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Tag: INDUSTRY GUIDE

  • PPWR Authorised Representative Suspension: What the ENVI Draft Report Changes

    PPWR Authorised Representative Suspension: What the ENVI Draft Report Changes

    5 minute read

    From August 12, 2026, PPWR requires producers selling packaged goods into EU countries where they do not have a legal entity to appoint a local authorised representative (AR) in each of those countries. That representative registers the producer in the national producer register, handles EPR reporting, and fulfils financial obligations on their behalf in that market.

    For a producer selling into five EU countries without a local office in any of them, that means five separate AR contracts, five sets of fees, and five parallel reporting obligations. Scaled to all major EU markets, the obligation can reach up to 26 national appointments. The fragmentation driving that complexity is the same problem an industry coalition recently called on the Commission to address through a digital EU-wide EPR registration and reporting platform.

    In December 2025, the European Commission proposed suspending this requirement for EU-established producers until 2035. That proposal is now moving through the European Parliament, and the Parliament member leading the review wants to narrow it significantly.

    The Commission’s Proposal

    The Commission’s proposal COM(2025) 982, would suspend Article 45(3) of PPWR (Regulation (EU) 2025/40) until 1 January 2035. During that period, EU-established producers would not be required to appoint a national AR in markets where they are not established. They could choose to do so voluntarily, but the obligation would be lifted.

    For producers established outside the EU, the original proposal gave each Member State the option to accept alternative verification methods rather than requiring a formal AR appointment.

    What the European Parliament’s Lead Reviewer Has Proposed Instead

    On 28 May 2026, Ingeborg Ter Laak, the European Parliament member leading the Environment Committee (ENVI) review of this proposal, published her draft report (ENVI_PR(2026)788916) with sixteen amendments. Her position reshapes the Commission’s proposal in four directions.

    1. The suspension would apply to small and micro businesses only

    The most significant change limits the suspension to producers that meet the EU’s definition of a microenterprise or small enterprise under Commission Recommendation 2003/361/EC:

    • Microenterprises: fewer than 10 employees, annual turnover or balance sheet total not exceeding €2 million
    • Small enterprises: fewer than 50 employees, annual turnover or balance sheet total not exceeding €10 million

    Medium-sized businesses (up to 250 employees, up to €50 million turnover) and large companies would keep the mandatory AR requirement in full. The MEP’s reasoning is practical: larger companies already have compliance teams and legal resources. Small and micro businesses are the ones that genuinely struggle to manage multiple national appointments at once.

    2. The suspension would end when the Circular Economy Act becomes law

    The draft adds a sunset clause: the suspension ends on whichever date comes first, 1 January 2035 or the date the Circular Economy Act (CEA) enters into force.

    The Circular Economy Act is a major piece of EU environmental legislation that the Commission is currently preparing. The MEP’s draft links the end of the AR suspension specifically to the moment the CEA is officially adopted into law, not to when its rules start applying in practice. In EU legislation, there is typically a gap of one or two years between a law being adopted and its provisions becoming operative. This means the suspension window could effectively be shorter than the 2035 backstop date implies: if the CEA becomes law in, say, 2029, the AR suspension could end at that point even if the CEA’s substantive rules do not apply until 2031.

    The Commission has indicated it plans to present the CEA proposal in Q3 2026, with full adoption unlikely before 2028-2029 at the earliest. Producers designing their 2028 compliance architecture around the suspension being in place should factor in this uncertainty.

    3. Non-EU producers: no change

    The MEP’s draft deletes the provision that would have allowed Member States to accept alternative verification methods for producers established outside the EU. For any producer based outside the EU that sells packaged goods on the EU Single Market, the mandatory AR requirement under PPWR stays exactly as it is.

    Company size makes no difference here. The MEP’s reasoning: producers based outside the EU are beyond the reach of EU enforcement mechanisms, and a named, locally accountable representative is the only practical way to hold them to their obligations.

    4. The suspension covers only the AR appointment, not the underlying EPR obligations

    A further amendment makes clear that lifting the AR obligation does not lift any of the other producer obligations. A micro-enterprise that does not appoint a national AR cannot use that as grounds to skip registering with a Producer Responsibility Organisation (PRO), the collective scheme that manages packaging waste collection and recycling in each country, or to avoid contributing to EPR fees. Every PPWR producer obligation remains in place. Only the requirement to appoint a representative is suspended.

    What This Means for You

    If you are a small or micro EU-established producer:

    You are the intended beneficiary of the suspension. If the regulation is adopted as the MEP proposes, you would not be required to appoint national ARs in countries where you sell but are not established. You could still do so voluntarily. The relief would last until the Circular Economy Act becomes law or until 1 January 2035, whichever comes first.

    If you are a medium or large EU-established producer:

    You are the intended beneficiary of the suspension. If the regulation is adopted as the MEP proposes, you would not be required to appoint national ARs in countries where you sell but are not established. You could still do so voluntarily. The relief would last until the Circular Economy Act becomes law or until 1 January 2035, whichever comes first.

    If you are a non-EU producer:

    The mandatory AR requirement applies in full in every Member State where you make packaging or packaged products available. Act on the basis of current law.

    What to Do Now

    The draft report is the MEP’s individual position. It still needs to go through a committee vote, potentially a Council position, and negotiations between Parliament and Council before anything is final. The PPWR becomes applicable on August 12, 2026. If the suspension is not formally adopted before that date, the AR obligation applies in full from day one, regardless of what happens afterwards.

