PPWR FAQ

The focus of this Q&A is practical: how to organize declarations, evidence, identification, traceability, and internal ownership in SyncForce Circular PIM so you can support audits and scale across many products, packaging variants, and suppliers.

Q: To be PPWR compliant, can we simply ask our packaging suppliers to provide the PPWR Declarations of Conformity?

Not by itself. Packaging suppliers can provide compliance information and evidence for the materials or components they supply, but the PPWR Declaration of Conformity is issued by the manufacturer responsible for the packaging that is placed on the market.

A practical way to organize this is as a Manufacturer:

• Collect supplier evidence (for example material composition declarations, food contact statements where relevant, REACH related information, test reports).

• Use that evidence as input for your PPWR technical documentation.

• Issue and sign the PPWR Declaration of Conformity at the level of the packaging type used for the product placed on the market, with clear identification and traceability.

This prevents a document collection approach and moves you to an auditable setup where evidence is sourced from suppliers, and the formal PPWR declaration is owned, controlled, and versioned by you as the responsible manufacturer.

Q: Do we need to print the Packaging System number on the packaging of every sales or transport unit?

No. PPWR requires that the manufacturer draws up a written Declaration of Conformity for each packaging type and that the declaration identifies the packaging and allows traceability. It does not require printing an internal Packaging System number on the packaging itself.

A practical compliant approach is:

• Use the GTIN on pack as the lookup key in your system.

• Store and retrieve all DoC versions linked to that GTIN.

Include the Packaging System number and a version or revision inside the DoC, so the declaration clearly identifies the packaging and links to the correct technical documentation and evidence set.

This keeps packaging marking simple, while still meeting the PPWR requirements for identification and traceability.

Reusable packaging and deposit return packaging

(additional requirements, later effective dates)

Deposit and return packaging must be marked with a clear and unambiguous label.

Reusable packaging placed on the market from 12 February 2029, or 30 months after the relevant implementing act enters into force (whichever is later), must bear a label stating it is reusable. Additional information must be made available via a QR code or other standardised open digital data carrier that supports tracking and the calculation of trips and rotations, or an average estimation if that calculation is not feasible.

PPWR does not say that your internal Packaging System ID must be printed as text. For reusable packaging you will typically want your internal identifier to be available behind the QR code or digital data carrier so you can manage trips, rotations, and audit traceability.

Target cycle count: PPWR foresees a delegated act to set minimum rotations for commonly used reuse formats by 12 February 2027.

Q: We use multiple suppliers for the “same” packaging component and their specs vary slightly. Can we declare one single value (for example weight) for PPWR?

Yes, but only if the single declared value still covers what is actually placed on the market and does not hide non compliant cases.

PPWR requires a Declaration of Conformity for each packaging type and expects that the declaration identifies the packaging and is backed by technical documentation. When multiple suppliers deliver variants within your approved ranges, your technical documentation should retain the supplier level specs and tolerances for traceability.

Recommended approach

• Keep three sets of specifications:

  • Specification requirements (target, min, max), used for sourcing/procurement

  • Supplier specifications (per supplier, per material or component)

  • Declared specifications (used in the DoC and reporting)

How to choose the declared value

• If a parameter can affect compliance in a worst case direction (for example higher weight can make minimisation harder), use a conservative declared value:

  • Declare the highest value, or

  • Declare a range and demonstrate compliance at the highest value.

• A weighted average can be useful for internal planning and reporting, but it is weaker as a compliance statement if a heavier sampled unit exceeds the declared number. If you use an average in the DoC, make sure the technical documentation clearly shows the allowed range and supplier values, and that all supplied variants remain covered.

When to create a new packaging type (new packaging system)
Split into separate packaging types when supplier differences could change compliance outcomes or the underlying assessment, for example changes in:

• Material composition or additives

• Inks, coatings, barrier layers, metallisation

• Weights or dimensions that impact minimisation claims

• Anything that affects recyclability performance or restrictions

This keeps one DoC defensible for what you actually place on the market while allowing flexibility in sourcing.