PPWR Three Weeks In: When Regulation Meets Reality
Author: Michael Staunton - September 2026
The PPWR is now live. But the first few weeks are highlighting a familiar challenge with major regulation: Writing the rules is one thing. Making them work across thousands of businesses and complex supply chains is another.
Three weeks into the application of the EU Packaging & Packaging Waste Regulation (PPWR), one thing is becoming increasingly clear:
The biggest challenge for many businesses isn't awareness of the regulations existence or indeed it’s importance, but in the turning of the requirements into a workable compliance process.
The PPWR represents a significant attempt to change how packaging is designed, produced, used and managed across Europe. Its primary objectives; reducing packaging waste, improving recyclability, increasing circularity and creating greater consistency across the Single Market, are difficult to argue against.
But legislation doesn't implement itself. It has to work through manufacturers, importers, distributors, retailers, packaging suppliers, testing laboratories, EPR systems and ultimately thousands of SMEs, and that is where the first few weeks have become interesting.
The gap between legislation and implementation
The European Commission and Member States have spent considerable time developing the PPWR framework, but practical questions remain. Industry was raising concerns about implementation well before August 12th.
In June, EuroCommerce called for further clarification and a realistic implementation approach, highlighting unresolved questions around the Declaration of Conformity, PFAS implementation, secondary legislation and the potential for supply-chain disruption.
That concern wasn't coming only from large corporations. A May/June 2026 survey of 276 professionals across the EU food and beverage supply chain found average self-assessed PPWR readiness of just 35%. Not one respondent reported that their suppliers were fully engaged, while data collection and supplier cooperation emerged as major obstacles.
So perhaps the more interesting question now is:
What happens when a regulation designed at EU level meets the practical reality of thousands of individual supply chains?
Three weeks in, I'm seeing several recurring themes.
The biggest bottleneck may not be the regulation, but the suppliers.
If I had to identify one issue above all others, it would be supplier information.
Businesses are being asked to establish packaging composition, material information, supporting test data, recyclability information and other evidence needed to demonstrate conformity. But much of that information sits upstream.
Article 16 of the PPWR requires suppliers to provide manufacturers with the information and documentation necessary to demonstrate the conformity of packaging. That sounds straightforward, however in practice, it can be anything but. A manufacturer may have the legal responsibility for demonstrating conformity while depending on several upstream suppliers or their sub-suppliers to provide the evidence needed to do so.
And this generates a difficult question to answer:
What happens when the party with the legal responsibility doesn't have the information, and the party with the information isn't sufficiently responsive?
The June industry survey illustrates the scale of the problem. Respondents reported that supplier cooperation was patchy and slow, with none of the 276 respondents describing their suppliers as fully engaged.
What I am seeing in practice with clients echo’s this, and further calls into question the quality of the information. In many cases, suppliers are taking a ‘send whatever we have and hope for the best’ approach. The result; an information dump containing irrelevant, non-product aligned, or outdated information.
This isn't simply a documentation problem, but a control problem. A business can send supplier questionnaires, issue requests and chase declarations. But if the supplier doesn't have the underlying data, or can't provide it at the required level of detail, the business remains exposed.
And while the PPWR establishes an obligation on suppliers to provide information, the practical question of how that obligation will work in a fragmented, international supply chain is considerably less straightforward.
For SMEs, this is particularly challenging. They often have less purchasing leverage than multinational companies and may be several steps removed from the manufacturer of the actual packaging material.
Documents are appearing, but not necessarily across the whole portfolio.
A recurring theme observed is the emergence of partial compliance.
Businesses have been preparing to certain extent. Some have obtained Declarations of Conformity, certificates of compliance, technical specifications, testing back-up, and so on, for their highest-volume products or priority SKUs. But that doesn't necessarily mean they have a complete conformity position across their packaging portfolio.
The difference between: "We have some documentation", and "We can demonstrate conformity across the packaging we place on the EU market", can be substantial.
The underlying issue comes back to data. A company cannot reliably assess a packaging portfolio if it doesn't know:
what each packaging component is made from;
who supplied it;
what evidence exists;
which test data relates to which SKU;
whether the information is current;
and whether the available evidence supports the relevant assessment.
