Key Takeaways
- The PPWR has applied since 12 August 2026. The proposed relief on authorised representatives is still only a proposal, and several implementing acts are late.
- "Manufacturer" and "producer" are separate PPWR roles. The manufacturer is one party per packaging across the EU. The producer is decided per member state. A single "brand owner" field in PIM or ERP can't hold both.
- Since 27 September 2026, EU rules against generic environmental claims apply too. Packaging claims in product texts, images, and marketplace feeds are now a second compliance surface next to the PPWR itself.
- The Annex V format bans (2030) and mandatory deposit return systems (2029) will force SKU and assortment decisions. Contracts signed this year already run into those dates.
- A PIM helps when it stores roles, claims, and country variants as data with evidence attached. It doesn't make the legal calls.
Most PPWR guides stop at registration numbers, component weights and recyclability grades. Those still matter. But two months after go-live, the questions reaching product data teams have shifted. Teams now ask who signs the declaration for a private-label carton and whether the shop can keep saying "recyclable packaging". This article covers those questions and what they change in PIM, ERP, shop, marketplace, and CRM data. For a system-by-system view of component weights and EPR reporting, see our breakdown of PPWR legislation across PIM, ERP and marketplaces.
Where PPWR Stands This Autumn
The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, applies directly in all member states. No amending act has moved the application date. Some suppliers still describe it as "pending" in their emails. It isn't.
What is pending is the secondary legislation and the political fix for small cross-border sellers. SMEunited, the European SME association, says the implementing acts weren't issued on time, and the co-legislators still haven't approved the simplification proposed in the Environmental Omnibus, according to Packaging Europe. The same report puts national registration at over €500 per country and an authorised representative at €200 to €800 per country. Germany's environment ministry has proposed exempting traders that place less than ten tonnes of packaging on the market per year. The upcoming Circular Economy Act may address EPR fragmentation later.
Run the numbers for an EU seller shipping direct to consumers in 15 other member states. That's at least €10,500 in fixed costs before a single kilo of packaging is licensed.
Plan against the regulation as published. Treat any relief from the omnibus as a bonus.
Some sellers will respond by dropping countries. That decision becomes a data job. The shop's shipping countries, the marketplace country listings, and the PIM's market assignments must change together. A product delisted in Austria on a marketplace but still shippable to Vienna from the own shop is an unregistered sale. In most stacks, these three settings live in three different admin panels, owned by three different teams.
Manufacturer And Producer Are Two Different Fields
The PPWR uses both terms, and they answer different questions.
The manufacturer carries the product-safety-style obligations: conformity assessment, technical documentation, the EU declaration of conformity, and identification on the pack. Under Article 3 of the regulation, where packaging is designed or made on someone else's behalf, the manufacturer is the party that markets it under its own name or trade mark. So each packaging has one manufacturer, valid across the EU.
The producer carries extended producer responsibility: registration, reporting and fees. That role is assigned per member state, based on who first makes the packaging available there. One SKU can have the same manufacturer everywhere and a different producer in each country.
Most systems hold neither role cleanly. A PIM usually has "brand" and "supplier". An ERP has "vendor" on the item master and "legal entity" on the sales order. None of these map to a PPWR role, and the gaps show up in two places.
Private label is the first. A manufacturer fills the same bottle for its own brand and for two retailer brands. For the retailer variants, the retailer markets the product under its trade mark, so the retailer is the PPWR manufacturer. The filler supplies the evidence. The retailer signs the declaration. If the PIM attaches the declaration to the bottle component only, every brand variant inherits the same signatory, and two of the three are wrong.
Distribution is the second. A brand owner sells to a distributor in Poland, which resells part of the stock to retailers in Czechia. The brand owner stays the manufacturer for all of it. The producer in each country depends on who first makes the goods available there, and the distribution contract decides who files the reports. Many of those contracts predate the PPWR definitions and say nothing about it.
The data model that follows from this is specific. The manufacturer sits on the packaging variant, meaning the combination of physical packaging and brand. It links to the declaration of conformity and the technical documentation, with a retention date of five years for single-use and ten for reusable packaging. The producer sits in a separate table keyed by selling entity, member state, and channel, with the registration number, compliance scheme, authorised representative, and validity dates. Then the ERP resolves the producer per ship-to country on each order line. Without that, the EPR report has to guess.
Our customers turn to us with this exact mix-up. In projects we implemented for manufacturers that sell under their own brand and under retailer brands, the starting point was one "manufacturer" field per product, filled with the company's own name for every variant. Generated declarations for private-label items named the wrong party. The fix was structural. Packaging variants became separate records per brand, each with its own manufacturer, declaration, and retention date. The producer role moved to a country table on the selling entity. Document generation then followed the data without manual edits.
Green Claims Became A Second Packaging Front On 27 September
Since 27 September 2026, member states have applied Directive (EU) 2024/825 on empowering consumers for the green transition. It amends the Unfair Commercial Practices Directive and tightens the rules on environmental claims, as Bird & Bird summarises in its analysis of the directive. It's consumer law. But for packaging, it lands in the same product records as the PPWR, and the two interact in ways most compliance plans haven't mapped.
Generic claims come first. Terms such as "eco-friendly", "green", "ecological", "biodegradable" and "biobased" count as generic unless the same medium explains them specifically. A generic claim then needs recognised excellent environmental performance, such as the EU Ecolabel or an officially recognised EN ISO 14024 Type I label. "Eco-friendly packaging" in a marketplace bullet point now carries risk in every country that feed reaches.
