Packaging Traceability Under the PPWR

Without it there is no valid DoC and no correct EPR settlement

From 12 August 2026, every item of packaging placed on the EU market must have a Declaration of Conformity (DoC) and technical documentation compliant with Regulation (EU) 2025/40 (PPWR). In our audit practice, however, we see companies start with a declaration template and only then ask: for exactly which packaging, in which sales stream, and who should actually sign it? This is the reverse of the correct order, as the traceability of packaging under the PPWR is fundamental. Each batch of packaging must be unambiguously linked to its manufacturer, material composition, test reports and – a point that is often overlooked – the sales model through which the packaging enters the market.

What does the PPWR require?

The PPWR applies to packaging the logic known from EU product legislation. Article 15 obliges the manufacturer to ensure identification of the packaging type and batch and to indicate its name and address on the packaging or in a data carrier (e.g. a QR code). Annex VII (Module A) requires technical documentation describing the materials, the design and the evidence of compliance with Articles 5–12, while Article 39 together with Annex VIII requires a Declaration of Conformity that unambiguously identifies the packaging it covers.

Suppliers of packaging and components (canisters, closures, labels) are obliged to provide the recipient with all information necessary to demonstrate compliance (Article 16) – but their declarations do not replace the responsibility of the entity that places the final, filled unit on the market under its own brand.

The DoC relates to the type. The traceability of the packaging applies to each batch.

The Declaration of Conformity is drawn up for a packaging type – not for every single item (Annex VIII point 2: an identification number unambiguously indicating the packaging covered by the declaration). Responsibility, however, reaches deeper: Article 15 requires the packaging to bear a type, batch or serial number enabling its identification, and Module A (Annex VII) obliges the manufacturer to ensure that every unit from series production remains in conformity with the technical documentation.

Whenever the raw material, the design, a component supplier or the legal requirements change, conformity must be reassessed and the DoC updated (Article 39).

Points to note:

• Declaration of Conformity (DoC) – by type,
• traceability of packaging – down to batch level.

The PPWR does not require the manufacturer’s logo to appear on every individual unit of empty packaging. However, it does require that the documentation makes it possible, at any time, to link a batch of packaging to its manufacturer and to the batch of the product placed on the market. Without this, the DoC cannot be verified.

The sales model decides who the EPR “producer” is

The second dimension of traceability concerns extended producer responsibility. Under Article 3(1)(15) PPWR, the “producer” for EPR purposes is whoever makes packaging or a packaged product available for the first time on the market of a given Member State. This role therefore changes with every sales stream:

1. Sales to a local distributor in country X (B2B)

In such a situation, the distributor is the ‘manufacturer’. It is the distributor who registers, reports tonnages and pays the ROP fees. The importer from Poland has no obligations in this country. However, they should confirm the division of roles in the contract and provide the distributor with details of the weights and materials of the packaging. Examples:

• a fertiliser manufacturer sells pallets of goods to a German agricultural wholesaler, which resells them;
• a cosmetics manufacturer supplies a French drugstore chain;
• a construction-chemicals manufacturer sells to a Czech distributor of building materials.

in each of these cases the wholesaler, the chain and the distributor act as distributors who are the first to make the product available on their market, and it is they, as “producers” within the meaning of Article 3(1)(15)(a), who bear the EPR obligations in the destination country.

Who draws up the DoC in this model?

he Declaration of Conformity does not follow the sales model – it is always drawn up by the manufacturer within the meaning of Article 3 PPWR, i.e. the entity placing the packaging or packaged product on the market under its own brand (here: the Polish manufacturer); the distributor is only obliged to check that the declaration exists (Article 19). More on the roles involved in signing declarations: Who signs the PPWR Declaration of Conformity?

2. Sales directly to end users in a country where the company has no establishment

n that case the company itself becomes the “producer” there: it must appoint an authorised representative for EPR (Article 45), register in the national producer register (Article 44) and pay the fees. Examples:

• the company’s own online shop ships dietary supplements to consumers in Germany;
• marketplace sales (Amazon, Kaufland, eMAG) to customers in France or Romania;
• deliveries of production inputs directly to farms in Lithuania, bypassing a local intermediary.

Who draws up the DoC in this model?

The authorised representative for EPR (Article 45) does not take over the Declaration of Conformity – the DoC is still drawn up and signed by the manufacturer. A separate role is the representative under Article 17 PPWR, who may draw up the DoC and keep the documentation on behalf of a non-EU manufacturer. We describe the difference between these two roles here: The Authorised Representative under the PPWR.