    If you are a micro or small EU-established producer: Do not dismantle existing AR arrangements yet. Watch for the ENVI Committee vote and check with your national PRO whether it accepts direct voluntary registration without a formal AR mandate in the meantime.

    If you are a medium or large EU-established producer: Plan for full AR compliance from August 12, 2026. Your AR contracts need to be signed, your mandates in place, and your registration dossiers with each national producer register complete before the application date.

    If you are a non-EU producer: Treat the current law as applying in full. Appoint ARs in every market where you sell packaged goods.

    For everyone: the Circular Economy Act is now the file most likely to determine the long-term future of the AR requirement. Following its progress is the most effective way to plan ahead.

    How PAQR can help

    Regardless of how the authorised representative question is resolved, producers still need to know exactly what packaging they have placed on the market, in which quantities and formats, in each country. That data is what feeds your annual EPR reporting, and it is your responsibility to have it structured and accurate.

    PAQR gives you a central workspace to organise your packaging data by format and market, so that when annual EPR reporting requires accurate quantities and categories, the information is ready. Learn more at PAQR Solution.

    Click “Try now for free” on paqr.com to start a free trial.

  • PPWR Transport Packaging: Who Is Responsible for the Declaration of Conformity?

    PPWR Transport Packaging: Who Is Responsible for the Declaration of Conformity?

    5 minute read

    From August 12, 2026, every packaging type placed on the EU market requires a Declaration of Conformity confirming it meets the sustainability requirements of the Packaging and Packaging Waste Regulation (PPWR). For transport packaging, determining who is responsible for the Declaration of Conformity depends on a distinction the regulation draws between rigid and flexible formats. Many supply chain teams have not yet identified which side of it they sit on.

    Understanding this now matters. It determines who builds the technical documentation, who issues the Declaration of Conformity, and who carries the legal obligation if something is wrong.

    PPWR Transport Packaging: The Rigid vs Flexible Rule

    Under the PPWR, the obligation to issue a Declaration of Conformity falls on the manufacturer, defined as the party that manufactures packaging under their name or trademark, or that effectively controls the manufacturing of such packaging.

    For transport packaging, whether your business carries that manufacturer status comes down to one question: does the packaging exist as a finished item before it reaches you, or does it only become packaging when you apply it?

    Rigid packaging (pallets, crates, rigid containers) holds its shape. It is already a discrete, finished item when it leaves the supplier. The supplier, the pallet manufacturer for example, is typically the manufacturer under PPWR and is responsible for issuing the Declaration of Conformity. Exceptions are made if a rigid packaging is branded (or in other ways made “non-standard”), which would make the brand owner the manufacturer.

    Flexible packaging (stretch film, strapping, shrink wrap) has no fixed shape until someone applies it to an item, or a load. It is a packaging material until the moment you bring it into its final shape, e.g. by wrapping a pallet. The film manufacturer is only a supplier under the regulation, and your company, as the party that creates the finished transport packaging by applying it, becomes the manufacturer and carries the compliance obligation.

    A useful way to think about this: discrete items (a pallet, a crate) exist as finished packaging before they reach you. Continuous materials (a roll of stretch film, a reel of strapping) only become packaging when you apply them, and whoever does that application is the manufacturer.

    This changes where the Declaration of Conformity obligation sits, who builds the technical documentation, and who is responsible if something is wrong.

    Where This Distinction Comes From

    The distinction emerges from how the PPWR defines its key roles.

    Article 3(1)(13) defines the manufacturer as the party that manufactures (or has someone manufacture) packaging under their name or trademark. The Commission Guidance Document C(2026) 2151 final, published on March 30, 2026, reinforces a principle already familiar from sales packaging: packaging only truly exists once it has been filled or applied. An unused roll of stretch film is not packaging yet. It becomes packaging when it is wrapped around another item to fulfill a packaging function (such as: protection).

    That logic, combined with Article 3(1)(16)‘s definition of a supplier as a party that provides packaging materials to a manufacturer, places film and strapping producers firmly in the supplier column, and operators using those materials in the manufacturer column.

    The Contested Point: FAQ XV-12

    There is a catch. FAQ point XV-12 of the Commission’s official PPWR Frequently Asked Questions appears to suggest that a separate Declaration of Conformity is also required for films and strapping bands as standalone products. Legal and compliance professionals have noted that this reading contradicts the regulation’s own logic, since it would treat an unused roll of film as finished packaging. The Commission FAQ and the regulatory text are currently pulling in slightly different directions on this point.

    The practical takeaway: do not assume your film supplier will carry this obligation. If you are the one wrapping the pallet, you likely hold it. Confirm that position in writing with your suppliers before August 2026.

    What the Technical Documentation Must Cover

    Once your role as manufacturer is established for flexible transport packaging, you need to build the technical documentation that supports your Declaration of Conformity.

    At the August 12, 2026 application date, component-level data is sufficient for material composition. This means confirming the material makeup of each packaging component. Your documentation must also confirm conformity with the heavy metals limit: the combined concentration of lead, cadmium, mercury, and hexavalent chromium in packaging and its components must not exceed 100 mg/kg.

    The Declaration of Conformity and the supporting technical documentation must be kept available for national market surveillance authorities for five years for single-use packaging.

    Collecting this data from your film and strapping suppliers in a structured format from the outset, rather than requesting it under deadline pressure, makes building these files significantly more manageable.

