SAP and Teneo have collaborated on this blog post to share insights and perspectives on the business impact of PPWR

Introduction: From Sustainability Issue to Board-Level Risk

The EU Packaging and Packaging Waste Regulation (PPWR) has now moved from policy debate to execution countdown. This is no longer only a “nice to have” sustainability topic; it is a direct compliance, revenue, and market access risk for any company placing packaged goods on the EU market. PPWR will generally apply from 12 August 2026, with further requirements and targets tightening over the following years. Authorities and customers will expect auditable proof that packaging is compliant—and without it, products may simply not be allowed on shelves.

For senior executives, the real question is shifting from “Are we sustainable enough?” to “Can we still legally sell this packaged product on the EU market, at this margin—and can we prove it on demand?”

PPWR also needs to be understood in the broader EU policy context. It is intended to strengthen circularity and harmonize packaging rules across the EU, but many implementation details will continue to evolve through Commission guidance, secondary legislation, standards and national enforcement practices. This means companies need more than a compliance checklist. They need a cross-functional readiness strategy that connects regulation, data, systems, financial exposure, supplier governance and stakeholder expectations.

Why PPWR Demands Executive Attention Now

PPWR begins to apply from 12 August 2026, with requirements tightening over the following years through detailed rules, new documentation obligations and future demands on recyclability, reuse and recycled content. Packaging portfolios often span hundreds or thousands of SKUs across multiple jurisdictions, each with different materials, suppliers and routes to market.

Most organisations are underestimating preparation time because critical data is scattered across R&D, procurement, packaging engineering, sustainability, finance and local operations, often locked in spreadsheets or legacy systems. The risk is not just late compliance; it is discovering too late that your current data model simply cannot support PPWR-grade documentation at scale.

Recent European Commission guidance has helped clarify some aspects of PPWR implementation, but important questions remain. For example, in relation to PFAS (“forever chemicals”) in food-contact packaging, the European Commission has confirmed that there is currently no harmonized EU methodology for measuring PFAS levels. This illustrates a broader challenge: companies must prepare for compliance while the interpretation, enforcement and technical detail of some requirements continue to develop. The biggest PPWR challenge is unlikely to be packaging itself. It is managing the data, governance and evidence required to demonstrate compliance.

The Hidden Complexity Behind Packaging Compliance

On paper, PPWR looks like a set of design and documentation rules. In practice, it forces companies to run a far more complex information, reporting and governance model across their entire packaging footprint. However, executives need to be confident that their organisation can, for every relevant packaging type:

• Trace material, substance and design data back to products, suppliers and bills of materials:
• Aggregate supplier declarations and test data into a consistent, auditable view:
• Reflect variations across formats, markets and channels in reporting and technical files, and keep pace with evolving requirements on recyclability classes, recycled content and reuse systems.

What Happens If Companies Delay?

Regulatory risk

• Inability to produce documentation, technical files or declarations of conformity when challenged
• Heightened scrutiny from regulators, NGOs and customers, increasing the chance of enforcement or public escalation
• Potential divergence in national enforcement if EU-level guidance, methodologies or standards are not sufficiently clear

Commercial risk

• Revenue at risk where products cannot be placed on the EU market or must be withdrawn at short notice
• Escalating remediation costs as teams scramble to re‑engineer packaging, re‑contract suppliers and rebuild data
• Margin erosion through last‑minute, sub‑optimal packaging choices and manual, high‑cost compliance processes

Strategic risk

• Slower product launches and innovation cycles as compliance checks become a bottleneck
• Reduced agility in responding to future regulatory changes on packaging, plastics and circularity
• Reputational exposure if PPWR non‑compliance is seen as a proxy for weak governance or ESG performance

This is where Teneo can provide a policy and regulatory perspective on likely consequences and risk exposure.

Why Data and Systems Readiness Are Now Core Controls

PPWR requires companies to create and maintain compliance evidence that is traceable, auditable and kept up to date as portfolios, suppliers and rules change. For most organisations, this means moving beyond project-based spreadsheets to an integrated data and systems backbone.

Key capabilities include:

• A single, trusted data model for products, packaging specifications, materials and suppliers
• Governance that clarifies ownership of data, decisions and documentation across functions
• Automated checks against regulatory rules and thresholds, rather than manual interpretation
• Rapid, repeatable reporting that can withstand regulatory scrutiny and internal audit

Where SAP and Teneo come in

SAP solutions, including SAP Responsible Design and Production, are being used by companies to manage packaging data at scale, link packaging attributes directly to products and suppliers, and automate PPWR compliance and EPR reporting across markets. AI‑enabled rule management and user‑defined reporting help organisations adapt as regulations evolve, while maintaining governance and auditability over time.

