Across Europe, awareness of the EU Packaging and Packaging Waste Regulation (PPWR) is growing rapidly. I regularly have conversations with procurement leaders, sustainability teams, packaging R&D, finance, and operations, and one thing is clear: many organisations still underestimate the real risk.

PPWR is not just about better materials or recyclability. It is about proving compliance — continuously, at scale, and with auditable data. And without that proof, products may not be permitted on the EU market.

The uncomfortable truth: many companies are not prepared

There is a consistent pattern: companies are still treating PPWR as a future problem. But the reality is much closer — and more practical. From August 2026, packaging placed on the EU market must be supported by a Document of Compliance (DoC), backed by technical documentation and verifiable data across the value chain. Yet today, most organisations are still working with:

• Packaging data fragmented across spreadsheets and legacy systems
• Supplier declarations buried in PDFs and emails
• Limited connection between packaging specifications and actual SKUs
• No real-time view of compliance status or exposure

This creates a critical gap. PPWR does not ask for static reports, it requires a live, system-driven proof of compliance. For many companies, that capability simply does not exist today.

From design for compliance to “proof of compliance”

PPWR introduces a fundamental shift in thinking. It is no longer sufficient to design compliant packaging; you must be able to prove it — at any time, for any product, across any EU market. That evidence must include:

1. Full material composition, including substances of concern (Article 5) for all packaging – primary, secondary and tertiary (transport)
2. Supplier declarations and supporting evidence (Articles 38, 39)
3. Test results and conformity assessments (Annex VIII)

This affects multiple personas in companies:

• For procurement, this means packaging supplier data becomes business-critical.
• For R&D, it means design decisions must be evidence-based.
• For sustainability teams, it means compliance must be measurable and auditable.
• For finance, it introduces genuine revenue-at-risk exposure – if you cannot prove compliance, you cannot sell the product.
• For operations and IT teams, it requires end-to-end process integration.

In short: PPWR compliance becomes a cross-functional, data-driven discipline. Or as we like to say at SAP: “Your packaging strategy becomes a data strategy.”

The business risk: revenue, cost, and market access

PPWR is not just a regulatory issue — it is a business issue centred on revenue, cost, risk, and access to markets.

If packaging cannot be proven to be compliant:

• Products risk being withdrawn from sale in the EU (from August 2026)
• Revenue is directly exposed at SKU level (also August)
• EPR fees and penalties increase due to suboptimal design (from early 2027)

This is why leading organisations are reframing PPWR as: a market access and financial risk issue — not just a sustainability topic.

PPWR is not a specific regulation

PPWR expands over time, with new regulations and requirements increasing from now through to 2030 (see diagram below).

Why spreadsheets and point solutions will fail

Many organisations are trying to solve PPWR with incremental fixes:

• Adding more spreadsheets
• Requesting further supplier documents
• Conducting regular compliance checks

This approach simply does not scale, since PPWR requires:

• Continuous updates—Documents of Compliance must be updated as new regulations are introduced over time, or if any packaging changes
• SKU-level accuracy—we need to see the attributes for every element, and need to know how those elements are combined, which dictates recyclability
• Audit-ready documentation—records must be kept for 5 years for Single Use and 10 years for Reusable packaging

This cannot be achieved with disconnected tools, or spreadsheets—these cannot be audited, as anyone can change a cell! The real challenge is not collecting more data—it is connecting, governing, and activating the data already within the business and across the supply chain. It needs a robust system.

What good looks like: a digital compliance data flow

To issue a valid Document of Compliance, organisations require an integrated, end-to-end data flow:

1. Data collection—Capture structured supplier data, material composition, and test results.

2. Data integration—Link packaging specifications directly to products, suppliers, and bills of materials in core systems of record (such as ERP systems).

3. Data validation—Apply regulatory rules to assess compliance (e.g. substances, recyclability).

4. Decision-making—The system should provide real-time answers to critical questions:

• Is this packaging compliant today?
• Which products are at risk?
• What is the financial impact?

5. Generation of Document of Compliance
Automatically generate audit-ready DoCs, dynamically linked to underlying evidence, at scale. This will not be a one-off process, it is a continuous compliance loop that must be governed over time.

SAP Responsible Design and Production: a control panel for packaging compliance

SAP Responsible Design Production is designed to address this challenge directly. Rather than acting as a standalone tool, the product serves as a control plane for packaging data and compliance, built on core SAP ERP systems (S/4HANA—either public or private cloud). It was created as a tool for EPR fee and plastic tax calculation, and the first PPWR features will be available by July or by the end of June for our customers to use, well ahead of the August deadline. It enables organisations to:

• Calculate EPR fees and plastic packaging taxes, and model scenarios for packaging, in a single platform, linked to core SAP systems—so has near real-time data on product shipments—no one else can do this!
• Create a single source of truth—Linking packaging data directly to products, suppliers, and commercial structures—ensuring compliance is managed at SKU level.
• Orchestrate data across the value chain—Integrate supplier data, packaging specifications, and regulatory requirements in one structured model, leveraging solutions such as SAP Integrated Product Development and SAP Product Compliance, and a rich ecosystem of partners.
• Automate compliance assessment—Continuously evaluate packaging against PPWR rules, removing manual effort and reducing risk.
• Generate audit-ready Documents of Compliance—Transform DoCs from static documents into live, system-driven outputs, always aligned with the latest data.

The time to act is now

August 2026 is closer than it appears. Establishing the necessary data foundation, governance, and system integration takes time—especially across procurement, R&D, sustainability, finance, and operations.  The risk is clear: many organisations are still sleepwalking towards a deadline that will directly impact their ability to sell in the EU. Those who invest now in data-driven compliance will not only meet PPWR requirements—they will build a foundation for smarter, more resilient, and more profitable operations.