Packaging data has become one of the most critical – and most fragile – elements of PPWR and EPR compliance. While the regulatory intent is clear, the practical reality is far more difficult: companies across the value chain are struggling to collect, validate, maintain, and distribute the data required to stay compliant. What used to be a simple annual declaration has evolved into a continuous, high-stakes data management challenge involving thousands of data points, multiple stakeholders, and constant regulatory change.
The data burden keeps expanding faster than companies can absorb
PPWR and modern EPR schemes demand a level of granularity that most organisations were never built to handle. Beyond material type and weight, businesses now need component-level specifications, recyclability attributes, recycled content verification, substance information, and performance data that touches chemical, technical, and regulatory layers.
For many organisations, this explosion in data requirements exposes a deeper structural issue: their systems cannot store, track, or update information to the level of precision the legislation now expects. The gap between regulatory expectations and data readiness continues to widen.
Fragmented supply chains slow everything down
Even when companies know what data they need, they often don’t control it. Multi-tiered global supply networks, inconsistent data practices, non-EU suppliers unfamiliar with EU rules, and highly variable technical capabilities are now common barriers. Suppliers receive overlapping questionnaires from different customers, each with slightly different formats, leading to slow responses, incomplete data, and continual follow-ups.
Meanwhile, private-label retailers rely on hundreds of suppliers—many of whom lack the resources or expertise to provide detailed packaging data—making the entire process slow, error-prone, and operationally draining.
Internal data silos undermine consistency and accuracy
Inside most companies, packaging data is scattered across departments such as design, procurement, sustainability, marketing, logistics, and compliance. Each unit tracks its own version of the truth. Packaging redraws, material substitutions, artwork updates, and supplier changes often fail to flow back into a central system.
This creates common issues: conflicting weights for the same SKU, outdated specifications circulating in different teams, and duplicated or incomplete records. When reporting deadlines arrive, compliance teams must piece together scattered information under pressure, with no guarantee of alignment to what is actually on the market.
Maintenance and standardisation pain points
- Packaging data remains fragmented across business functions. Without a unified data system, teams update information differently, creating inconsistencies, version conflicts, and preventable reporting errors.
- Harmonisation across EU countries is still lacking. Every market operates with its own EPR reporting definitions, material classifications, portals, and timelines. This forces teams to manually rework data for each jurisdiction, multiplying workload and increasing the risk of mistakes.
- No universally accepted methodology exists for measuring recycled content. This undermines comparability, verification, and audit readiness—three elements central to PPWR and EPR compliance.
These systemic gaps create friction in routine operations and make even basic updates disproportionately time-consuming.
Regulations evolve continuously, but business processes don’t
PPWR implementation acts, eco-modulation criteria, recyclability frameworks, and national EPR rules change frequently. Fee tables update annually, categories shift, definitions evolve, and new reporting obligations appear with little notice.
Most internal systems, spreadsheet-based workflows, and manual processes cannot adapt at the same pace. Changes ripple across BOMs, artwork, supplier declarations, internal databases, and customer requirements—creating a constant uncertainty about which version of the data is correct.
The industry-wide impact is becoming harder to ignore
- The administrative burden of PPWR and its associated labelling, traceability, and certification requirements is substantial. EU estimates place one-off industry costs for new systems in the tens of billions, with over €1 billion in annual recurring compliance costs.
- Industry bodies warn that fragmented data systems and weak engagement across the value chain undermine transparency and accountability, making compliance far less reliable.
- Production and sustainability teams are overwhelmed by the sheer volume of data points required for PPWR, EPR, ESPR, and related frameworks—sometimes hundreds or thousands per product line.
This isn’t an isolated problem. It’s a structural one spanning organisations, sectors, and countries.
Distribution challenges multiply the risk
Once data is collected and temporarily stabilised, it must still be distributed across multiple stakeholders—regulators, PROs, customers, internal finance teams, and ESG reporting functions. Each requires different formats, levels of detail, validation rules, and submission cycles.
Inconsistency at this stage leads to financial leakage, misaligned forecasts, rejected submissions, or even penalties. With manual processes, every additional stakeholder magnifies the operational risk.
A strain on governance, accountability, and operational integrity
Perhaps the most worrying trend is the lack of clear ownership. Packaging sits at the intersection of design, sourcing, sustainability, and compliance, but no single team typically holds end-to-end responsibility for the data.
- Confusion over who should maintain which attributes
- Disagreements over classifications and interpretations
- Reactive reporting cycles instead of proactive governance
- A chronic sense of “data insecurity” each time new reporting obligations emerge
Across the supply chain, the ongoing struggle to collect, maintain, and distribute packaging data for PPWR and EPR compliance is no longer just a regulatory inconvenience. It is now a fundamental threat to operational efficiency, business continuity, and regulatory integrity.
Benefits of Building Packaging Data Systems Now
Starting early with structured, accurate packaging data management brings transformational value for long-term compliance under PPWR and EPR rules.
- Businesses who invest in comprehensive, transparent packaging data now gain cost control by predicting fee implications and spotting non-compliant formats early, avoiding expensive last-minute redesigns or penalties.
- Proactive data management ensures regulatory readiness, protecting against shipment blocks, audits, or fines as legislation becomes stricter and reporting deadlines shrink.
- With digital product passports and increased traceability requirements on the horizon, companies that already have centralized, version-controlled data systems will adapt effortlessly, saving resources and staying ahead of competitors.
- Reliable data facilitates smooth cross-team collaboration, breaking down silos and enabling easy export of country-specific compliance reports—keeping compliance stress-free and continuous.
In short: the lack of robust packaging data infrastructure is making PPWR and EPR feel far harder than they need to be, turning what should be strategic compliance into an exhausting operational struggle. Now is the moment for companies to invest in building a reliable, comprehensive packaging data repository—because without it, the pressure, complexity, and risk will only grow.