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PPWR-solution for everyone who doesn’t want to build it twice

Every piece of packaging you place on the EU market needs an EU declaration of conformity and the evidence behind it. We bring both into one digital packaging record, on the same platform that later runs your Digital Product Passport.

Legal Basis Regulation (EU) 2025/40 Art. 15 and 16, Annex VII
IN FORCE SINCE 12. August 2026 for anything newly placed on the market
WHO IT APPLIES TO Anyone selling under their own brand not the plant that manufactures the packaging
WHAT YOU NEED One record per packaging type declaration of conformity, evidence, change history
200+ business customers
300 Mio. DPP requests per month
12 industries in production use

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DIN EN ISO/IEC 27001:2024 zertifiziertDIN EN ISO 9001:2015 zertifiziertDSGVO-konform, EU-Hosting

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B&W International bonprix COR KEUCO KOINOR BEMER

REGULATION (EU) 2025/40

The PPWR has applied since 12 August 2026. Here is what that means in practice

The Packaging and Packaging Waste Regulation governs which data and evidence must exist for a piece of packaging before it is newly placed on the EU market. Four consequences already apply today, each with the article it comes from.

01

You may not place the packaging on the market

Without a completed conformity assessment and an issued EU declaration of conformity, packaging has not been allowed onto the EU market since 12 August 2026. Goods already in the trade are unaffected.

Art. 15(1) and (2), Art. 38, Art. 39

02

Market surveillance gives you ten days

On a reasoned request you must supply the technical documentation electronically, as a rule within ten days. Anyone who only starts collecting it from suppliers at that point will not make it.

Art. 15(10)

03

If something is non-compliant, you have to act

You are obliged to restore conformity without delay and, if necessary, to withdraw or recall the packaging. That decision sits with you, not with the authority.

Art. 15(8) and (10)

04

No EPR registration, no market access

Anyone not registered in a given member state may as a rule not make packaging or packaged products available there for the first time. This applies country by country.

Art. 44(2) and (4)

ONE THING THAT IS CURRENTLY BEING OVERSTATED

Since 12 August, every requirement applies

No. From that date the role model, the conformity obligations and the substance restrictions apply. Recyclability and minimum recycled content start in 2030, harmonised labelling in August 2028 at the earliest. Solving everything at once today ties up the capacity you will need in 2028.

If you did not prepare for the deadline, you are not alone. What counts now is both: start quickly, and implement in the right order.

THE NARRAVERO APPROACH

PPWR

The Packaging Regulation asks about the packaging: material, weight, recyclability, recycled content and the evidence for it. It has applied since 12 August 2026.

ESPR AND DIGITAL PRODUCT PASSPORT

The Ecodesign Regulation asks about the product inside: composition, repair, durability, circularity. The Digital Product Passport is the data record through which this information becomes accessible. First product groups from 2027.

Two regulations, two questions, but one product and one data basis. That is exactly where we start.

One record per packaging type, in which every change stays traceable

One packaging type, one record. If the material, weight, construction or your supplier's plant changes, a new version is created inside it and the previous ones are retained. The record is kept once and assigned to every product that uses this packaging, instead of maintaining the same evidence in every affected product record. You start with a first packaging family, not with the entire range.

PACKAGING RECORD Version 4, approved

VP-4821 folding carton, E-flute

Components
3
Materials
Board, printing ink, adhesive
Total weight
312 g
Evidence
4, all valid
Used in
128 products
PPWR proof of conformityEPR volume reportProduct DPP
Illustrative example. One record per packaging type, several regulatory outputs.

Data model

Every packaging type gets a unique identity and a data record you can query, instead of a folder.

  • Packaging ID, type and version
  • Components, materials and individual weights
  • Source, method, validity and approval status
  • Change history and affected products

Data carrier

If your product is subject to a data carrier obligation under Union law, product and packaging information must run through a single shared data carrier and remain distinguishable.

  • Requirement under Art. 12(5) PPWR
  • The same data carrier that carries your product DPP
  • Open standards instead of vendor lock-in
  • 300m requests per month, proven in the field

Evidence management

Your systems deliver through open interfaces, including REST and SAP. What only exists as a document today is captured in a structured form and assigned to the correct version.

  • Audit-proof versions for every change
  • New mandatory fields do not force a migration
  • Rights and confidentiality control per recipient
  • Machine-readable export for audit and authorities

WHAT HAS TO COME TOGETHER IN THE END

Packaging ID + version Components Materials Weights Evidence Product / SKU Market Period + volume

This chain carries two jobs at once: the proof of conformity for the packaging and the volume calculation for your EPR reporting.

DIVISION OF LABOUR Licensing and compliance schemes, registration in LUCID and other national registers, filing the EPR report, waste collection and take-back, and legal advice stay with your EPR service provider and your advisers. We supply the data basis their work is built on.

The fastest way to understand this is with your own packaging.