    What This Means for Your Operations

    If your warehouse or outbound logistics team uses flexible packaging, here is what to act on now.

    1. Identify which transport packaging you create versus source as finished items. Use the discrete/continuous distinction as your guide. Discrete items sourced from a supplier (a pallet, a crate): their Declaration of Conformity. Continuous materials you apply yourself (stretch film, strapping): your Declaration of Conformity.
    2. Treat your flexible packaging material suppliers as material suppliers, not compliance providers. They need to supply material composition data and substance information to support your technical documentation. The declaration is yours to issue.
    3. Align with your suppliers on who holds which obligation. Make clear what data you need from them and why. Put that understanding in writing before August 2026.
    4. Do not rely on FAQ point XV-12 as a safe harbour. The Commission guidance and the regulation text do not fully align on this point. Build your compliance approach on the regulation itself.

    The rigid vs flexible distinction is one of those details overlooked in high-level PPWR summaries but with real operational consequences. If your business ships goods on stretch-wrapped pallets, you are likely a packaging manufacturer under PPWR, whether or not you have thought of yourself that way.

    Getting your role defined now is the first step to getting the rest right.

    How PAQR Can Help

    If you are the manufacturer for your flexible transport packaging, the Declaration of Conformity and its supporting technical files are your responsibility to produce and retain. PAQR’s PPWR compliance workspace gives you a central place to organise your packaging data by format, collect the material documentation you need from your film and strapping suppliers through the supplier request portal, and generate your Declaration of Conformity when your technical files are complete.

    Click “Try now for free” on paqr.com to start a free trial.

  • PPWR Non-Compliance: Legal Consequences Across the Supply Chain

    PPWR Non-Compliance: Legal Consequences Across the Supply Chain

    3 minute read

    From August 12, 2026, the Packaging and Packaging Waste Regulation (PPWR) creates binding obligations for packaging placed on the EU market. PPWR compliance is not optional, and the regulation sets out clear consequences for those who do not meet its requirements.

    PPWR Non-compliance looks different depending on your legal role. Here is what each carries.

    Manufacturers and brand owners

    Manufacturers are responsible for the physical conformity, safety, and technical documentation of their packaging.

    If packaging contains PFAS above permitted limits or exceeds heavy metal thresholds, it cannot legally be placed on the market. If non-compliant packaging has already reached the market, manufacturers are legally required to take corrective action, which may include withdrawal or a public recall.

    Member States are required under article 68 of the PPWR to impose effective, proportionate, and dissuasive administrative fines for infringements. The regulation does not cap the penalty amount, leaving this to national authorities. To comply with the EU’s requirement for a deterrent effect, some national authorities have already indicated that they intend to base their fines on the penalties set forth in the GDPR, where fines can amount to up to 7% of a company’s total global revenue. Other countries have enacted or drafted laws that impose fines of up to €600,000 (Spain), €200,000 (Germany, Netherlands), or €100,000 (France).

    Importers

    Importers carry legal responsibility for the compliance of packaging they bring into the EU.

    Importers cannot place packaging on the market until it meets all applicable requirements. Market surveillance authorities coordinate with customs to identify non-compliant packaging at EU borders. If non-compliant packaging reaches the market, the importer assumes liability for recall or withdrawal.

    In practical terms, missing documentation, such as an incomplete Declaration of Conformity or absent technical files, can result in shipments being held at customs.

    Distributors and retailers

    Before making a product available, distributors must verify that packaging is correctly labelled, that the manufacturer has met documentation requirements, and that the Producer is registered for EPR.

    If a distributor suspects non-compliance, they are legally prohibited from making the product available. If non-compliant packaging is identified after sale, authorities can require withdrawal.

    Retailers operating downstream who cannot verify supplier compliance carry legal exposure that the regulation places directly on their shoulders.

    Producers (EPR Registration)

    The Producer role under PPWR is the legal status tied to Extended Producer Responsibility. Producers are responsible for registering in national producer registers and contributing to the cost of packaging waste collection and recycling.

    Without registration in a Member State’s EPR database, a Producer is legally prohibited from making packaging available in that country.

    For e-commerce, PPWR goes further: fulfillment service providers and online marketplaces must verify a producer’s EPR registration. If proof of compliance is not provided, the platform must block the seller from accessing EU consumers.

    The common thread

    Across all four roles, the consequences of non-compliance share a pattern: prohibition from the market, mandatory corrective action, and financial penalties. Market surveillance, customs coordination, and EPR registration requirements all create documented audit trails.

    A single gap in documentation, a late Declaration of Conformity, an unregistered EPR Producer, or an unverified supplier, can affect your ability to sell across the EU market.

    How PAQR can help

    The consequences described in this post share a common root: documentation that is missing, incomplete, or not ready when it is needed. PAQR gives you a central workspace to keep your compliance records current and organized by packaging format and market, so that when an audit, a customs check, or a retail partner review requires them, they are there.

    That is the practical value. The peace of mind is the bonus.

    Click “Try now for free” to start a free trial.

  • EU EPR One-Stop Shop: What It Means for Producers

    EU EPR One-Stop Shop: What It Means for Producers

    5 minute read

    An industry coalition has called on the European Commission to introduce a digital EU EPR one-stop shop for registration and reporting as part of the upcoming Circular Economy Act. The joint statement, published on May 18, 2026 and signed by Ecommerce Europe, EuroCommerce, EUROPEN, and fellow organisations, sets out what this platform would need to do and why current EPR registration systems are falling short.

