From fragmented packaging data to controlled PPWR compliance. Discover how PRIMS brings packaging data, documentation, version control and reporting together to support PPWR compliance across products, suppliers and markets.

How PRIMS supports PPWR compliance

From fragmented packaging data to controlled compliance: how PRIMS supports PPWR requirements across products, suppliers and markets.
By Zoran Gavric
Principal Safety Assessor

The EU Packaging and Packaging Waste Regulation (PPWR) makes packaging an integral part of product compliance. Companies will increasingly need to demonstrate that packaging meets applicable requirements for composition, recyclability, recycled content, minimisation, labelling and traceability. Manufacturers must support conformity through technical documentation and an EU Declaration of Conformity, while importers, distributors and EPR producers have their own verification, registration and reporting obligations.   

From fragmented packaging data to controlled compliance 

Effective PPWR management starts with reliable packaging master data. In PRIMS, each packaging component is managed as a structured Packaging Item with its respective composition information and supporting documentation, and linked to the relevant products.  

The record can include: 

  • component and supplier identification; 
  • material type and composition; 
  • component weight and dimensions; 
  • recycled-content and recyclability information; 
  • relevant recycling or material codes; 
  • technical specifications, declarations and supporting documents; 

This creates one controlled source of information for packaging compliance, rather than separate spreadsheets, email attachments and supplier files. 

Based on the data on number of sold product units per region, PRIMS automatically calculates the required EPR reporting data for distributors and EPR producers and/or their EPR representatives. 

Versioning, change control and traceability

Packaging specifications are not static. A new supplier, material, closure, label, component weight or recycled-content percentage may affect the compliance status of several products and markets. 

PRIMS maintains packaging versions and links each version to the products in which it is used. Historical specifications and documents remain available, making it possible to determine: 

  • which packaging version was used for a product; 
  • when a change was introduced; 
  • which products and markets are affected; 
  • whether the change requires reassessment or updated documentation; 
  • which evidence supported the compliance conclusion at that time. 

This reflects the wider PRIMS approach: packaging components and their documents are managed as connected, version-controlled items with a complete history and audit trail.   

Documentation supported by regulatory expertise 

Based on the structured data and documentation maintained in PRIMS, The Regulatory Company (TRC) can assess the available evidence and support preparation of the PPWR conformity documentation, including the technical file and draft EU Declaration of Conformity for approval by the manufacturer.

Where separately agreed and formally mandated, TRC may also act as the PPWR authorised representative for packaging conformity. In that role, TRC can maintain access to the relevant conformity documentation, respond to competent-authority requests and support communication and corrective actions. The manufacturer remains responsible for ensuring packaging conformity and for the completeness and accuracy of the underlying technical documentation.

PRIMS brings packaging data, documentation, versioning and regulatory expertise together, providing the control and traceability needed to manage PPWR compliance across products, suppliers and markets.

Watch our PRIMS/TRC Clarity Session on PPWR

Want to learn more about what PPWR means in practice? In our PRIMS/TRC Clarity Session “PPWR for cosmetics: What to do NOW. What can wait”, we explore the key requirements and how PRIMS can help manage packaging data, documentation and compliance.

Watch the recording below for practical insights from Zoran Gavrić, the Scientific Director of The Regulatory Company and PRIMS.

recording of webinar PPWR

PPWR webinar: What to do NOW. What can wait.

September 2026

Published: September 2026