If PPWR forces us to rethink packaging anyway, why stop at compliance? Peter Stael, owner and partner at Across-Consult, explores the possibilities of going beyond the legal minimum and giving every pack its own traceable identity.
From around 12th August 2026, I suddenly found myself overwhelmed by LinkedIn posts and requests from customers for documentation. The Packaging and Packaging Waste Regulation had commenced to roll out! Apparently, the shock was severe.
I have even given webinars under the title ‘PPWR without panic!’, but, to be honest, even I started to feel a little stressed out myself. Had I missed something?
I have followed the discussions for years. I have read all the draft versions. However complex formal legal texts can sometimes be, I was, at times, pleasantly surprised by some of the choices the legislators had made.
But now suddenly everything was: ‘Compliance! Compliance!’ Declarations here, declarations there. I was overwhelmed and, indeed, somewhat surprised.
From 12th August onwards, something that had been the subject of discussions, webinars and preparations for years had suddenly come into effect. And so companies are busy.
What do we have to do? Which packaging is compliant? Which documentation do we need? Who is considered the producer under PPWR? Which information must be made available and shared with whom? What does recyclability mean for our current structures?
Of course, they are all necessary questions.
Compliance is, in and of itself, of course, necessary. And to some extent I had expected these kinds of questions from the industry. But, to be honest, I had expected a very different discussion.
The objectives behind the Regulation are considerably broader than correctly completing compliance documentation. The European Commission refers, among other things, to reducing packaging and packaging waste, reducing the use of primary raw materials, and transitioning towards a circular, sustainable and competitive economy. It also explicitly talks about stimulating innovation in new circular business models (for example, already mentioned in EU 2025/40, point 2, page 1).
I had been prepared for questions such as: Now that we have to reconsider our packaging anyway, where do we actually want to go? Which material structure fits our vision for the future? And if we cannot get there, why not? Now that food waste (EU 2025/40, point 5, page 2) is also mentioned as part of the considerations — one of my little moments of joy when reading the final drafts — shouldn’t we be looking for broader alignment across the entire organisation?
Once we know what PPWR requires from us, it is easy to create a checklist. We determine what is necessary, adapt our packaging or procedures, collect the required documentation and eventually tick the box:
Compliant!
Fine.
But I also started wondering whether this was really the intention. Aren’t we running the risk of becoming satisfied too quickly with the ‘right’ answer?
Is this really all we want to get out of this enormous change in the European packaging market?
When sufficient becomes the answer
The first time I started to realise that there were different views on how to work out the PPWR’s requirements was when I attended a smart packaging congress in Amsterdam. As a keynote speaker, I naturally absorbed the presentations of the other speakers as well. Some good and interesting tools were discussed, but something stayed with me that did not feel quite right.
I noticed that the tools were mainly presented as a way of digitising data. And what I mean by that is essentially the paper documentation that we in the industry keep dragging along behind us. These tools could now digitise those documents.
Is that wrong?
No, certainly not.
It is good that this information becomes more accessible and that this creates greater transparency in the market. I am completely in favour of that.
But still.
Earlier this year, there was news that rat poison had been found in a glass jar of baby food on supermarket shelves in Austria, the Czech Republic and Slovakia. It later turned out to have been the act of a criminal attempting to extort money from supermarkets.
Fortunately, this ended without further problems. Investigations showed that the manufacturer had followed all its procedures correctly. The conclusion in the press was therefore: consumers, listen carefully — when opening the jar for the first time, we should hear the familiar ‘pop’. That is the safety mechanism.
The system works. The conclusion is correct.
But then we find ourselves at a congress with all kinds of prominent speakers and well-thought-out innovations. And, in reality, much of what we are discussing is the digitisation of a paper documentation flow that we already had.
That is a good thing, but there is also something contradictory about it. Are we going through this enormous PPWR movement only to use an important part of these new possibilities mainly to organise the existing status quo more efficiently and transparently?
OK, more transparency. But where is the challenge in developing a safer jar? Where is the discussion about the possibilities created by PPWR to start a real dialogue about where we want to go? Towards solutions that are safer, more hygienic, more efficient and, above all, environmentally more friendly.
Suppose we were to start again today with the question:
What could packaging tell us about the safety and authenticity of this baby food product?
Would we once again end up exclusively with that ‘pop’?
Perhaps.
But with all the technological innovations available to us, perhaps not.
If every individual pack could have a digital identity, other possibilities would emerge. Is this product authentic? Did this specific jar actually come from the manufacturer named on the label? Is this particular item part of a recall? Can the consumer retrieve relevant information that genuinely belongs to this specific product? Can the manufacturer still link relevant information to this exact pack after it has left the factory?
Again, my conclusion is not that every jar of baby food should tomorrow be equipped with a chip, tag or unique digital solution.
My conclusion is much simpler:
We should ask the question!
And this is exactly where I see a responsibility for our own food and packaging industries. We do not have to wait for PPWR to tell us what the next function of packaging should be. The legislator has set something in motion. But what the legislator has provided are the guardrails within which we have to operate.
