PPWR packaging records
Since 12 August 2026, every packaging type placed on the EU market needs a signed EU Declaration of Conformity backed by technical documentation - even when the product needs no Digital Product Passport. Soverio keeps both per packaging type: versioned, retained, and exportable as one bundle when an authority asks.
What the law asks of you now
Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation, has applied since 12 August 2026. Four duties bind every manufacturer today:
- The EU Declaration of Conformity (Article 39, model in Annex VIII), drawn up and signed per packaging type.
- The technical documentation behind it (Annex VII): what the packaging is, its materials and weights, and how each requirement of Articles 5 to 12 that applies today is met.
- Retention: 5 years for single-use packaging, 10 years for reusable packaging, counted from the date the packaging was placed on the market (Article 15).
- Hand-over on request: a national authority can demand the file on reasoned request (Article 15(10)), under the market-surveillance rules of Regulation (EU) 2019/1020. Importers must check that the assessment was done and the technical file exists before they place the packaging on the market (Article 18).
Read the full guide: PPWR is in force - the packaging paperwork you owe since 12 August 2026.
What a packaging record holds
One record per packaging type, in seven sections that follow the regulation's own structure:
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Identity and format
The packaging, who places it on the market, unit weight, units placed per year, food-contact flag.
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Material composition
The declared material breakdown and your design-for-recycling assessment.
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Reusability
Whether the packaging is reusable, the intended rotations and the return system (Article 11).
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Recycled content
Post-consumer and pre-consumer shares and the calculation method (Article 7, binding from 2030 at the earliest, recorded now so the series exists).
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Substances of concern
The PFAS declaration for food-contact packaging, the heavy-metals sum and any listed substances (Article 5).
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Conformity
The Declaration of Conformity data, the assessment module, the signatory, the harmonised standards applied, and the Annex VII technical documentation.
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Record metadata
Version, issue date and issuing organisation, so every change is traceable.
Built for the duties in force, not for a label that does not exist yet
- Readiness check, 34 checks. 26 cover duties binding today; 8 cover duties that start later and are reported separately - design for recycling and recycled content from 2030 (Articles 6 and 7), and the recycled-at-scale grade from 2035 (Article 6(2)(b)). The check tells you what your record evidences and what it does not. It never issues a compliance verdict - that stays your responsibility, and ours is to make it easy to meet.
- Business rules that catch the usual errors: material weights that do not add up, recycled-content arithmetic, the heavy-metals cap of Article 5(4), the PFAS limits for food-contact packaging that apply since 12 August 2026 (Article 5(5)), reuse claims that contradict each other.
- Declaration of Conformity rendered in the Annex VIII structure from the record. It is marked an unsigned draft until you attach the signed PDF, and it fills in nothing the record does not say.
- Evidence vault: the Declaration of Conformity and every Annex VII file live on the record, versioned, with an audit trail.
- Surveillance pack: the whole dossier as one archive for a Regulation (EU) 2019/1020 request - the record, the declaration, the evidence files, the readiness report, and a README that states what the bundle is and what it is not.
- QR code and public link per record. GS1 Digital Link, the carrier standard PPWR labelling is converging on, is supported where your packaging carries a GTIN. The public page shows a consumer-safe subset; the conformity dossier stays in the authority tier.
- Roadmap honesty: the harmonised material-composition label (Article 12) depends on Commission implementing acts that are not yet adopted, and applies 24 months after they enter into force, never before 12 August 2028. We add the label fields the moment the act defines them. We do not guess at them now, because a wrong guess in a permanent record is worse than an absent one.
If your product also needs a passport
Where a product already has a Digital Product Passport under other EU law, the regulation's preamble says that passport should also be used for the packaging information. On Soverio the packaging record and the passport live on the same platform: same identifiers, same access tiers, same audit trail. And where the product needs no passport - the long tail PPWR just created - the packaging record stands alone. It is a conformity record, not a passport, and we never present it as one.
Included in every plan
Packaging records are part of every DPP Platform plan: 3 on Free, 100 on Starter with unlimited documents per record, 2,000 on Professional, unlimited on Enterprise.
Frequently asked questions
Does PPWR require a Digital Product Passport?
No. Packaging alone never triggers a passport. Where your product already has a DPP under other EU law, PPWR's preamble says that passport should also be used for the packaging information.
Is a packaging record a "packaging DPP"?
No. It is a conformity record: your Declaration of Conformity, the Annex VII technical documentation and the evidence behind them, with a public link for the consumer-safe part. We never call it a passport, and nothing in EU law does.
Do I need the harmonised packaging label yet?
No. The label (Article 12) applies 24 months after implementing acts that are not yet adopted, and never before 12 August 2028. We add the label fields when the acts define them.
Who can see a packaging record?
The public page shows a consumer-safe subset. The conformity dossier sits in the authority tier: you hand it over, as one archive, when a market-surveillance authority asks.
What is in the surveillance pack?
The record's data, the Declaration of Conformity as rendered from it plus your signed PDF if attached, every Annex VII evidence file, the readiness report, and a README stating what the bundle is and is not. It is a record export, not a certificate.