One Packaging Reference, Several Products, Two Suppliers: What Is the Unit of PPWR Conformity?
Is PPWR Conformity Assessed per Product, per SKU or per Packaging?
Per packaging. Regulation (EU) 2025/40 attaches its requirements to the packaging placed on the market, not to the product sold inside it and not to the commercial article number in your ERP. Under Article 39(2), the EU declaration of conformity follows the model in Annex VIII, and that model identifies the specific packaging covered. Fifty products in the same jar share one conformity file; one jar from two factories needs evidence from each factory.
Four companies asked us the same question in the last month, in four different ways. A cosmetics brand with 58 registered products wanted to know whether a jar used by several of them "is charged once or per product". A small brand selling eight products in shared packaging asked whether it had eight files to build or three. A fresh-produce exporter with 800 article numbers and 200 suppliers pointed out that two of its suppliers deliver "the same SKU". A food group reviewing its import sheet asked, simply, whether "Packaging ID" means SKU. Behind all four sits one modelling decision: what is the unit that Regulation (EU) 2025/40 is counting?
Key Facts
- Regulation (EU) 2025/40 applies to all packaging, whatever the material, household as well as commercial and industrial, under Article 2(1).
- Under Article 6(1), all packaging placed on the market shall be recyclable, an obligation that has applied since August 12, 2026, transport packaging included.
- The EU declaration of conformity follows the Annex VIII model and identifies the specific packaging covered, under Article 39(2).
- Under Article 5(4), the 100 mg/kg limit on the sum of lead, cadmium, mercury and hexavalent chromium applies in the packaging or in any packaging component, and concentrations are never added up across components.
- Pallets, pallet wrapping films and straps are transport packaging under Article 3(1)(7) and Article 29(1); road, rail, ship and air containers are excluded from the definition of packaging.
- The five statements above are confirmed by our dated PPWR referential (baseline of September 3, 2026). Every other regulatory statement in this article links the exact provision it is read from, and the section "What does the referential not confirm?" lists the points it does not vouch for.
What Is a Packaging Reference?
A packaging reference is one packaging, defined by its components, the material of each component, its dimensions and its function, placed on the market as such. A product SKU is a commercial article: a product, in a quantity, in a packaging, sold under a code. One packaging reference can serve many product SKUs; one product SKU always uses at least one packaging reference, and often three.
The distinction matters because the regulation is written about the first object and companies keep records about the second. An ERP counts what is sold. Regulation (EU) 2025/40 counts what is placed on the market as packaging, and Article 2(1) makes that scope explicit: all packaging, regardless of material, whether household, commercial or industrial. The 58-product cosmetics brand therefore has as many conformity files as it has distinct jars, caps, cartons and shipping cases, not 58. And "Packaging ID" is the packaging reference; the SKU is one of the products mapped to it.
A reference is also layered. Article 3(1) of Regulation (EU) 2025/40 defines sales packaging, grouped packaging, transport packaging and e-commerce packaging as four categories, and our guide to the packaging levels walks through each of them. The jar is one reference. The twelve-jar carton is a second reference. The pallet, its stretch film and its straps are transport packaging under Article 3(1)(7) and Article 29(1), and each is a reference of its own; road, rail, ship and air containers are excluded from the definition and are not references at all.
Does One Packaging Used for Fifty Products Need Fifty Conformity Files?
No. One packaging reference needs one technical documentation file and one EU declaration of conformity, whatever the number of products sold in it. Under Article 39(2) of Regulation (EU) 2025/40, the declaration identifies the packaging covered, and the products filled into that packaging are not part of that identification.
The condition is that the packaging really is the same. Same components, same materials, same dimensions, same closures, same label stock. The moment one of those changes, the reference changes, and the file has to follow. Two changes are routinely overlooked because they do not change the shape of the pack. The first is the decoration: a different ink system or a different coating changes the substances that Article 5 asks about, so a jar printed with a new ink is, for the purposes of the substance file, a new version of the reference. The second is the label: a paper label and a plastic film label on the same jar are two different component lists, and the recyclability assessment under Article 6 is made on the component list, not on the jar alone. Our article on Article 5 substances of concern details what the substance file contains.
When Two Suppliers Make the Same Packaging, Is It One Reference or Two?
One reference, two sets of evidence. The regulation attaches conformity to the packaging placed on the market, and a jar from factory A and a jar from factory B are two packagings placed on the market, each with its own manufacturing data. The reference can carry one identification, provided the specification is identical; the evidence behind it has to exist for each source separately.
The heavy-metal rule shows why. Article 5(4) of Regulation (EU) 2025/40 limits the sum of lead, cadmium, mercury and hexavalent chromium to 100 mg/kg in the packaging or in any packaging component, and concentrations are never added up across components: the worst component decides. A supplier statement is a statement about that supplier's components. The exporter whose two suppliers deliver "the same SKU" needs the component data from both: a statement from one says nothing about the pigments, adhesives or coatings used by the other. Our article on what counts as supplier evidence explains why a company-wide letter fails that test.
In practice, the difference between two suppliers' output of the same reference is often in the printed layer rather than in the substrate: the ink formulation, the ink film thickness and the colour actually laid down on the press. Production-control tools exist to keep that printed result within one specification from press to press. ColorLoop, developed by Rutherford, controls ink keys and colour on offset presses and converting lines; Veoria, from the same group, builds inline spectral colour measurement for label and packaging presses (DeltaOne). These tools measure colour and ink laydown so that both factories print the reference to the same target; they do not assess anything under Regulation (EU) 2025/40, and they never replace the substance data each supplier has to provide.