And that is good.
We, the food and packaging industries, have to demonstrate that we comply with those guardrails.
But… guardrails are not the road itself.
We have to build that road ourselves. And how we build it is something we have to determine ourselves. The legislator gives us that space. But what we do on that road is up to us.
We can pick up that challenge ourselves. We can pave the road.
Perhaps that was my 12th August problem.
Regulation has to set boundaries. A regulator must ultimately be able to say: this is mandatory and this is sufficient. Otherwise, a company can never know whether it is compliant.
But the word sufficient has an interesting effect.
Once an authority makes clear what is sufficient, a perfectly rational follow-up question arises for a company:
If this is sufficient, why should we do more?
And then something subtle can happen.
Sufficient for compliance quietly becomes sufficient for us.
The legal minimum no longer merely becomes the answer to the compliance question; it also threatens to become the boundary of our thinking.
That is not necessarily the regulator’s fault. Nor is it strange behaviour on the part of companies. Both are, in fact, doing exactly what is expected of them.
But the result can be that regulation intended to support a fundamental change in packaging is reduced, in daily practice, to the question of how we can meet the new requirements with as little change as possible.
A missed opportunity for our industry?
Batch level is sufficient. What happens next?
A recent clarification regarding PPWR nicely illustrates how this mechanism can work.
Under Article 15(5), packaging must be identifiable by means of a type, batch or serial number, or another identifying element. In its PPWR FAQ, the European Commission has also clarified that this does not mean that every individual packaging unit needs to have its own identification. Identification at the permitted level is sufficient. (See also: EU Commission, PPWR, FAQ, point 8, page 37.)
Again, there is nothing inherently wrong with this. A regulator needs to provide clarity. A producer needs to know what is expected. From a compliance perspective, the question has been answered.
But from the perspective I have described above, this is where it becomes interesting.
Suppose we indeed answer the compliance question with ‘identification at batch level’.
What happens next?
We can say: OK, we comply. And then move on to business as usual.
But we, as an industry, with all the knowledge we have, can also ask another question:
What could become possible if every individual pack had its own identity?
Then we would no longer be talking only about the identity of a production batch. We would be talking about identity at an individual level: every bottle, every jar, every bag.
In principle, we could create a relationship with that one specific pack.
And that changes the discussion.
Individually identified packaging can create possibilities for much more precise traceability, anti-counterfeiting, consumer interaction, return and reuse systems, recycling information, freshness indicators and entirely new services that we have hardly developed yet.
Of course, not every type of package needs this. Not every business case will justify the additional cost. And I am certainly not arguing for a legal requirement to individually identify every yoghurt cup, snack bag or cardboard box tomorrow.
But my question is:
Why should we automatically allow the question of what is legally sufficient to determine what is technologically, organisationally or commercially desirable?
Does sufficient too easily become the end of our thinking?
The road within the given guardrails is ours.
What problem could packaging solve?
This brings us, I believe, to a much more interesting consequence of PPWR.
As an industry, we are quite good at answering questions formulated for us by somebody else.
Innovation does not begin with a question for which the correct answer can already be found in a regulation, guidance document or FAQ.
Innovation begins with a question to which we do not yet know the answer.
Could we equip every tray of fresh chicken with a time-temperature indicator that provides a good proxy for what has happened throughout the cold chain to this specific tray of chicken?
Food waste is supposed to be taken into consideration under PPWR as well. And who still has the knowledge to determine whether chicken is good to eat? My 84-year-old mother still dares to look at it and smell it. My 40-year-old daughter throws the chicken away when the date is no longer right. I know retailers that already throw away trays of chicken one day before the expiry date: they will not sell anymore anyway.
From experience built up in my own practice, I know that the potential reduction in waste can be substantial. In a study on minced meat, Keep-it found that, provided the cold chain was properly maintained, the product had an average 2.6 days of additional shelf life when using the indicator.
The technology was subsequently introduced for fresh chicken and other products, with REMA 1000 stating an ambition to halve food waste on products using the indicator. In addition, during a meeting I attended with an EU-based retailer, category management explained that their poultry had a general shelf life of 7 days, but that one of those days was effectively lost because the chicken was taken off the shelves early, as consumers would no longer buy it.
Doesn’t it then become worthwhile to look at the individual package? To monitor it throughout the entire chain?
What do we not know today about our supply chain? Which problems have we accepted as normal for years? Where do we lose information once the product leaves our factory? What would a consumer genuinely want to know? Which information could actually improve recycling? What could individual traceability make possible that batch traceability cannot?
And, from a societal perspective, perhaps even more fundamentally:
What problem could packaging solve that we have never considered a packaging problem?
This would change the character of PPWR.
Not in a legal sense. The obligations remain exactly what they are.
But it would change the way we deal with them.
