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Start With What You Know: What Sustainability in Packaging Europe Revealed About PPWR Compliance

Posted on

October 14, 2026

• 

  Danielle Goad

  Director, EMEA

PPWR Sustainability Sustainable Packaging

I spent last week in Barcelona at Smithers’ Sustainability in Packaging Europe, two months after the first obligations of the EU’s Packaging and Packaging Waste Regulation (PPWR) took effect on August 12, 2026. Brand owners, retailers, converters, producer responsibility organisations and the European Commission’s own Joint Research Centre shared the stage, and the conversation has moved on. Sessions spent little time explaining PPWR regulation and far more on what it takes to live with it.

Three ideas came up in almost every session I sat in. Start with what you know while the detailed rules settle. Treat eco-modulation as a design and market-access decision, not a line on an invoice. And accept that PPWR compliance starts with the data you hold, and with the suppliers who hold the rest.

1. Start with what you know, while PPWR timelines settles

There is a fair case for waiting. Much of the detail behind PPWR requirements still sits in delegated and implementing acts, and many companies do not have the resources to redesign their packaging twice. Nestlé made the point from experience: it wants to see whether some of the innovations it introduced in the last five years will pass the test, and earn a grade between A and C, before deciding what to change again. Teams that act without clear thresholds risk overcorrecting. Teams that freeze risk a rush in the final two years.

The counterweight is lead time. Manufacturing lines, materials, supplier changes, artwork and more take years to move, and EXPRA, Huhtamaki Flexibles and Amcor all argued that the direction of travel is clear enough to start. Packaging changes can take two to five years, and once the Commission publishes the PPWR labelling rules, companies have two years to implement them across every pack. The room settled on a balance. Make the obvious shifts now, hold the uncertain ones until the rules firm up, and do not let the second group become an excuse to delay the first.

Engagement belongs in the same plan. Amcor and Nestlé both urged companies to feed into the Commission while secondary legislation is still being drafted, and Amcor pointed to PPWR PFAS restrictions as proof that it works: industry feedback helped move the expected approach toward a proportionate one backed by documentation. The Joint Research Centre also acknowledged that some technical work is running behind plan, so the rules will keep moving.

Colruyt Group named the no-regret move: data. Packaging has historically been a lower priority, so the data behind it is thin. Whichever way the delegated acts land, companies that know what is in their packaging, component by component, and can prove it, will have the shortest path to PPWR compliance.

2. Eco-modulation turns packaging data into a market-access question

Our partner Lorax EPI’s pre-conference workshop on eco-modulation set the tone for the fee conversations that followed. Across Europe, Extended Producer Responsibility (EPR) fees vary from flat, weight-based charges to systems that reward or penalise design. EPR fees are rising, the systems are getting more complex, and missing data costs money. In the UK, packaging without sufficient data defaults to the most expensive rating.

The bigger shift is the incentive. Before PPWR, the reason to redesign packaging was a lower fee. Under PPWR, the reason is market access. The Commission is due to adopt harmonised design-for-recycling criteria and recyclability performance grades by January 1, 2028, and fees will modulate against those grades, although each market will still set its own.

That turns packaging into a cost question as much as a design one. Nestlé described weighing delivered cost: material price, line performance, EPR fees and the other costs that come with each choice, all together. Paper can look cheapest until it misses a material definition or thresholds in one market, and those differences are hard to explain to upper management when you produce in one country and sell into more than twenty. Amcor said total cost of ownership is changing the conversation, and expects many companies to simplify rather than design separate packaging for each country.

Simplification ran through the fireside chat too. Recyclability only makes economic sense once plastic packaging is harmonised, and a proliferation of SKUs and specifications works against it. Simplifying a portfolio starts with seeing it. Teams need component-level data on every specification to spot duplicates, compare materials and model the EPR fee impact of consolidating formats by market. That exercise is slow and error-prone across spreadsheets and PDFs; it becomes practical when the data sits in one connected software system that can be searched, compared and updated. Eco-modulation rewards the companies that can do it before the invoice arrives.

3. PPWR Declaration of Conformity starts with data, and with your suppliers

Henkel gave a good representation of what the journey to a PPWR Declaration of Conformity looks like as a first step. Its team said the biggest PPWR challenge was understanding where the business stood against the regulation at all, and that transparency starts with data. Henkel organised its response around shared ownership across regions and functions and three workstreams: portfolio assessment, external engagement and digital data management, which it called the critical one. Every benefit it listed, from better packaging decisions to implementation at scale, rested on the same dependency: trusted packaging data. The team was open that the work continues, with recycled content, labelling, minimisation and reuse still ahead.

Suppliers were the hardest part. Henkel packaging leads ran engagements alongside their procurement team, with a dedicated team, a detailed questionnaire, defined escalation routes and weekly tracking. Larger suppliers cope. Small and mid-sized suppliers often lack the resources and regulatory knowledge, and some still ask why they need to share the data at all.

Other speakers described the same strain from different seats. Nestlé called documentation the big theme of PPWR, and said its first round of supplier statements took far longer than planned. Colruyt Group, speaking as a retailer, said many suppliers in Asia and many smaller companies still do not know what PPWR means. Put those together and a pattern emerges. Every brand and retailer is now sending suppliers its own request, in its own format, at the same time. The industry recognised that this does not scale, and that supplier engagement has to become close to frictionless if the data is going to be good enough to support a Declaration of Conformity.

The principles that follow are simple. Collect supplier data once, in whatever format suppliers can provide. Validate it as it arrives. Hold it in one connected data model that serves the Declaration of Conformity, EPR reporting and the next requirement alike. And treat suppliers as partners, with a clear explanation of what you need and why.

Specright in Barcelona, and what’s next

We value our partnership with Lorax and were glad to exhibit alongside them in Barcelona, where the conversations at their stand and around their eco-modulation workshop kept returning to the data behind EPR fees.

The supplier problem is one we work on every day. Specright’s Supplier Network lets suppliers send data as they hold it, and AI validates and maps it to the specification, so a supplier answers once instead of once per customer and the data arrives ready to use.

We are taking these conversations to Utrecht next month. Specright will exhibit and run a workshop at Packaging Europe’s Sustainable Packaging Summit, November 10-12, 2026, at the Jaarbeurs. If you are attending, come and find us.

What PPWR Compliance means for packaging teams now

Barcelona showed an industry that has moved from reading PPWR to living with it. The rulebook still has gaps, and the detailed rules on recycled content, labelling and recyclability grades will keep arriving between now and 2028. Some teams should wait on the uncertain decisions. Most cannot wait on the obvious ones, because the lead times are too long. The companies that spoke with the most confidence were making the clear shifts now, treating eco-modulated fees as a design input, and building transparency from their own data and their suppliers’ data up. Whatever the final grades look like, they will reward the teams that can answer one question quickly: what is this packaging made of, and can you prove it?

If your team is working out where its packaging data stands against PPWR or eco-modulated EPR fees, get in touch with our team and we can walk through what that looks like for your portfolio.