    Here is what the proposal involves, what is driving it, and what it would mean for companies placing packaged goods on the EU market.

    Why EPR Registration Is Complex Right Now

    Under PPWR, a producer is the economic operator who is first to make packaged goods available in a specific EU Member State. That producer must register in the national producer register of every Member State where they operate. For companies placing packaged goods across multiple EU markets, that means managing multiple separate national processes.

    Research published by Amazon in May 2026 puts specific numbers to that fragmentation. Across ten EU countries, Amazon identified 64 unique registration data fields, with each country requiring an average of sixteen. More than half of those fields are country-specific, and roughly 72% of current requirements go beyond what is mandated in the PPWR. Completing a registration can take anywhere from two to six weeks per country, and in several Member States the process can only be completed by the producer or an authorised representative.

    Authentication systems vary significantly across Member States. Some require national electronic credentials; others rely on email-based processes, including cases involving offline forms and signed contracts. Registration portals are frequently available in local languages only. Several countries, including Italy and Spain, require dual registration with both a national government registry and a Producer Responsibility Organisation (PRO), adding further steps to an already complex process.

    For producers operating across multiple markets, the cumulative administrative burden is considerable.

    What the Proposed EU EPR One-Stop Shop Would Do

    The coalition describes the proposed platform as a single digital point of entry for all mandated EPR schemes in the EU. Producers, or organisations acting on their behalf, would input EPR-relevant data once. That data would then be validated, translated where needed, and accessed by PROss and the competent authorities and registers in each relevant Member State.

    In short: one submission, made available to the national systems that need it, rather than a separate process in each country. This model mirrors the EU’s existing VAT OSS system. Under VAT OSS, companies declare and pay VAT for all EU sales through a single online portal in one member state, while the system handles the distribution.

    The proposed EPR One-Stop Shop would handle data the same way: you upload your packaging metrics once, and the platform routes it to the correct national registers and Producer Responsibility Organizations (PROs). The coalition envisions the platform as voluntary, designed to be user-friendly across a diverse range of companies and business models.

    The coalition emphasises that digitalisation of EPR compliance and monitoring has been underused as a policy tool, even as complexity in the EPR landscape has grown. The European Commission indicated its intention to explore a digital one-stop shop for EPR as part of the Single Market Strategy, published in May 2025; the coalition is now calling for that commitment to become a concrete legislative proposal in the Circular Economy Act.

    The signatories have committed to delivering detailed recommendations to the Commission on the features the platform would need in order to function effectively.

    What This Would Mean for Producers

    The most direct impact of a functioning one-stop shop would be a reduction in the time, cost, and process complexity of registering across multiple Member States. Producers currently placing packaged goods in multiple EU markets must manage as many separate registration systems. Under the proposed model, the initial data submission happens once.

    The coalition identifies particular benefits for smaller producers and cross-border e-commerce sellers, who currently face the greatest proportional burden from fragmented processes, including the cost of appointing authorised representatives in multiple markets.

    One thing the proposed one-stop shop does not change: the underlying data that EPR registration and reporting requires. Producers will still need to know what packaging they are placing on the EU market, in which quantities and categories, and keep that information accurate for annual reporting. A simplified registration portal makes having structured, current packaging data more important, not less, because that data now feeds a single submission point with broader reach.

    Manufacturers of packaging or packaged goods subject to PPWR will also continue to carry Declaration of Conformity obligations and the full Annex VII technical documentation requirements that sit alongside EPR. The one-stop shop proposal addresses registration and reporting infrastructure; it does not alter the compliance documentation picture.

    Where Things Stand

    The joint statement is an industry call to the Commission, not a legislative outcome. The Circular Economy Act has not yet been published, and the scope and form of any one-stop shop will depend on the final text. For current EPR registration requirements, refer to the national producer registers in each relevant Member State and the official PPWR text on EUR-Lex.

    Companies with EPR obligations across multiple EU markets should monitor the progress of the Circular Economy Act and the Commission’s response to the coalition’s recommendations.

    How PAQR helps

    A digital one-stop shop simplifies how and where producers submit EPR data. The underlying data still needs to be structured and accurate before any submission is possible: what packaging you have placed on the market, in which formats and categories, with what documentation behind it.

    PAQR gives you a central workspace to organise your packaging data. When annual EPR reporting requires accurate quantities and categories, and when your Declaration of Conformity and technical files need to be complete and retrievable, the same structured dataset covers both. Learn more at paqr.com/ppwr-solution/.

    Click “Try now for free” on paqr.com to start a free trial.

  • PPWR PFAS Restrictions: What Food-Contact Packaging Teams Need to Know

    PPWR PFAS Restrictions: What Food-Contact Packaging Teams Need to Know

    6 minute read

    From August 12, 2026, food-contact packaging placed on the EU market must meet specific PPWR PFAS concentration limits under the Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40). The thresholds are precise, the data requirements are demanding, and the documentation burden falls directly on your supply chain as manufacturer.

    This post covers the PPWR PFAS restrictions your team needs to prepare for, the supplier data you must secure, and how to structure your technical documentation before the deadline.

    1. How the PPWR Defines PFAS

    Before requesting supplier data, it is worth agreeing on exactly what the regulation targets. Under article 5 of the PPWR, PFAS is defined as any substance that contains at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom, without any hydrogen, chlorine, bromine, or iodine attached to it.