The survey evidence points in the same direction: businesses were actively requesting DoCs, mapping portfolios and building spreadsheets, but many remained in the information-gathering phase rather than having a fully controlled compliance system.
So the paperwork is beginning to accumulate, and the key question is whether it is developing into a meaningful system of information and data gathering.
Paperwork is not the same as conformity assessment
By extension, there comes probably the most important distinction I am witnessing;
A business may have:
supplier declarations;
material specifications;
test reports;
recyclability information;
packaging drawings;
certificates;
spreadsheets.
On paper, this can all look great, but the next question is: Has anyone actually assessed the packaging against the applicable requirements?
A Declaration of Conformity isn't simply another document to add to the folder. It needs to be supported by the relevant conformity assessment and technical documentation.
So there is a fundamental difference between:
"We have the paperwork" and, "We have assessed the packaging against the applicable requirements and can demonstrate why we believe it conforms."
I suspect that distinction will become increasingly important as businesses move from preparation into routine compliance.
Is the "manufacturer" definition always proportionate?
This is one area where I think there is a legitimate policy question to ask.
The PPWR doesn't necessarily define the manufacturer as the business that physically produces the packaging.
A business can potentially be treated as the manufacturer where packaging is designed or produced under its own name or trademark, even if another company physically manufactures it. There is a rationale for this. If a business puts its name or brand on packaging, it may have significant influence over its characteristics and should arguably have responsibility for ensuring that it complies.
But consider a smaller company that asks an established packaging supplier to produce boxes carrying its logo.
The SME may specify:
dimensions;
artwork;
intended use;
quantities.
But it most likely will have no involvement whatsoever in the formulation of the material, manufacturing process or sourcing of the raw materials. Yet it can still find itself carrying manufacturer-level responsibilities.
That raises a question: Is ownership of a trademark always a good proxy for technical control?
There is a policy argument that someone needs to be clearly accountable. and that makes perfect sense. But there is another side to the argument, particularly when you consider the previous observation on supplier and information management challenges.
If the party carrying the legal responsibility doesn't control the underlying technical information, does assigning responsibility actually improve compliance, or simply place the burden on the most accessible party in the supply chain?
I don't think that question has been fully answered by implementation yet. And it could become increasingly important as enforcement develops.
EPR is exposing another layer of complexity
The PPWR may establish a common EU framework, but EPR remains heavily dependent on how obligations operate in individual Member States.
For companies selling across borders, the practical questions therefore become:
Where are we the relevant producer?
For which packaging?
In which Member State?
What registration and reporting obligations follow?
Industry has already raised concerns about divergent national approaches and the potential administrative burden of different EPR structures. EuroCommerce and other organisations have specifically called for greater harmonisation and transparency in EPR systems.
Again, there is a tension here. The PPWR is intended to strengthen the Single Market. But businesses can experienceadditional complexity before they experience greater harmonization.
That is an implementation issue worth watching.
Then there is the question of enforcement
This is where the situation becomes particularly interesting.
The PPWR is legally applicable. But the European Commission has also recognised that implementation of a regulation of this scale needs to be pragmatic.
Industry has argued that initial enforcement should focus on guidance and support rather than punitive action, particularly while outstanding questions are being clarified. EuroCommerce explicitly made that case before the application date, alongside concerns about supply-chain disruption.
That approach is understandable. A regulatory framework of this scale was never going to operate perfectly from day one. But it raises another question:
How long can a supportive approach remain practical once the underlying obligations are legally in force?
And there is a second tension. The objective is to avoid unnecessary disruption to supply chains. But if non-compliant packaging ultimately has to be corrected, withdrawn or prevented from being placed on the market, some disruption may be unavoidable.
So the question isn't whether enforcement will eventually matter. It is:
When does the transition from education and correction to intervention begin to bite?
If businesses are still waiting for supplier information, testing methodologies or clarification when that point arrives, compliance problems can quickly become commercial problems.
And commercial problems travel through supply chains very quickly.