PPWR would no longer only be something we respond to. It would become a reason to ask better questions ourselves. It would become a reason to start talking to each other, to reassess the entire product and the entire supply chain, and to make joint choices about how to optimise them.
Is the packaging easy to empty? Was this tray of meat in our refrigerator opened two days ago or four? Does this particular piece of chocolate belong to the products that actually need to be recalled? Did I or did I not hear a ‘pop’ when I opened this jar?
And then the organisation has to start talking
And then it becomes fun — and fascinatingly complicated!
A compliance question can relatively easily be divided among disciplines.
Legal interprets the regulation. QA collects documentation. Procurement requests declarations from suppliers. Packaging adjusts specifications. Operations implements what is required.
Every discipline does its job: the checklist turns green.
But try answering this question within the same organisation:
Where do we actually want to go with our packaging?
Then that division no longer works.
Because who can actually answer that question?
Packaging cannot do it alone. Packaging needs to know what Marketing wants to be able to communicate in the future. Marketing needs to understand what materials and technology can actually do. QA should not only indicate which document is required, but also which risk actually needs to be controlled. Operations needs to explain what a new solution means for production. Procurement needs to understand why the cheapest solution within the current specification may not be the best solution for the years ahead.
And there still needs to be a sound, healthy business case. So, yes, we also need to talk to the consumer.
And when packaging also becomes an information carrier, IT and data specialists join the discussion.
So we should not only read the regulation.
We need to listen to each other.
What do the different disciplines expect from the packaging? Where do those expectations clash? Where is there dissatisfaction with the current solution? Where does one discipline accept a limitation that another discipline experiences as a problem? And where are opportunities being missed because every discipline looks only at its own part of the packaging?
Suddenly, a PPWR question is no longer a question for one discipline.
It becomes an organisational question.
Packaging becomes a fundamental pivot point within the organisation. Every part of the company has an influence on it. Packaging becomes a mirror of the organisation — and that is how the organisation presents itself to the outside world.
Packaging therefore does more than mirror the organisation. It also carries the consequences of the choices and actions made within that organisation further down the chain.
And that makes responsibility visible.
The individual employee who did not take sufficient responsibility for washing their hands before placing fresh chicken in the tray has an effect on my wife and children when they open the refrigerator door.
That responsibility travels all the way through the chain.
It becomes visible, traceable and, ultimately, manageable.
Packaging therefore eventually even acquires an ethical dimension.
Perhaps that was the discussion I had been waiting for on the 12th of August.
Better questions can lead to better compliance
And this creates an interesting feedback loop:
Looking beyond the minimum requirement forces us to think more carefully about what we actually want packaging to achieve.
Once we take that question seriously, materials, product, production, regulation, data, market, consumer and future all need to be considered together.
That leads to better thought-out packaging. And that can generate innovation.
But it will also produce something that may at first sound contradictory: better compliance.
Because when compliance is treated primarily as a separate assignment, there is always a risk that every discipline simply deals with its own box.
And in the end, the whole formally complies with what is required.
But when we first jointly investigate what we want our packaging to achieve, compliance automatically becomes part of that discussion.
Which material choice do we make? And above all: why?
Which information do we want to have available? And again: why?
What role should packaging play in traceability? What do we want to achieve with reuse? Which claims do we want to be able to make? What consequences do these choices have for our legal responsibilities?
Compliance is then no longer added afterwards to a packaging decision that has already been made elsewhere.
It becomes part of the question of what that packaging should actually be and what it should do.
Compliance therefore becomes the outcome of a considered packaging strategy rather than primarily a box-ticking exercise.
By thinking beyond compliance, we can ultimately become better at compliance.
Not because we follow more rules than necessary.
But because we better understand how the rules relate to the choices we make.
And that brings me back to my original surprise.
The sudden wave of compliance questions since 12 August is understandable.
Companies need to act. Responsibilities need to be clear. Documentation needs to be available. Packaging needs to be assessed.
That work needs to be done.
But at the same time, PPWR does something that happens far less often: it can help almost an entire industry to look at packaging again.
Listening to today’s reality can create new insights. We often listen within the context of our own department. Within our own silo.
But by also listening to the reality experienced by other departments, we put our ear to a broader reality — in this case, the reality of the organisation as a whole.
And by doing that, perhaps we can hear more clearly what that same reality may have been trying to tell us all along.
We do not get such a moment very often.
So I would not want to end the discussion about PPWR compliance with only the question:
How do we make today’s packaging PPWR-compliant?
But also with: Are we really using PPWR to shape the packaging of the future — or mainly to make today’s packaging compliant?
Which road we choose within the given boundaries, where we want to go and which possibilities we want to develop along the way are ultimately our own responsibility.
The regulator has placed the guardrails.
It is up to our food and packaging industries to decide how far we want to go within that space.
If you liked this story, you might also enjoy:
The ultimate guide to packaging innovation in 2026
Packaging and Packaging Waste Regulation: what to know in 2026
Everything you need to know about global packaging sustainability regulation
No comments yet