    The definition includes specific exceptions. If a substance only contains CF3-X or X-CF2-X’ groups, where X or X’ is a methyl, methylene, aromatic group, or carbonyl group, it may fall outside the restriction. Your packaging team should cross-reference the exact chemical structures of your materials against these exemptions before drawing conclusions.

    2. The Three Critical PFAS Thresholds

    Starting August 12, 2026, food-contact packaging cannot be placed on the market if PFAS concentrations meet or exceed any of the following limits:

    • 25 ppb for any single PFAS, measured using targeted PFAS analysis. Polymeric PFAS are excluded from this quantification.
    • 250 ppb for the sum of PFAS, measured as the sum of targeted PFAS analysis. Polymeric PFAS are also excluded here.
    • 50 ppm for total PFAS. This threshold is broader: it includes polymeric PFAS.

    The distinction between the first two thresholds and the third matters. Targeted analysis covers specific PFAS compounds. Total PFAS analysis is wider and will catch materials that appear compliant under targeted testing alone. Your technical documentation needs to address all three.

    3. The “Total Fluorine” Trap

    This is where many packaging teams run into difficulty, and it is worth understanding before you start collecting supplier data.

    If a packaging material’s total fluorine content exceeds 50 mg/kg, you cannot assume compliance. At that point, the manufacturer, importer, or downstream user is legally required to demonstrate how much of that fluorine comes from PFAS and how much does not.

    In practice, this means a standard material declaration from your supplier is not enough. You need documentation that differentiates between PFAS-sourced fluorine and non-PFAS fluorine, and that breakdown must form part of your Annex VII technical files. If a supplier cannot provide this, treat it as a procurement issue to resolve now.

    4. Other Chemical Restrictions to Prepare For

    PFAS is the most technically demanding restriction, but your compliance files must also cover two additional areas.

    • Heavy metals: The combined concentration of lead, cadmium, mercury, and hexavalent chromium in packaging and its components cannot exceed 100 mg/kg. This threshold applies to the sum of all four metals, not to each individually.
    • Bisphenol A (BPA): A comprehensive restriction on BPA applies across food packaging and food-contact materials. Factoring in the 18-month general transition period, managing BPA-free supply chains alongside the new PPWR chemical thresholds is a parallel compliance priority for 2026. If BPA has not yet been addressed in your technical documentation, it should be.

    5. What to request from your suppliers

    Your suppliers may not be accustomed to providing this level of chemical analysis, and some will need clear guidance on what is required. Here is the breakdown of what your technical files must contain for each food-contact material.

    For PFAS:

    • Targeted PFAS analysis results, listing individual PFAS compounds and concentrations in ppb
    • Sum of PFAS concentrations, including results with prior precursor degradation where applicable
    • Total PFAS measurement in ppm, covering polymeric PFAS
    • Where total fluorine exceeds 50 mg/kg: a breakdown confirming the quantity of PFAS-sourced versus non-PFAS fluorine

    For heavy metals:

    • Declarations or test results showing combined lead, cadmium, mercury, and hexavalent chromium concentrations below 100 mg/kg

    For BPA:

    • Declaration of compliance according to Annex III of the Commission Regulation (EU) 2024/3190, confirming the BPA-free formulation, or documentation of BPA use within permissible limits.

    Request these in a structured format that can be stored and retrieved as part of your formal technical documentation.

    How PAQR can help

    The PFAS documentation challenge is largely a data collection and organisation problem. Your suppliers need to know exactly what to send, you need a structured place to store it, and your technical files need to be complete and retrievable when an audit requires them.

    PAQR’s supplier request portal lets you send targeted data requests directly to your suppliers, specifying exactly which declarations, test results, and certifications you need. Responses are stored centrally alongside the rest of your packaging data, so your PFAS declarations, heavy metal certifications, and BPA confirmations sit in the same auditable workspace as your component specs, recyclability assessments, and supplier certificates.

    When you are ready to generate your Declaration of Conformity, the documentation you have collected feeds directly into the process.

    Click “Try now for free” on paqr.com to start a free trial.

  • Clarity on PPWR Reuse: The Exemption for Pallet Wrappings and Straps was officially published on May 6, 2026

    Clarity on PPWR Reuse: The Exemption for Pallet Wrappings and Straps was officially published on May 6, 2026

    3 minute read

    The transition to the Packaging and Packaging Waste Regulation (PPWR) is often seen as a steep climb for manufacturers and suppliers. However, the latest update from Brussels offers a significant sigh of relief for logistics operations.

    Commission Delegated Decision (EU) 2026/429, published this week, introduces a critical exemption regarding the reuse of pallet wrappings and straps.

    Here is what you need to know, without the legal jargon.

    The Background: The 100% Reuse Target

    Under the original PPWR framework (Article 29), transport packaging used for shipments within the same company or between partner sites in the EU was subject to a strict 100% reuse target. For many of you, this meant a looming requirement to transition all stretch foil, plastic wrapping, and metal or plastic strapping to reusable alternatives by the deadline August 12, 2026.

    The Change: A Practical Exemption

    The Commission has recognized that for many packaging lines, the shift to 100% reusable wrappings is currently technically difficult and financially disproportionate. High investment costs in automated packaging lines and a lack of market-ready, scalable reusable solutions for these specific formats would have caused significant supply chain disruption.

