Defining the Right Packaging Object Before Collecting Data
Short answer: Before collecting packaging data, you need to decide which packaging object is assessed and identified in the EU Declaration of Conformity. The PPWR does not prescribe a GTIN, but a unique identifier for identification and traceability (Art. 15(5), Annex VIII). Whether you use the article number or a separate packaging object, its scope across variants and packaging levels must be defined deliberately, and changes must be versioned traceably.
Which number should appear on your Declaration of Conformity? The question sounds like a small input field. In fact, it involves a decision that shapes effort, traceability and change management across your entire packaging portfolio.
Many companies start with their article list. That is understandable: article numbers and GTINs already exist, departments know them and customers order by them. But the existing article logic does not automatically answer which packaging is being assessed and which packaging levels the documentation covers.
The identifier is the result of a decision
The PPWR requires identifiability: Article 15(5) refers to a type, batch or serial number or another element allowing the packaging to be identified. The EU Declaration of Conformity template in Annex VIII provides for a unique identifier of the packaging and a description that enables traceability. A GTIN is not prescribed there as a mandatory system.
A GTIN can be a suitable reference if the associated packaging is clearly described and its respective state is traceable. It is not, however, automatic proof that all packaging variants and packaging levels of an article are covered. The company must define this scope deliberately.
One article can have several packaging realities
A company sells the same article individually and in a multi-pack configuration. The individual packaging stays the same; the outer carton, filling material and transport configuration differ. The article number alone does not tell you which of these configurations was the subject of an assessment.
Conversely, several articles can use technically identical packaging. If independent master data records are maintained for each, a material correction has to be made several times. The risk of contradictory information grows with every copy. A separate packaging object with traceable article assignments can be more efficient here.
This is not an argument against article-driven systems. Where the assignment is unique and stable, this approach can fit very well. What matters is that the software supports different operational situations and does not confuse the chosen logic with a legal requirement.
The scope must be described explicitly
The decision includes which sales, grouped or transport packaging is covered. A shipping configuration displayed together does not automatically mean that all its components should be the subject of a single Declaration of Conformity. Assessment scope, responsibilities and document assignment must fit together.
The data model should therefore link articles, packaging systems, components, materials, suppliers and evidence in a distinguishable way. Not every connection is a rigid hierarchy: a component can be used in several systems, and one piece of evidence can relate to several components. Reuse, however, is only permissible where the documented scope actually fits.
Only identity makes changes manageable
A supplier replaces a coating. The article number stays the same. Without a separate packaging and change history, the system can give the impression that it is still the same reviewed state.
The case is different when an unchanged packaging is assigned to an additional article. This assignment alone need not trigger a new material review. What still needs checking is whether use and requirements continue to fit – for example with food contact. Identical dimensions alone are not enough.
Article 15(4) requires changes to be taken into account and conformity to be reassessed where it may be affected. For day-to-day operations this means: changes need rules. The system should be able to distinguish between an administrative assignment, a documentary correction and a potentially compliance-relevant change.
The most efficient data collection starts with existing sources
Once the packaging object is clarified, data collection can be organised in a targeted way. Existing material and weight information does not belong in a general questionnaire again. Suppliers should specifically add the information that is missing or whose evidence is insufficient.
A general piece of evidence may be assigned to several components if it actually covers them. It should not be requested anew for each assignment. Nor should missing values be replaced by seemingly precise assumptions. Origin, measurement or calculation basis and review status must remain distinguishable.
This creates, almost as a by-product, an overview that is often missing: which components are reused? Which materials dominate? Where are there variants or dependencies on individual suppliers? These insights do not come from additional questionnaires, but from the right structure for information that is needed anyway.
A data foundation that can be extended
Structured material and weight data can later support EPR evaluations. For reliable volume reporting, however, sales volumes, target markets and the applicable classification must be added. CO₂ calculations additionally require suitable emission factors and a defined calculation methodology. Being future-proof means being able to connect these additions – not promising every evaluation from a handful of master data.
This packaging management perspective defines SUSYCHECK. Packaging and components are structured, suppliers integrated, data gaps made visible and information checked against relevant PPWR requirements. Documents are the result of this process, not a substitute for it.
Before you import a thousand records, test three cases: several articles with the same packaging, one article with several packaging configurations, and a packaging change with an unchanged article number. If your system can represent these cases traceably, you have a sound foundation. Otherwise the import merely multiplies an unresolved model.
Sources
- Regulation (EU) 2025/40 (PPWR), original text – in particular Article 15 and Annexes VII and VIII