Why weren't more businesses ready?
This is perhaps the most difficult question. to pin-point an answer to. Three weeks in, there is clearly a preparedness gap across many parts of the industry. But why, with a looming deadline of August 12th, is that the case?
There are at least two possible explanations.
Regulatory uncertainty
The PPWR is a substantial piece of legislation, with a number of practical details dependent on implementing and delegated acts, methodologies and further guidance.
Industry was highlighting this before the August application date. EuroCommerce specifically raised concerns around unresolved questions, PFAS testing, the Declaration of Conformity and the timing of secondary legislation.
The Simvia survey also found that many businesses were still trying to understand their responsibilities and collect information shortly before the application date.
If businesses don't know exactly what evidence they will ultimately need, it becomes difficult to invest confidently in systems, testing and packaging redesign.
Or something else?
Perhaps some businesses simply underestimated the scale of the change. The packaging supply chain is already dealing with a substantial regulatory and commercial workload.
PPWR joins a landscape that includes EPR, food-contact requirements, sustainability reporting, environmental claims, recycled-content expectations and other EU and national requirements.
So perhaps another question deserves to be asked:
Can regulation move quickly enough to achieve its environmental objectives without creating a compliance infrastructure that becomes disproportionate for the businesses expected to operate it?
That isn't an argument against the environmental objectives, but it is an argument for considering how regulation works in practice.
The uncomfortable paradox
There is an interesting paradox emerging. The PPWR is intended to create:
more harmonization
more transparency
better packaging
less waste
But during the transition, businesses may experience:
more documentation
more supplier dependency
more uncertainty
more cost
more administrative complexity
That doesn't necessarily mean the regulation is wrong. It means that implementation matters just as much as legislation.
If the eventual outcome is a more consistent European packaging market with better data and less waste, the effort may prove worthwhile.
But if businesses spend years building parallel systems around unclear requirements, repeatedly redesign packaging because methodologies change, or face different interpretations across Member States, the regulatory burden itself becomes part of the problem.
That is the balance the Commission, Member States and industry now need to get right.
None of this means SMEs should wait
Crucially, the existence of uncertainty doesn't make the PPWR optional. It is live.
Some requirements already apply, while others will phase in over the coming years.
Further delegated and implementing acts will continue to shape how individual requirements operate.
So I don't think SMEs should adopt either extreme.
Don't assume everything is already perfectly clear. But equally: don't use uncertainty as a reason to do nothing.
The sensible response is to establish a baseline.
Start with the packaging, not the paperwork
For an SME, that baseline doesn't have to be complicated.
Start with:
What packaging do we actually place on the EU market?
Who supplies it?
Who is responsible for it?
What evidence do we have?
What evidence are we missing?
Which requirements apply now?
Which requirements are coming later?
Where are we dependent on information we don't control?
That creates something much more useful than a folder full of certificates. It creates a living compliance record that can evolve as suppliers change, packaging changes and additional PPWR requirements come into force.
Three weeks in: my biggest takeaway
I don't think the immediate PPWR challenge for many SMEs is going to be understanding every Article in the Regulation.
It is going to be building enough structure around their packaging portfolio to cope with a regulatory framework that is itself still evolving.
The businesses that are likely to be best positioned, regardless of size, are the ones that will:
understand their packaging portfolio;
know where responsibility sits;
have organised their supporting evidence;
understand where their information comes from;
know where the gaps are; and
have a process for keeping that information current.
The PPWR may have been written in Brussels, but Its success, and much of its complexity, will be determined by what happens in procurement departments, packaging teams, warehouses and SMEs across Europe.
The legislation is now live. The debate about how it should work in practice is clearly not finished. But perhaps that's the most important observation three weeks in:
The challenge isn't whether the PPWR exists. It does. The challenge is turning it into something businesses can actually implement, maintain and demonstrate.
TrailZero helps Irish SMEs review packaging portfolios, supplier documentation and PPWR responsibilities, identify evidence gaps and establish practical packaging compliance records.
Sources / further reading
European Commission's PPWR guidance/FAQ
European Commission PPWR Guidance