    The Decision: Economic operators are now exempted from the 100% reuse requirements for:

    1. Pallet wrappings (e.g., stretch and shrink films)
    2. Straps (used for stabilization and protection during transport)

    This applies specifically to the mandates for internal company transfers and domestic B2B shipments.

    Marketing teams can update digital content without reprinting packaging. Recalls can be precise to individual units. Country-specific information can be served dynamically. Sustainability stories surface at the moment of consumer engagement without cluttering the design.

    What this means for your operations

    • Reduced Capex Pressure: You are no longer legally mandated to overhaul your packaging lines to accommodate reusable pallet stabilization systems for internal or domestic transport in the immediate term.
    • Focus on Recyclability: While the reuse mandate for these specific items is lifted, the requirements for recyclability and recycled content targets under the broader PPWR still apply. Your focus should remain on sourcing high-quality, recyclable films.
    • Reporting remains key: Even with exemptions, data is the backbone of compliance. You still need to accurately track the volumes of these materials to meet your annual reporting obligations and EPR (Extended Producer Responsibility) requirements.

    How PAQR helps

    At PAQR, we believe compliance should be a competitive advantage, not a headache. Our platform is already updated to reflect these regulatory shifts.

    We help you categorize your packaging formats accurately so that you benefit from every available exemption while staying fully compliant with the targets that do remain.

    The bottom line: You can keep your pallets secure with traditional wrappings for now, just make sure your data is as secure as your cargo.

  • Sunrise 2027: Why the Barcode You’ve Used for 50 Years Is Being Replaced

    Sunrise 2027: Why the Barcode You’ve Used for 50 Years Is Being Replaced

    5 minute read

    In 1974, a pack of Wrigley’s Juicy Fruit became the first product ever scanned at retail using a barcode. For the next 50 years, the 1D barcode (those familiar vertical lines) became the universal language of global commerce.

    That era is ending. GS1, the standards body that governs barcodes, has set 2027 as the global retail transition date from 1D to 2D codes. The initiative is called Sunrise 2027, and it requires every point-of-sale system worldwide to read 2D codes by then.

    Several major retailers are already ahead of schedule. For packaging teams, this is an active project, not a future consideration.

    Why the 1D barcode is being retired

    A traditional barcode encodes a Global Trade Item Number (GTIN) in a linear EAN or UPC format. It does one thing: identify the product. Scan it, get a number, look up the product in a database. For checkout and basic inventory, this has been enough.

    Modern commerce demands more. Consumers want to know origin, recall status, allergens, and disposal instructions.

    Brands want serialised tracking, dynamic engagement, and recall precision. Retailers want freshness automation and compliance reporting.A 1D barcode holds about 20 characters of data. That is the entire ceiling. Everything else has to live in a backend system, accessible only to those with the right credentials.

    What 2D codes make possible

    A standard QR code holds several hundred times more data than a 1D barcode. The capacity is the easy part. The bigger shift is the GS1 Digital Link, a standardised URL structure that turns a QR code into a gateway to dynamic, audience-specific information.

    One QR code on a pack can serve different data to different scanners:

    • A consumer with a smartphone sees product info, allergens, sustainability credentials
    • A retailer at checkout gets GTIN, price lookup, loyalty integration
    • A logistics operator gets batch number, expiry date, traceability
    • A regulator gets the full compliance record

    Marketing teams can update digital content without reprinting packaging. Recalls can be precise to individual units. Country-specific information can be served dynamically. Sustainability stories surface at the moment of consumer engagement without cluttering the design.

    The pitfalls are real

    None of this means the transition is straightforward. Five challenges are worth understanding before you start.

    Print quality and verification

    Linear barcodes tolerate imperfect printing. QR codes do not. Print defects, substrate variations, varnish effects, and color contrast all matter more. Every packaging format (flexible film, corrugated, glass, metal) has its own verification challenges.

    Symbology selection

    QR codes are the consumer-facing standard, but the 2D landscape also includes Data Matrix codes (common in pharma and logistics), PDF417, and Aztec. Brands operating across sectors need a clear policy on which codes go where.

    Dual-code transition periods

    Through 2027 and beyond, many brands will need both a 1D and a 2D code on the same pack. Managing layout, regulatory clearances, and data consistency across two codes on every SKU multiplies the workload.

    Data governance

    A 1D barcode links to a static database record. A GS1 Digital Link QR links to a live digital resource that can and should be updated. An outdated or broken link on a product already in market is not just a poor experience. It can be a compliance failure.

    Consumer literacy

    Most consumers know QR codes link to digital content, but not everyone scans, and not everyone trusts what they find. Designing a QR-linked experience that adds genuine value (rather than checking a marketing box) requires content strategy investment.

    How a packaging management hub helps

    Managing GS1 Digital Link QR codes is not a design task. It requires coordination across regulatory data, supply chain identifiers, digital content, and brand guidelines, applied reliably across hundreds or thousands of SKUs.

    Sunrise 2027 is the starting line, not the finish line

    Treating Sunrise 2027 as a deadline (get QR codes in place, ensure POS compatibility, move on) underestimates what is actually happening.

    This is a structural change in how packaging connects products to the broader data ecosystem. The 2027 deadline starts the new infrastructure. It does not end it.

    Organizations that recognize this early, and treat the QR transition as an opportunity to build better data governance rather than a compliance box to tick, will be positioned for everything that comes next: dynamic regulatory environments, transparency demands, traceability requirements, and the EU Digital Product Passport.

