Packaging material data requirements under PPWR: the complete field list
The EU Packaging and Packaging Waste Regulation (PPWR) — Regulation (EU) 2025/40 — requires every producer to hold documented data on every packaging format they place on the EU market. This is not optional supplementary information. From 12 August 2026, the Declaration of Conformity and technical documentation for packaging are regulatory requirements, and the data behind them must be available to authorities on request.
The EU Packaging and Packaging Waste Regulation (PPWR) — Regulation (EU) 2025/40 — requires every producer to hold documented data on every packaging format they place on the EU market. This is not optional supplementary information. From 12 August 2026, the Declaration of Conformity and technical documentation for packaging are regulatory requirements, and the data behind them must be available to authorities on request.
This guide lists the specific data fields the PPWR requires, explains where the data comes from, and describes what to prepare now versus what comes in later phases.
Why packaging data matters now
Under the previous directive, packaging obligations were primarily about EPR registration and fee payment. The data you needed was relatively simple: material type, weight, and volume per unit. National schemes collected this for reporting purposes.
The PPWR changes the scope of what you need to know about your packaging. Design requirements, substance restrictions, empty-space limits, and recyclability criteria all require underlying data that most sellers have never collected systematically.
The gap is not theoretical. Across products scanned on Regonance, packaging-related compliance data is among the most frequently missing categories. Sellers often have product compliance data but lack structured information about the packaging those products ship in.
The core data fields
Identity and classification
- Packaging format description — what the packaging is (e.g. "corrugated cardboard shipping box," "LDPE polybag," "glass bottle with aluminium cap").
- Packaging function — primary (sales), grouped, or transport packaging. This classification determines which PPWR rules apply.
- Packaging level — whether the packaging is single-use or reusable. Different obligations attach to each.
- Material type — the dominant material (plastic, paper/cardboard, glass, metal, wood, composite, other).
- Material composition detail — for plastics: polymer type (PET, HDPE, LDPE, PP, PS, etc.). For composites: all material layers. For paper: whether coated, and with what.
- Weight — net weight of the packaging component in grams, excluding the product.
Substance data
- Heavy metal concentrations — the sum of lead, cadmium, mercury, and hexavalent chromium must be below 100 ppm. This is a continuing requirement from the previous directive, now within the PPWR framework.
- PFAS concentration — for food-contact packaging, per- and polyfluoroalkyl substances must comply with Article 5 limits. This requires supplier declarations or test certificates.
- Substances of concern — the PPWR requires minimisation of substances of concern in packaging. While detailed implementing rules are expected later, producers should begin tracking known restricted substances.
Design requirements (applicable from August 2026)
- Empty-space ratio — for ecommerce packaging, the ratio of empty space to total package volume. Must not exceed 40%.
- Packaging minimisation — packaging must be designed to minimise weight and volume while maintaining its protective and informational functions. No fixed threshold yet, but the principle is enforceable.
Design requirements (phased in later)
- Recyclability grade — A, B, or C classification. Expected from 2028.
- Recycled content percentage — minimum targets for plastic packaging. Expected from 2030.
- Material identification marking — harmonised labelling for sorting. Expected from 2028.
Documentation
- Declaration of Conformity — a formal declaration that the packaging meets the PPWR essential requirements. Must be prepared by the manufacturer or their authorised representative.
- Technical documentation — supporting evidence for the Declaration of Conformity, including material test reports, supplier declarations, and design specifications. Must be available to authorities on request.
Where the data comes from
Most sellers do not manufacture their own packaging. The data chain typically runs: packaging supplier → brand/seller → EPR scheme → authorities.
From your packaging supplier: material composition, weight, substance test certificates (heavy metals, PFAS), supplier declarations. Request these proactively — many suppliers have standard documentation available but do not send it unless asked.
From your own operations: packaging format descriptions, function classification, empty-space ratios, which products use which packaging formats.
From EPR schemes: registration numbers, reporting templates, fee structures. These are country-specific and scheme-specific.
If your supplier cannot provide material composition data or substance declarations, that is a supply chain gap that needs addressing. The PPWR puts the documentation obligation on the producer, but the underlying data often originates upstream.
What to do now
Step 1: Create a packaging inventory. List every packaging component across your product range. Include retail packaging, shipping packaging, labels, inserts, and protective materials.
Step 2: Request supplier documentation. For each packaging component, request from your supplier: a material specification sheet, a declaration of heavy metal compliance, and (for food-contact packaging) a PFAS test certificate or declaration.
Step 3: Prepare Declarations of Conformity. For each packaging format, prepare a Declaration of Conformity. This should reference Regulation (EU) 2025/40, identify the packaging format, state that the essential requirements are met, and be signed and dated.
Step 4: Map EPR registrations. For each EU country where you place packaged products on the market, confirm you are registered with the national EPR scheme and that your registration covers the packaging types you place.
Step 5: Measure empty-space ratios. For your standard ecommerce shipment configurations, measure the void-fill percentage. Adjust packaging sizes if the ratio exceeds 40%.
How Regonance helps
Regonance scans your product listings and surfaces missing compliance fields across GPSR, PPWR, EPR, EmpCo, and other EU mandates. The platform identifies packaging-related gaps alongside product compliance issues, giving you a single view of what is missing and what to fix.
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Educational information only. Not legal advice. The PPWR's detailed implementing acts for recyclability, recycled content, and labelling are still being developed — monitor the Official Journal for updates.
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Compliance guidance based on published EU regulatory texts. Not legal advice. Consult qualified counsel for your specific situation.