Composition and traceability
Materials, components, weights, suppliers and supporting evidence must be collected and kept under control.
Regolamento (UE) 2025/40
PPWR and EPR: turn packaging obligations into a controlled process.
SQM supports importers, brand owners and distributors with packaging verification, technical documentation and the management of EPR obligations across EU markets.
What is changing
Packaging is now part of your company compliance framework.
The PPWR covers the entire packaging life cycle and directly affects businesses importing and making packaged products available in the European Union.
Recyclability and minimisation
Packaging must be assessed for recyclability, empty space, weight and the absence of unnecessary elements.
PFAS and heavy metals
Targeted checks, reliable declarations and, where necessary, testing or further technical investigation are required.
Demonstrable compliance
A supplier declaration alone may not be enough: evidence must be consistent, organised and verifiable.
National obligations
Registrations, producer responsibility organisations, reporting and fees still require country-by-country management.
Market surveillance and customs
Incomplete documentation may lead to requests for further information, corrective action, shipment holds or formal challenges.
The weak point is often the supply chain.
Non-EU suppliers may change packaging components without notice or source materials from third parties without structured traceability.
→Foam and plastic inserts changed
→Undocumented films, adhesives and inks
→Unverifiable recycled-content data
→Incomplete or missing packaging BOMs
The SQM solution
From fragmented data to a defensible Packaging Technical File.
We build a documentation process that links every packaging component to technical information, supplier evidence and the required compliance checks.
✓ Packaging classification
✓ Packaging BOM
✓ Evidence matrix
✓ Gap analysis
✓ Corrective actions
✓ Change monitoring
PPWR and EPR services
Modular support, from the initial review to ongoing compliance management.
The scope is tailored to your products, markets, volumes and current level of documentation maturity.
PPWR Gap Analysis
Packaging mapping, review of available evidence and a prioritised action plan.
Packaging Technical File
Document structure, packaging bill of materials, supporting evidence and technical consistency checks.
Supplier Due Diligence
Questionnaires, technical requests, declaration reviews and supplier change control.
Recyclability and minimisation
Preliminary design assessment and identification of potential improvement measures.
PFAS & Materials Assessment
Collection of declarations, risk analysis and definition of the necessary checks.
EPR Coordination
Support in identifying the EPR producer and the applicable national registration and compliance duties.
Label & Artwork Review
Review of mandatory information and management of the transition to harmonised labelling.
Customs & Surveillance Support
Technical assistance with document requests, authority challenges and corrective actions.
Compliance Monitoring
Monitoring of delegated acts, implementing acts and national EPR developments.
Our approach
From packaging mapping to ongoing control.
A practical process that integrates new packaging obligations into your existing compliance system.
Classify
SKUs, packaging levels and components, economic operator roles and destination markets.
Collect
Specifications, TDS, declarations, weights, compositions and supplier evidence.
Assess
Technical and documentation gaps, EPR risks and action priorities.
Maintain
Technical files, corrective actions, change control and regulatory updates.
Key timeline12 August 2026 2028–2029 From 2030 2035–2040
Preparing today avoids costly corrective action tomorrow.
General application of the PPWR, subject to the specific application dates set out in the Regulation.
Initial harmonised-labelling deadlines, subject to the applicable acts and transition periods.
Key requirements on design for recycling, recycled content and other targets.
Recyclability at scale and progressively higher performance levels.
Note: the PPWR provides for different application dates and numerous secondary acts. Applicability must be assessed for the specific packaging, the operator’s role and the market concerned.
EPR packaging
One EU Regulation, but obligations remain territorial.
The EPR “producer” must be identified by determining who first makes the packaging or packaged product available in the territory of a Member State. The commercial chain must therefore be assessed country by country.
Identifying the obligated producerRoles, commercial flows, distance sales and destination markets.
Registration and representationAssessment of national registers and any required EPR authorised representative.
Reporting and feesData setup by material, quantity and national reporting category.
Multi-country coordinationA consistent operating framework across EU jurisdictions.
First step
Speak to a consultant →Is your packaging ready for the PPWR?
Request an initial assessment. SQM will review your products, markets, available documentation and supply chain to define the operational priorities.
Frequently asked questions
PPWR and EPR, in brief.
Does the PPWR also apply to importers of packaged products?
Yes. The obligations do not apply only to packaging manufacturers: importers, brand owners and other economic operators also have specific responsibilities depending on their role.
Are PPWR and EPR the same thing?
No. The PPWR lays down requirements throughout the packaging life cycle and also includes extended producer responsibility. EPR duties are implemented through national systems and registers.
Is a declaration from a Chinese supplier sufficient?
Not always. The declaration must be consistent with the packaging structure and supported by reliable data. The necessary level of evidence depends on the requirement and the risk.
Is technical documentation required for packaging?
The PPWR introduces technical documentation and conformity-assessment obligations. A dedicated file provides a structured way to manage composition data, checks, evidence and updates.