    The barcode that scanned chewing gum in 1974 served its purpose. The technology replacing it can do far more. But only for organisations that build the right foundation.

    PAQR generates GS1-compliant 2D codes alongside your full packaging data set. One platform, one source of truth, ready for Sunrise 2027 and what comes after. Click “Try now for free” on paqr.com to start a free trial.

  • Mastering PPWR in Six Moves: A Compliance Blueprint for European Businesses

    Mastering PPWR in Six Moves: A Compliance Blueprint for European Businesses

    6 minute read

    The EU Packaging and Packaging Waste Regulation (PPWR) replaces a patchwork of national rules with one set of laws that apply directly in all 27 Member States. It covers every package placed on the EU market, from a single wrapper to an industrial pallet.

    If you manufacture, brand, fill, import, or retail packaged goods in the EU, this is a structural change to how you operate. Below are the six strategic moves that turn PPWR from a compliance threat into an operational advantage.

    1. Audit and redesign for recyclability

    By 2030, every piece of packaging needs a Recyclability Performance Grade of A, B, or C. Anything below C is banned. By 2038, only A and B are allowed.

    What to do: Audit your portfolio now. Phase out multi-material laminates, heavily dyed plastics, and adhesives that disrupt recycling streams. Build a single source of truth for component data, including supplier specs. EPR fees will be modulated by your grade, so a Grade A design lowers your tax bill on every unit shipped.

    2. Cut packaging size and ban shipping air

    Packaging weight and volume must be reduced to the minimum needed for function, hygiene, and safety. Double walls and false bottoms are banned. The empty space ratio in transport, grouped, and e-commerce packaging is capped at 50%, and void-fill materials like bubble wrap and paper count as empty space.

    What to do: Invest in box-on-demand technology or smart packing algorithms. Document your minimisation logic in technical files for every primary package.

    3. Lock in recycled plastic supply

    Mandatory minimum post-consumer recycled (PCR) content takes effect January 1, 2030.

    • 30% for contact-sensitive PET packaging
    • 10% for contact-sensitive non-PET plastics
    • 30% for single-use plastic beverage bottles
    • 35% for all other plastic packaging

    Targets jump again by 2040, hitting 65% for beverage bottles and other non-contact-sensitive plastics.

    What to do: Start procurement conversations with recyclers now. Long-term contracts beat last-minute scrambles. Make sure recycled inputs comply with Regulation (EU) 2022/1616 on food-contact safety.

    4. Build reuse into core operations

    By 2030, at least 40% of transport packaging must be reusable, aiming for 70% by 2040. Inter-site and intra-Member-State transport packaging must be 100% reusable. Beverage distributors must offer at least 10% of products in reusable formats. By 2027, HORECA businesses must let consumers bring their own containers at no extra cost.

    What to do: Treat reuse as a core logistical operation, not a sustainability project. Invest in reverse logistics, durable formats, and cleaning facilities. The regulation legally protects HORECA operators from food safety liability when consumer containers are involved.

    5. Eliminate restricted chemicals and formats

    From August 12, 2026, food-contact packaging cannot exceed 25 ppb for specific targeted PFAS, 250 ppb for the sum of PFAS, or 50 ppm for total PFASs. If total fluorine exceeds 50 mg/kg, you must be able to prove the fluorine does not come from PFAS. Heavy metals (lead, cadmium, mercury, hexavalent chromium combined) cannot exceed 100 mg/kg. By 2030, dine-in disposables, hotel miniatures, and retail-grouping shrink wrap are banned.

    What to do: Test your packaging for PFAS and heavy metals now. If your suppliers cannot provide composition declarations, treat that as a procurement problem to fix immediately. Limit compostable materials to the narrow categories the regulation specifies, otherwise you contaminate recycling streams.

    6. Modernise your compliance documentation

    Every package needs a conformity assessment, technical documentation, and an EU Declaration of Conformity before it goes to market. Records must be kept for 5 years (single-use) or 10 years (reusable). EPR registration is required in every Member State you sell into. By August 12, 2028, packaging must carry a harmonised pictogram label for sorting. Furthermore, by February 12, 2029, reusable packaging must carry a QR code or digital data carrier to track trips and rotations.

    What to do: Digitise compliance tracking. Build a system that generates and stores Declarations of Conformity automatically, alerts you when supplier data changes, and produces audit-ready files on demand. Importers carry the same legal burden as domestic manufacturers, so document verification needs to happen before customs clearance.

    The bottom line

    Companies that treat PPWR as a compliance hurdle will absorb rising EPR fees, supply chain bottlenecks, and product recalls. Companies that audit their portfolios now, lock in recycled plastic contracts, right-size their boxes, and digitise their documentation will move from compliance into competitive advantage.

    The window to act is open. 

    PAQR is the single source of truth for your packaging data. Generate Declarations of Conformity, track supplier data, and stay audit-ready as the regulation evolves. Click “Try now for free” on paqr.com to start a free trial.

  • The Recyclability Paradox: Why the Holy Grail of Packaging Engineering Keeps Moving

    The Recyclability Paradox: Why the Holy Grail of Packaging Engineering Keeps Moving

    6 minute read

    For the modern packaging developer, the last decade has reshaped the brief. We have moved from “barrier at all costs” and shelf-appeal optimisation to a world where end-of-life dictates the very first design decision.

    But there is a painful truth that the public, and even many regulators, rarely grasp: recyclability is not a property of a material. It is a property of a system.

