Most brand manufacturers can tell you whether their products are PPWR compliant. Far fewer can tell you who, legally, is on the hook for proving it, because that answer changes per packaging system, per market, and sometimes per supplier relationship on the same pallet. PPWR doesn’t ask “are you compliant.” It asks “which role are you playing right now, and can you prove it.”
In this PIMvendors.com webinar, Stephan Spijkers (Co-Founder, PIMvendors.com) sits down with Hans de Gier (Founder, SyncForce) for the second session in their PPWR series, moving from “what counts as packaging” into the harder question of who manages it, who signs for it, and what that means for your product data. The conversation covers the new packaging system layer most PIM and PLM tools have never had to model, the misconceptions burning the most internal hours right now, and where the regulation is heading once recycled material starts changing compliance values after the fact.
Speakers:
Stephan Spijkers – Co-Founder, PIMvendors.com
Hans de Gier – Founder, SyncForce
The full session is available on the PIMvendors YouTube channel. If your organization has identified PPWR as a risk but hasn’t mapped who carries which obligation across your packaging portfolio, this session addresses the gap most compliance guides skip.
A packaging system is the compliance object, not the SKU. PPWR doesn’t regulate the sales unit or the bill of materials. It regulates the packaging system: the generic technical composition of a unique set of packaging masters, independent of which decor variant sits on top of it. A label redesign doesn’t create a new compliance event. A different polymer or a different cap does. Most PIM and PLM systems were never built to track this layer, because two years ago nobody needed to.
Your role is decided per packaging system, not per company. A single business can be the manufacturer for one item on a pallet and only the importer for another, depending on who specified the materials and who designed the packaging. Levi’s owns the sales packaging it specs and brands. The outer transport carton, sourced from whatever box was available that week, belongs to the supplier in Asia. Two manufacturers, one pallet. Every item in a portfolio needs its role identified individually, not assumed from the company’s general position in the market.
Producer liability now follows market placement, not brand ownership. Under the old packaging waste rules, the brand on the label paid the EPR fee. Under PPWR, the producer is whoever first places the packaging on the market in a given EU member state, which can shift the obligation to a distributor or importer even when the brand’s logo stays the same. A company can be the producer in one country and not in another, for the identical product.
Most PPWR misconceptions point toward over-compliance, not under-compliance. Teams are second-guessing details the regulation doesn’t actually require. Packaging system IDs don’t need to be printed on individual packs; a GTIN link to the system record is sufficient. Compliance data doesn’t need to be exposed to consumers; it’s an internal document held for authorities. And there’s no packaging-level register at all, only a legal-entity producer registration designed to catch companies that aren’t reporting volumes or paying EPR fees, not to track individual packaging systems.
Recycled feedstock breaks static compliance data. Once recycled material enters a production stream, substances of concern can appear that weren’t present in virgin material, and every declaration of conformity tied to that material needs to update. This is the next real challenge for the industry: not a one-time compliance push, but a live data pipeline running from raw material supplier through to recycler. SyncForce is working with GS1, Ardagh, Heineken, and Ahold Delhaize on a federated data model built to carry that.
Signing a declaration of conformity is a personal legal commitment, not a checkbox. The named signatory carries individual responsibility, and a portfolio of 5,000 sales units can sit on top of 300 to 1,000 distinct packaging systems once a company actually maps them. Enforcement and penalties land by member state starting around February 2027, with the regulation’s first compliance deadline already set for August 12, 2026. Manual review buys time. It is not a substitute for a governed process.
👉 Not sure where your packaging data model breaks under PPWR?
Book a call and we’ll help you map your packaging systems against PPWR before the deadline forces the conversation.
