conformity links to the approved Packaging Pattern, not to every individual order.
Why not one Declaration of Conformity per order?
A Declaration of Conformity per order would not scale.
A mid-sized B2B distributor or e-commerce operation can create thousands or millions of shipments per year. If every shipment required a new document, PPWR compliance would become a document factory.
The better model is:
Approve the packaging logic once. Record the actual shipment. Keep the link to evidence and the signed Declaration of Conformity.
That gives you traceability without creating unnecessary documents.
Master Packaging System versus Packaging Pattern
| Situation | SyncForce operational term | Best used for | Declaration of Conformity logic |
|---|---|---|---|
| Fixed product packaging | Master Packaging System | Sales packaging, grouped packaging, standard transport packaging | One signed Declaration of Conformity can cover the approved packaging system |
| Dynamic order packaging | Packaging Pattern | B2B order fulfilment, e-commerce, mixed pallets, dollies, order-specific cartons | One signed Declaration of Conformity can cover the approved pattern and its boundaries |
| Actual packed shipment | Packaging Instance | The real order or shipment as packed | Linked back to the approved pattern for traceability |
Relation to PPWR packaging types
The operational model does not replace PPWR terminology.
Under PPWR, packaging is classified by function. PPWR distinguishes sales packaging, grouped packaging and transport packaging. The SyncForce PPWR readiness material also applies the Declaration of Conformity logic across all three packaging levels: sales, grouped and transport packaging.
For order-specific packaging:
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B2B order delivery will normally be transport packaging
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e-commerce order delivery will normally be e-commerce packaging, with a transport and delivery function
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back-of-store replenishment pallets will normally be transport packaging
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service packaging filled at the point of sale is a separate case and should be assessed based on its function
The SyncForce terms Master Packaging System, Packaging Pattern and Packaging Instance are operational terms. They are not defined in PPWR. They are introduced to make the PPWR conformity assessment model workable in real supply chains.
Empty space and order-specific packaging
Order-specific packaging also matters because PPWR introduces empty-space requirements. The Commission FAQ summary describes a maximum 50 percent empty-space threshold for grouped, transport and e-commerce packaging from 2030.
That means a Packaging Pattern should not only define what components are allowed. It should also define how empty space is controlled and calculated where relevant.
For example:
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carton size selection rules
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maximum void-fill rules
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allowed box-to-order matching logic
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pallet height rules
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shipment consolidation rules
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exceptions for product protection or regulatory requirements
This makes the Packaging Pattern not only a compliance object, but also an operational control mechanism.
How SyncForce can support this
In SyncForce Circular PIM, fixed pre-packed packaging can be managed through:
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Packaging Masters
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Packaging Assembly Units
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Packaging BOMs
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Master Packaging Systems
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material splits
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supplier evidence
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technical documentation
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Declaration of Conformity automation
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GTIN linkage to Sales Units and Transport Units
For order-specific packaging, the same compliance logic can be extended with:
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Packaging Pattern IDs
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Packaging Patterns
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allowed packaging components
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allowed packaging rules
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packing limits
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reusable packaging status
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empty-space method
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Packaging Instances
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shipment-level traceability
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evidence linkage
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signed Declaration of Conformity linkage
This creates one connected model from product packaging to order packaging.
Practical implementation model
The practical implementation model is:
1. Define Master Packaging Systems
For all fixed, repeatable packaging combinations around Sales Units, Grouped Sales Units and standard Transport Units.
2. Define Packaging Patterns
For dynamic order-specific packaging in e-commerce, B2B fulfilment, wholesaler delivery, horeca supply and store replenishment.
3. Assign Packaging Pattern IDs
Each Packaging Pattern receives a unique and stable identifier, for example VTA-SYN-PK-5436BAF32, or another governed identifier used by the company.
4. Approve the evidence set
Link supplier declarations, material specifications, test reports, reusable packaging information, empty-space method and other technical documentation.
5. Generate and sign the Declaration of Conformity
For the approved Master Packaging System or Packaging Pattern.
6. Record Packaging Instances
Capture the actual shipment data and link it back to the approved Packaging Pattern ID.
7. Maintain traceability
Make sure each shipment can be traced back to the correct evidence and signed Declaration of Conformity.
The key principle
Fixed packaging combinations should be managed as Master Packaging Systems. Dynamic order-specific packaging should be managed as Packaging Patterns. Actual shipments should be recorded as Packaging Instances.
This is the scalable answer to the PPWR Declaration of Conformity challenge.
Conclusion
PPWR compliance should not turn every order into a new document.
For fixed pre-packed products, a Master Packaging System can be approved, versioned and covered by a signed Declaration of Conformity.
For order-specific packaging, companies need Packaging Patterns that define the approved boundaries of dynamic packaging operations.
The actual shipment then becomes a Packaging Instance, linked back to the right Packaging Pattern ID, evidence and signed Declaration of Conformity.
In practice, PPWR Declaration of Conformity automation needs one legal structure, but two operational core models:
Master Packaging Systems for fixed packaging.
Packaging Patterns for dynamic order-specific packaging.
Approve the pattern.
Record the instance.
Keep every shipment traceable.
* This example uses a VTA-style identifier structure:
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VTA = identifier namespace
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SYN = issuer code, in this example SyncForce
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PK = Packaging
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5436BAF32 = local identifier
The PK entity code is used because the Packaging Pattern is an identified packaging entity in the model. The exact identifier scheme is less important than the governance rule: the identifier must be unique, stable, persistent, not reused, and linked to the approved pattern, evidence set, technical documentation and signed Declaration of Conformity.
Any other robust internal or external identifier can also be used.