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Aus dem Feld

B&W International: eine Datenbasis, zwei Regulierungen

B&W International führt seine Produktdaten heute über die Narravero-Plattform und setzt die Verpackungsdaten für die PPWR auf derselben Basis auf. Kein zweites System und keine spätere Zusammenführung.

Wir haben den Produktpass nicht als Pflichtübung aufgesetzt, sondern als Datenbasis. Dass jetzt die Verpackungsdaten für die PPWR in dieselbe Struktur laufen, war deshalb kein neues Projekt, sondern ein weiterer Datensatz.
Dirk Uhlenbrock, Geschäftsführer B&W International Dirk Uhlenbrock
Geschäftsführer B&W International

PPWR AND THE DIGITAL PRODUCT PASSPORT

Why your packaging data belongs in the product passport and not in the sustainability report

Packaging data is product-related, not company-related. In many organisations it is still collected through the annual sustainability survey. That pattern is well established and right for its purpose. The PPWR simply asks a different question.

WHAT AN ANNUAL SURVEY IS BUILT FOR WHAT THE PPWR REQUIRES
Reference object WHAT AN ANNUAL SURVEY IS BUILT FORCompany-related. One questionnaire per legal entity, consolidated into a report. WHAT THE PPWR REQUIRESProduct-related. One record per packaging type. You do not package the company, you package many products in many different kinds of packaging.
Result WHAT AN ANNUAL SURVEY IS BUILT FORA document. What comes out at the end is a report that a person reads. WHAT THE PPWR REQUIRESA data record. Machine-readable, versioned, ready to connect to the data carrier of the packaged product.
Cadence WHAT AN ANNUAL SURVEY IS BUILT FOROnce per reporting year, with a cut-off date. WHAT THE PPWR REQUIRESContinuous. New supplier, different material, different production site: every change creates a new version in the record. On top of that come the next stages of the regulation: labelling from 2028, recyclability and recycled content from 2030.

THE REGULATION SAYS SO ITSELF

Recital 70 of the PPWR provides for exactly this: where the packaged product is covered by the Ecodesign Regulation or other Union law requiring a DPP, that Digital Product Passport should also be used to make the relevant packaging information available.

Regulation (EU) 2025/40, Recital 70 and Art. 12(5)

THE QUESTION YOU SHOULD BE ASKING

Will the same data basis later carry the product passport under the ESPR and, if relevant for your products, the battery passport? If not, you will be building the same foundation a second time very soon.

Anyone collecting packaging data is not collecting it for a report. They are collecting it for a product that sits on a shelf and comes back at some point. That is a different job from an annual survey, and it does not stop when the deadline has passed.
Thomas Rödding präsentiert DPP Hose Thomas Rödding
CEO, Narravero. Co-Chair of CEN-CENELEC JTC 24, Vice Chairman at DIN.

What people usually ask before a demo

We have our products packed under our own brand. Are we even the responsible party?

As a rule, yes. The responsible party is whoever has the packaging or the packaged product developed or manufactured under their own name or brand. The plant that physically produces the packaging is a supplier and has to hand you the documents, but does not carry the obligation. Microenterprises and a few special constellations are allocated differently.

Is this a separate PPWR product or part of your platform?

Part of the platform. Packaging data sits in the same data model as your product data, not in a separate tool alongside it. That is exactly where the benefit comes from: what you build for the PPWR later carries the Digital Product Passport, without collecting the same data a second time.

How does our suppliers' data get into the platform?

Your own systems deliver through open interfaces, including REST and an existing SAP integration. Documents that arrive from suppliers today as test reports, drawings or spreadsheets are captured in a structured form and assigned to the correct packaging type and version.

What does our IT need to provide?

To get started: name the source systems and grant access. The real effort is not in connecting them but in agreeing which field from which system is the reliable source. We work through that with you; it cannot be delegated.

How long does it take until the first record is in place?

The effort is not in connecting systems but in clarifying which field from which system is the reliable source. Once that is settled for a first packaging family, it produces a template that the rest runs on. The duration therefore depends on the number of your source systems, not on the number of your packaging types.

We did not prepare for the deadline. How bad is that?

Uncomfortable, but not an emergency. What is affected is packaging you newly place on the market, not your existing stock. It becomes critical if market surveillance asks and the technical documentation is not available within ten days.

Where is our data held?

In the EU. For publication Narravero holds its own copy of the approved data, because once a data carrier is in the field the requests come from outside, at volumes PIM, PLM and ERP systems were never built for. What you do not approve is not copied and not published.

Do we now need a QR code on the packaging?

No. For general packaging labelling the PPWR does not prescribe a QR code. A digital data carrier only becomes mandatory in special cases, for instance for certain reusable packaging under Art. 12(2), and there at a point in time no earlier than February 2029.

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  • Packaging record, versions and evidence in the system
  • Export for technical documentation and EPR volumes
  • An assessment of your specific case
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The content of this page reflects the legal situation as at the date given and does not constitute legal advice. Labelling details and formats depend on implementing acts that have not yet been fully adopted. The allocation of roles, products and markets must be assessed case by case.

Last updated: August 2026