Take stock of what you have

2. Take inventory of products and packaging
This doesn’t start with compliance, but with the product data itself. Consider which products you carry, in which packaging variants, and through which channels. This is usually a joint effort between category management and product data management.

The complete list of product data is often not centralized in one place. In many organizations, packaging variants turn up that are only listed in an old Excel spreadsheet or documented at a regional branch.

3. Collect product, material, and supplier data
Once you know what you have, you need to know what it’s made of and who made it. Procurement often plays a key role here, because suppliers must provide material specifications and substance information. Suppliers often don’t have this information readily available. So it may take some time before you have all the information you need.

Bring structure and hierarchy to packaging components

4. Organize packaging components and material information
Raw data is not yet usable data. This is where the data management team comes in. Packaging components (box, film, closure, label) are consistently named and linked to material types. This ensures that you don’t have to search for them manually every time you create a report.

5. Define packaging hierarchies and BoM relationships
Packaging often consists of multiple layers (primary, secondary, or tertiary), each with its own materials and weights. Product development and data management work together to definehow these layers relate to one another, detailed in a bill of materials down to the component level. A standard spreadsheet often gets bogged down by this complexity.

Documentation as needed and the long-term process

8. Generate the required PPWR compliance documentation (DoCs)
You do not need to print and save a Declaration of Conformity for each package in advance. However, the assessment and technical justification must already be complete before the packaging (and thus your product) is placed on the market. According to the regulations, you have ten days to submit a DoC once a regulatory authority requests it. Those ten days are achievable if the underlying data is in order.

Compliance therefore only generates the document when it is specifically requested. For example, when the sales team needs to send a DoC to a customer, or when an audit is coming up. The work lies in the preparation, not in the paperwork afterward.

9. Establish processes to ensure ongoing PPWR compliance
PPWR is not a project with an end date; it is an obligation that evolves with every new package, supplier, or market launch. When a component changes, you want to be able to easily implement that change in the Data Supply Chain.

Governance and IT work together on this. Who is responsible when a new product is added, how often is data reviewed, and who identifies upcoming regulatory changes (such as the 2028 material labels)? Without an owner to stay in charge, all your work will have been for nothing in no time.

There isn’t a single step in the process that one department can handle on its own. Category management, procurement, data management, quality, IT, and compliance all work closely together here. Becoming PPWR-ready isn’t something you can achieve with a checklist that just sits on a desk. It’s a process in which everyone knows what their responsibilities are.

Don't think of it as an IT project

The organizations that get through this process the fastest aren’t necessarily the ones with the fewest packaging variants. They’re the ones that take every step seriously—and designate a clear point person before the first data is collected, rather than trying to figure out afterward who should have been responsible.

Would you like to know where your organization stands right now in relation to these steps? Complete the PPWR quick scan, and within a few days you’ll know exactly which steps have already been completed and which still require attention.