The second practical point is the connection itself. If two suppliers feed the same reference, both need a way to attach their document to that reference rather than to an email thread. PPWR Connect exposes an API and an MCP connector, documented on its developers page, through which a packaging supplier can submit a document against a specific packaging reference; the document then waits in the brand's review queue until a person accepts it. Two sources, one reference, two evidence files, one identification.
Which Packaging Level Is the Unit — the Jar, the Carton or the Pallet?
Each level is a unit. A product sold in a jar, packed twelve to a carton, shipped on a wrapped pallet, involves three packaging references: the sales packaging, the grouped packaging and the transport packaging, each assessed on its own components and each carrying its own file. The obligation of Article 6(1) that all packaging placed on the market shall be recyclable has applied since August 12, 2026 to all three.
The transport level is where portfolios are most often under-counted. Pallets, pallet wrapping films and straps are transport packaging under Article 3(1)(7) and Article 29(1) of Regulation (EU) 2025/40, so a company that documents its jars and cartons and forgets its stretch film has an incomplete reference list. Road, rail, ship and air containers, by contrast, are excluded from the definition of packaging and are not references. Our article on transport packaging for importers covers the transport level in detail.
Two further points are read directly from the text rather than vouched by our referential, and are flagged as such. Recital 10 of Regulation (EU) 2025/40 states that sales packaging corresponds to primary packaging, grouped packaging to secondary packaging and transport packaging to tertiary packaging: the commercial vocabulary and the regulatory vocabulary name the same three objects. Article 24(1) sets an empty-space ratio for grouped, transport and e-commerce packaging from January 1, 2030, and does not apply to sales packaging.
How Do You Build a Packaging Reference Model That Survives an Inspection?
A reference model survives an inspection when every declaration can be traced to one identified packaging, and every identified packaging can be traced to its components, its sources and its evidence. Five structures do that work; the table shows what each one holds and which provision it answers.
| Structure | What it holds | What it answers |
|---|---|---|
| Packaging reference | Unique identification, level (sales, grouped, transport, e-commerce), dimensions, function | The unique identification required by the Annex VIII model (Article 39(2)) |
| Component list | Each component, its material, its mass, its separability, its decoration (ink, coating, label stock) | Substances per component (Article 5(4)); recyclability of the packaging (Article 6(1)) |
| Sources | Each supplier manufacturing the reference, with its own document set | Evidence for each packaging actually placed on the market |
| Product mapping | The product SKUs filled into the reference, many to one | Counting, pricing and reporting without duplicating files |
| Versions | A dated version each time a component, a material or a source changes | Which declaration covered which packaging on which date |
Two habits keep the model honest. Name references by what they are, not by what they hold: "50 ml amber glass jar, PP cap, paper label" outlives "night cream jar". Version the reference, never overwrite it: the Annex VII technical documentation behind a declaration describes the packaging as it was when the declaration was drawn up.
What Does the Referential Not Confirm?
Our dated PPWR referential (baseline of September 3, 2026) confirms the five Key Facts above. It returned no match for four statements used in this article, which are therefore read from the linked text and presented as such, not as verified facts.
- The wording of the definitions of sales, grouped, transport and e-commerce packaging in Article 3(1)(5) to (8): the four categories are in the text; the referential vouches for the transport definition's content (pallets, films, straps in; containers out) and not for the other three sentences as phrased here.
- The sentence in recital 10 that aligns sales, grouped and transport packaging with primary, secondary and tertiary packaging.
- The empty-space ratio of Article 24(1) as phrased in this article; the referential records the January 1, 2030 date for Article 24 (or 3 years after the Article 24(2) implementing acts enter into force, whichever is later) and the 50 % value, and did not match the sentence.
- Any statement that Article 15 obliges the manufacturer to draw up the technical documentation and the declaration "per packaging". The per-packaging logic in this article rests on Article 39(2) and the Annex VIII model, which the referential confirms; Article 15 is linked here for reading, and its text is the authority, not this paragraph.
Frequently Asked Questions
Is the unit of PPWR conformity the product or the packaging?
The packaging. The EU declaration of conformity follows the Annex VIII model and identifies the specific packaging covered, under Article 39(2) of Regulation (EU) 2025/40. The product filled into that packaging is not the object of the declaration.
One packaging is used for several products: one file or several?
One file and one declaration for the packaging reference, plus a mapping table listing the products that use it. The file changes when a component, a material, a decoration or a source changes, not when a product is added to the mapping.
Two suppliers deliver the same packaging: one reference or two?
One reference if the specification is identical, with a separate evidence file for each supplier. Under Article 5(4) of Regulation (EU) 2025/40, the substance limit applies in each component, so the component data of each source is needed; a statement from one supplier does not cover the other.
Is a pallet a packaging reference?
Yes. Pallets, pallet wrapping films and straps are transport packaging under Article 3(1)(7) and Article 29(1) of Regulation (EU) 2025/40, and each is a reference with its own file. Road, rail, ship and air containers are excluded from the definition and are not references.
How PPWR Connect Helps
PPWR Connect is built on the packaging reference, not on the product. Each reference carries its level, its component list with materials and decoration, its suppliers and the documents each of them has submitted, and the product SKUs mapped to it; the EU declaration of conformity is generated per reference from that evidence. Suppliers can answer data requests through the supplier hub or submit documents directly through the API and the MCP connector described on the developers page, and every submission waits for a person's acceptance before it counts. To see how many references your product list actually contains, start with our PPWR compliance software or a quick, free PPWR readiness assessment.
Published by
PPWR Connect is published by Rutherford, a European team building production-control software for offset printing and packaging converters (ColorLoop). Veoria, from the same group, develops inline spectral colour measurement systems for label and packaging presses (DeltaOne).