The traceability of packaging under the PPWR is fundamental

This is not a problem of the future. Already today, a Polish manufacturer selling B2C abroad (own online shop, marketplaces, deliveries straight to users) pays EPR fees in countries where the rates are in force and enforced, including:

• Germany – rejestr LUCID + system dualny,
• France – CITEO,
• Italy – CONAI,
• Spain – Ecoembes,
• Austria – ARA,
• the Netherlands – Verpact,
• Czechia – EKO-KOM.

Failure to register in these systems means the risk of penalties and sales blocks – marketplaces verify registration numbers. More on the fee mechanism and eco-modulation: PPWR and EPR fees.

A practical tool: the packaging identification table

We therefore recommend starting your preparations not with the declaration template, but with an inventory. The obligation to identify items stems directly from the Regulation. Article 15 of the PPWR requires the identification of the type and batch of packaging, whilst Annex VII requires technical documentation describing each component of the packaging unit. This is where the linking and mapping of data in the context of the PPWR begins. It is best to do this straight away in the context of the ROP as well. The same data on components, materials and weights will later be used to populate the declaration of conformity, tonnage reports and the calculation of fees in the destination countries.

The table below sets out our proposal for the minimum scope of data that should be collected for each type of packaging. This data should be updated for each series (batch). This is in line with the principle: declaration – by type; traceability – down to batch level.

Table: How to approach packaging traceability under the PPWR?

Guidance for the future on the traceability of packaging

It is worth thinking about the next stages now. For some organisations, it may also be important to carry out an assessment covering:

1. Recycled content with its proof (certificate) and the proof’s validity date .

The declared recyclate must be demonstrable (mass balance, certification e.g. RecyClass / EN 15343), and without a certified supply chain it does not count towards the result.

Obligation: minimum levels from 1.01.2030 (Article 7); in some countries recyclate already lowers EPR fees today.

⭢ Find out how to verify the recycled content.

2. Recyclability.

The packaging recyclability grade (A/B/C) will be the basis of eco-modulation and a direct tool for reducing EPR fees; not only finished packaging is assessed, but also its elements – a canister, closure, label, film or laminate can be assessed separately.

Obligation: recyclability grades become a requirement from 1.01.2030, but RecyClass Recyclability certificates are valid for 3 years – by seeking certification as early as, say, late 2027, you write it directly into the 2030 obligations and gain time for any packaging design changes.

What to do?

Traceability of packaging under the PPWR: step by step

1. Take stock of all packaging units and their components – down to the level of the adhesive and the label.
2. Collect specifications, declarations and test results from suppliers (Article 16) and link them to delivery batches.
3. Map the sales streams country by country and determine who the EPR “producer” is in each of them (Article 3(1)(15)).
4. Supplement the contracts with distributors with the division of EPR obligations and the flow of packaging weight data.
5. Only on this basis draw up the Declarations of Conformity (Article 39, Annex VIII) – the right entity, the right scope, the right evidence.

How can SRC help?

Silk Road Certification supports companies in identifying the type of sale, their role in the supply chain and the packaging components. We help determine who is the manufacturer drawing up the declaration of conformity, and who is the ‘manufacturer’ under the ROP responsible for the fees. As a result, the certification serves as valuable evidence supporting the declaration of conformity (DoC). That is why we do not start with a form template, but with the supporting documents on which the Declaration of Conformity should be based.

Certifications that bring value

• Certyfikacja REACH / SVHC / POP / RoHS – verification of the substance compliance of packaging materials.
• EPD – environmental product declarations for packaging and products.
• RecyClass Recycling Process – certification of recycling process control at recyclate suppliers.
• Recycled content – RecyClass Recycled Plastics Traceability (certification of recyclate traceability, confirming the PCR content required from 2030) and the EN 15343 Certification Programme – SRC’s own programme (accredited since 19.12.2025): traceability of recycled plastics and recycling process control.
• Recyclability – RecyClass Recyclability – certification of the recyclability grade (A/B/C) of packaging and its elements. The methodology covers three routes:
  • Letter of Compatibility – assessment of the technical recyclability of packaging semi-finished products and elements (e.g. the HDPE canister itself before assembly, the closure, the label) on a scale from A to C, for B2B communication. The outcome is a confirmation – a design and educational tool, not an official certification document.
  • Design for Recycling Certification – assessment of the technical recyclability of a packaging design (A–C). Full, paid certification; the certificate granted may be used in B2B and B2C communication of the packaging design (without the right to place the mark on the packaging).
  • Recyclability Certification – a full recyclability assessment of existing packaging as a whole (e.g. canister + closure + label, which the user will not separate with bare hands), taking into account the local collection and sorting infrastructure. It includes an audit and laboratory tests. Full, paid certification; the certificate may be used in B2B and B2C communication with the right to place the mark on the packaging, and in ESG and EPR reports and PPWR documentation – which is why it is at the same time a valuable document for your company’s credible communication.

We provide expert advice.

Would you like to find out more? Do you need help? Please get in touch!