The priority is to build data for each specific packaging item and design version. Manufacturers should know what the packaging is made of, how component changes affect the assessment and which evidence each PPWR requirement will need.
1. Map your packaging portfolio
Each packaging item should have a clear identity: format, materials, component weights, application, market and design version. Without this, it becomes difficult to reconstruct a subsequent conformity assessment.
2. Create an up-to-date bill of materials
The body, closure, label, sleeve, adhesive, inks, barriers and other components should be described by material and weight. Link supplier data to specific packaging versions.
3. Assess the design for recycling
The PPWR introduces legal requirements for packaging recyclability. It is already useful to identify components that could hinder sorting, washing or separation, or affect the quality of the recycled material.
4. Organise PCR data
For plastic packaging, establish how much of the material comes from post-consumer recycling, where the recycled material originates and how its content is calculated. Suppliers and documentation must enable verification of the data.
5. Build the technical documentation
The documentation should link product identification, drawings, the bill of materials, specifications, test results, assessments and change control. Do not postpone creating its structure until all detailed requirements fully apply.
6. Introduce change control
A new adhesive, label, barrier, supplier or recycled content percentage may alter the basis of an earlier assessment. The system should identify when a new review is needed.
7. Monitor delegated and implementing acts
Some detailed PPWR methodologies are specified in subsequent acts. Assign responsibility for monitoring legislation and establish a way to update documentation when new requirements are published.
8. Distinguish legal evidence from certification evidence
A third-party assessment or certificate can support the documentation, but it should not automatically be treated as confirmation of full PPWR compliance.
Key point
Preparing for 2030 is primarily a matter of building data and processes. A company that can quickly reconstruct a packaging design, material origins and change history will be much better prepared for detailed conformity methodologies.