    This post covers why the momentum behind recyclability has accelerated, why “recyclable” is a moving target, and how packaging developers can navigate the assessment landscape.

    Why recyclability has reached this moment

    The regulatory hammer

    The transition from the EU Packaging and Packaging Waste Directive (PPWD) to the Regulation (PPWR) turned guidelines into law. By 2030, all packaging on the EU market must be recyclable at scale. Voluntary commitments became mandatory compliance, which forced companies from pilot projects into full portfolio overhauls.

    EPR fees that actually bite

    Extended Producer Responsibility fees are now eco-modulated. In France (CITEO) and Italy (CONAI), a pouch with a non-compatible barrier or carbon-black pigment that disrupts NIR sorting attracts much higher fees. Highly recyclable mono-materials get bonuses. For an FMCG company at scale, those differentials translate into millions of euros per year.

    Investor pressure

    Institutional investors now treat un-recyclable portfolios as stranded asset risk. If a primary revenue stream depends on a format that will be banned or heavily taxed within five years, that is a financial liability. Recyclability has moved from the marketing department to the CFO’s office.

    Why deterministic recyclability is a myth

    A 100% PE pouch is not automatically recyclable just because it is polyethylene. The devil is in the components: the inks, adhesives, closures, and residual contents.

    Functionality versus circularity

    Packaging exists to protect the product. For decades we solved that with complexity:

    • PA/PE for puncture resistance and gas barrier
    • PET/Alu/PE for total light and moisture protection
    • PVDC coatings for exceptional oxygen barriers

    Each layer is a technical achievement and a recycling problem. PA in a PE stream causes gels and process instability. Alu foils trigger metal detectors or cause inclusions. The challenge for today’s developer is hitting 95% of that performance with mono-material families or functional barriers the recycling system can tolerate.

    The sorting blind spot

    A package is only recyclable if it can be sorted. This is where chemistry meets mechanical engineering.

    • Size matters: items under 5cm often fall through trommel screens at Material Recovery Facilities and end up in residual waste.
    • NIR detection: Near-Infrared sorters identify polymers by reflected light spectrum. Dark pigments like carbon black absorb the signal, making the package invisible to the sorter.
    • 2D vs 3D: a flexible flat pouch may behave like paper in a wind sifter, even if it is plastic, and end up in the wrong stream.

    The “at scale” problem

    To be considered recyclable, a material needs collection, sorting, and recycling infrastructure covering a significant portion of the population. This creates a chicken-and-egg problem: recyclers will not invest in specialised lines for new mono-materials until volume exists, and developers will not switch to those materials until they are officially classified as recyclable.

    The assessment landscape

    There is no single global standard. Developers must navigate a patchwork of national methodologies, each measuring recyclability differently.

    RecyClass (Europe-wide, cross-industry)

    The most influential tool for plastic packaging today. Uses Design for Recycling guidelines and a grading system from A to F. Based on actual laboratory testing: if you want to know whether a new adhesive is compatible with the PE stream, RecyClass likely has a protocol for it. Looks at the entire pack (body, cap, label, ink) and determines if the resulting recycled polymer has high, medium, or low value.

    Germany’s Minimum Standard (Zentrale Stelle Verpackungsregister)

    One of the most rigorous definitions in Europe. Three pillars: collection (is there a path to the bin?), sortability (can it be detected and assigned to a fraction?), and recycling (no incompatibilities like certain EVOH layers or PETG in PET).

    COTREP (France)

    A collaboration between CITEO, Elipso, and SRP. Produces highly specific technical notices, like the exact percentage of EVOH allowed in a PE film before it loses its recyclable status in the French market.

    APR (Association of Plastic Recyclers, North America)

    Where Europe leans on the Precautionary Principle, APR focuses on the quality of the final recycled flake. The APR Design Guide is the gold standard in North America, using Critical Guidance testing where a package goes through a simulated recycling process to see whether it harms the resulting Post-Consumer Resin.

    How to design for a fragmented landscape

    Design for the strictest market

    Launching across EMEA means designing for the strictest assessment, usually Germany or France. If your pouch passes the German Minimum Standard, it will likely be accepted elsewhere.

    Embrace mono-materials, but validate

    Switching to mono-PE or mono-PP is the safest bet, but do not assume compatibility:

    • Barrier layers: limit EVOH to under 5% of total weight, ensure tie-layers are compatible.
    • Inks and adhesives: use washable or recycling-compatible systems.
    • Labels: match the label material to the container polymer or use floatable labels for PET bottles.

    Move from “recyclable” to “circular”

    The ultimate goal is not just a package that can be recycled, but one that contributes to high-quality recycled material. That means avoiding anything that downgrades the resulting feedstock. Moving from coloured PET to clear PET, for example, enables bottle-to-bottle recycling, the pinnacle of the circular economy.

    The expert’s mandate

    Recyclability is the most complex engineering challenge our industry has faced in 50 years. It demands more than material science. It demands systems thinking, an understanding of NIR laser wavelengths, washing medium densities, and twin-screw extruder chemistry.

    National assessment approaches provide a roadmap, but they are still evolving. The mandate for developers is to lead that evolution: design packaging that does not just pass the test, but actively feeds the machines that will build the next generation of materials.

    PAQR helps packaging teams centralise component data, supplier specifications, and assessment results in one workspace, ready for whichever methodology your market demands. Click “Try now for free” on paqr.com to start a free trial.