But system readiness is only one part of the challenge. Companies also need to understand how PPWR will be interpreted and enforced, which parts of the business are most exposed, and what the financial and operational consequences could be, and how to communicate readiness to boards, regulators, investors, customers and other stakeholders.

This is where Teneo brings a complementary advisory perspective, combining EU policy and regulatory insight with financial advisory, management consulting, risk advisory and communications expertise. Together, SAP and Teneo can help companies move PPWR from a fragmented compliance issue to a structured business readiness programme.

In short: SAP provides the technology spine to make PPWR compliance repeatable, auditable and scalable; Teneo helps ensure that spine is aligned to the organisation’s broader policy, financial and operational risk, stakeholder and communications priorities.

Five Actions for 2026—Before the Countdown Runs Out

Executives do not need another long regulatory explainer. They need a focused set of actions that protect revenue and market access before the PPWR applies on 12 August 2026. Between now and August, companies should:

1. Clarify your PPWR exposure: Map where and how the business places packaging on the EU market, which obligations apply, and which categories, brands and channels are most exposed.
2. Map your packaging, material and supplier data, assess data quality, ownership and gaps: Identify where product, packaging, material, substance and supplier data currently sit, and how they are connected to core systems (or not).
3. Determine who owns which data, where quality issues exist, and what cannot currently be linked to a specific packaging item, supplier or market.
4. Quantify revenue, margin and cost exposure: Assess which produce lines, markets or packaging formats could create revenue-at-risk, higher EPR fees, remediation costs, delay launches or margin pressure.
5. Stress‑test your reporting and documentation processes: Run “tabletop” exercises: could you produce PPWR‑grade documentation for a high‑value product line within days, and would it stand up to challenge?
6. Build an integrated readiness roadmap: Define the target operating model, systems architecture, governance process and stakeholder strategy needed to manage PPWR compliance over time, including where SAP will provide the digital backbone, and where Teneo will support on regulatory, financial and reputational risk management.

Taken together, these steps move PPWR from a diffuse compliance topic to a defined programme with clear executive ownership and measurable risk reduction

Why the C Suite Cannot Delegate This

PPWR will touch finance, legal, sustainability, supply chain, packaging, regulatory affairs and commercial teams. But the most material risks sit squarely with the C‑suite.

• CFOs need visibility on fines, remediation costs, EPR exposure and revenue‑at‑risk scenarios—and confidence that PPWR readiness is integrated into capital allocation and planning.
• Compliance and legal leaders must ensure that the evidence and documentation model will withstand regulatory and, if needed, legal scrutiny.
• Supply chain and operations leaders have to build PPWR requirements into procurement, supplier management and logistics processes.
• Sustainability and packaging leaders must translate regulatory requirements into practical design and implementation choices that do not compromise commercial strategy.
• Government affairs and corporate affairs teams need to anticipate how implementation guidance, enforcement practice and stakeholder expectations will evolve, and communicate readiness credible to policymakers, customers, investors and the wider market.

PPWR is becoming a test of how well an organisation connects regulation, data and technology at the top of the house. It is also an opportunity: those who get ahead can unlock better packaging economics, stronger ESG narratives and more resilient market access.

Call to Action – Turn PPWR from Threat to Advantage

PPWR is now on a fixed timeline. The open question is whether your organisation treats it as a late‑stage compliance scramble or as a managed business risk with a clear technology and governance response. Get this right, and you can save money from reduced compliance costs, EPR fees, and OPEX, and SAP and Teneo have many examples.

SAP and Teneo are working together to help CEOs and their teams:

• Understand PPWR obligations and implementation risks
• Quantify PPWR exposure and “revenue at risk”
• Design a data and systems backbone that can generate audit‑ready documentation at scale
• Position PPWR readiness as evidence of strong governance and ESG performance to investors, regulators and customers

If you are responsible for protecting EU revenues, market access or corporate reputation, PPWR should now be on your short list of board‑level risks. To explore what this means for your organisation—and how SAP technology and Teneo’s advisory support can accelerate your readiness—join our webinar From Packaging Compliance to Revenue Risk: Why PPWR Matters Now, on 7 JULY 2026 at 4 pm CET—REGISTER HERE

Teneo is a global CEO advisory firm. Drawing upon our team and expansive network of senior advisors, we provide advisory services across our five business segments to help our clients solve complex business challenges. Our full range of advisory services includes strategic communications, investor relations, financial transactions and restructuring, management consulting, physical and cyber risk, organizational design, board and executive search, geopolitics and government affairs, corporate governance and ESG.