The directive also bans presenting a legal requirement as a distinctive feature of an offer. This is where the PPWR matters. The PPWR now limits PFAS in food-contact packaging. A "PFAS-free packaging" badge on a food product may present that legal requirement as a selling point. It may also be inaccurate, because the PPWR sets thresholds, and below-threshold is different from zero. Steps that go beyond the legal minimum can still be advertised. Where national enforcers draw that line is not settled yet, so this is a review item, with no ready answer. The same logic will reach "recyclable" claims once recyclability becomes a market access condition in 2030.
Partial claims are the third trap. The directive prohibits an environmental claim about the whole product when the improvement concerns only one aspect. A "sustainable product" tag because the carton now uses recycled fibre is a textbook case.
Then there are sustainability labels. Under the directive, they must be established by public authorities or based on a certification scheme with independent third-party verification. In-house leaf icons and "green choice" seals often sit in image sets and DAM folders, far from the compliance team's review.
Bird & Bird also points to B2B relevance. Some member states apply these advertising rules to B2B communication, and resellers expect to repeat the manufacturer's claims. That puts claims into the CRM, the B2B portal, and the product data sheets sent to retail customers.
A claim without an evidence link is a liability with a SKU number.
Packaging claims usually live in many places at once: long descriptions, bullet points, marketplace attribute fields, image overlays, PDF data sheets, translations and, increasingly, AI-generated texts. Nobody owns them as a set. So the practical fix is to make claims governed objects in the PIM:
- A claim library with approved wording per language, the scope (whole product, packaging or one component) and the evidence document behind it.
- Allowed markets and channels per claim, plus a review date, because evidence expires when packaging changes.
- An export check that scans free-text attributes for blocked terms per market and stops the feed or flags the SKU.
AI text generation needs the same rules as input: the approved claim list and the blocked terms. Without them, a model trained on years of marketing copy will write "eco-friendly" with great confidence.
In projects we implemented for manufacturers with large catalogues, the first claims audit usually turns up wording nobody owns. Typical finds are "eco" copy from an old print catalogue, translated into several languages and copied into marketplace bullets years ago. Teams couldn't fix what they couldn't find. After the claims moved into a separate entity with evidence links, a term scan across all text attributes per language produced a concrete list of affected SKUs per channel. Fixing them then became normal content work.
Annex V Turns Into Assortment Decisions
From 1 January 2030, Article 25 and Annex V of the PPWR restrict a list of single-use formats. For manufacturers, the relevant entries include single-use plastic packaging for fresh fruit and vegetables under 1.5 kg, single-use portion packaging for condiments, sauces, sugar and creamer in the hotel, restaurant and catering sector, and small single-use toiletry packaging in accommodation (under 50 ml for liquids or 100 g for non-liquids). Very lightweight plastic carrier bags are also restricted, with exceptions.
The data problem here is that several bans depend on where the product is used. The PIM knows "portion pack, 10 g". It rarely knows "sold to hotels". That information sits in the CRM customer segment and in ERP price lists for food service.
So the work is a join across systems. Product data needs an "intended use sector" attribute and an Annex V flag with a review owner. Sales needs a list of customers in the affected sectors. And contract managers need to know which supply agreements run past 2029. A five-year amenities contract with a hotel chain signed this autumn already ends after the ban starts. A manufacturer of hotel miniatures has fewer than four years to replace those formats, and redesign, testing and tooling eat most of that.
Deposit Return Systems Split SKUs By Country
By 1 January 2029, member states must run deposit return systems for single-use plastic beverage bottles and single-use metal beverage containers up to three litres, under Article 50. Member states that reach a separate collection rate above 80% in 2026 can be exempted if they submit an implementation plan, and certain beverage types are excluded.
For product data, a deposit means country-level facts on a product that used to be pan-European: a deposit flag, the deposit amount, the scheme's mark on the label, and often a scheme registration of the GTIN. National schemes already operating today work this way. One recipe in one can may need several pack variants with country-specific artwork.
The PIM needs country variants of artwork and labels without duplicating the whole product. The ERP prices the deposit as its own line. The shop and marketplace feeds show it per country. Beverage manufacturers planning label changes for the harmonised PPWR material labels should combine both projects. Two artwork cycles cost twice the agency fees and twice the stock write-downs.
What A PIM Should Do Here, And Where It Stops
A PIM is the natural place for this layer because it already sits between the ERP, the DAM, and every outbound channel. The requirements are concrete. It needs custom entities for packaging variants, roles, claims, and country rules. It needs relations with validity dates, completeness rules per market and channel, export validation that can block a feed, and workflows for supplier evidence with review dates.
AtroPIM covers the packaging side with its PPWR module, and its configurable data model lets teams add a claims entity or a producer-per-country table without custom code. Any PIM with custom entities, relations, and export validation can do similar work. The data model decides the result more than the vendor does.
A PIM does not decide who the producer is in Italy, whether a claim counts as generic or whether an item is packaging at all. Lawyers and compliance teams make those calls. The PIM records the decision, links the evidence, and makes sure every channel uses the same answer.
Signals To Watch Before Year-End
- Environmental Omnibus talks. Watch whether the authorised representative suspension or the German ten-tonne threshold gets adopted. Either one changes the per-country cost of staying in small markets.
- Implementing acts. The harmonised labelling act drives artwork changes. Don't finalise label redesigns on draft pictograms.
- Enforcement tone. SMEunited is asking for an "advice first, sanction later" approach. Whether national authorities follow it varies by country and is still unknown.
- Circular Economy Act. It may simplify EPR across member states, but it won't help with this year's registrations.