Why Supplier Collaboration is the Real PPWR Challenge

• PPWR compliance depends less on understanding the regulation and more on controlling supplier data that sits outside the organization.
• Supplier readiness does not reduce legal responsibility – missing or weak data remains a compliance risk for the company placing packaging on the EU market.
• Structured supplier collaboration is no longer a “nice to have”, but a core compliance capability under PPWR.
• osapiens helps companies regain control over PPWR supplier data with structured workflows, clear ownership, and full risk visibility.

PPWR compliance rarely fails because companies misunderstand the regulation. While the Packaging and Packaging Waste Regulation is complex, most organizations have already invested significant effort in interpreting its objectives, scope, and role-based obligations. What proves far more challenging in practice is not the regulation itself, but the data required to demonstrate compliance. That data is often incomplete, inconsistent, or controlled by parties outside the organization. Material composition, substance information, test results, and detailed packaging specifications frequently sit with suppliers, converters, or upstream manufacturers rather than with the company placing packaging on the EU market.

The PPWR makes this dependency explicit. It establishes clear legal responsibility for manufacturers, importers, and distributors, while at the same time requiring evidence that can only be obtained through third parties. Understanding one’s role under PPWR is therefore only the first step. The decisive factor is whether an organization can reliably access, verify, and maintain the supplier data needed to support that role. In this context, supplier collaboration emerges as one of the most critical – and still widely underestimated – risk factors under PPWR.

Why PPWR raises supplier-related risks

The PPWR significantly raises expectations around data quality, consistency, and proof. High-level confirmations or generic material statements that may have been sufficient in the past no longer meet regulatory expectations. Companies must be able to demonstrate, for each packaging type, how requirements such as chemical safety, recyclability, and minimization are fulfilled, supported by verifiable and up-to-date information.

This creates friction at several points in the supply chain. Many suppliers may not yet be familiar with PPWR requirements or interpret them differently based on national or sector-specific experience. Others may struggle to respond to repeated data requests, especially when those requests are unstructured or change over time. In global supply chains, additional challenges arise, including language barriers, long response times, and documentation formats that do not align with EU expectations.

Crucially, PPWR does not adjust obligations based on supplier readiness. Whether a supplier is slow, unresponsive, or unaware of the regulation does not change the legal position of the company placing packaging on the EU market. From a compliance perspective, missing or weak supplier data remains a risk that must be managed, not excused.

The main supplier risks under PPWR

In practice, supplier-related PPWR risks tend to fall into three recurring categories.

• Data gaps, where material details, certificates, or substance information are missing or outdated
• Inconsistent information, especially when similar materials are sourced from different suppliers
• Limited supplier responsiveness, caused by overload, unclear expectations, or low regulatory awareness

These risks directly affect a company’s ability to build technical documentation, issue Declarations of Conformity, and respond to market surveillance authorities. Without a clear view of which suppliers provide reliable data and where critical gaps exist, compliance efforts remain fragile. This is where structured Supplier Risk Management becomes essential. Companies need to understand which suppliers are linked to high-risk materials, which packaging items carry the greatest compliance exposure, and where remediation efforts should be prioritized.

Why global sourcing increases blind spots

Global sourcing amplifies these challenges. Suppliers outside the EU may have limited exposure to European packaging regulations and may not maintain documentation aligned with EU standards. Test reports may be missing or based on non-EU methodologies, substance declarations may be incomplete, and material compositions may lack the granularity required for PPWR assessments.

Under PPWR, these blind spots are no longer acceptable. Companies must proactively identify high-risk suppliers and establish clear expectations around data quality, timelines, and supporting evidence. This requires more than occasional follow-ups. It demands a systematic approach to supplier engagement that recognizes regulatory compliance as a shared, ongoing responsibility across the value chain. Strong Supplier Relationship Management helps move interactions towards stable processes.

Reducing supplier risk under PPWR

A structured approach helps companies regain control:

1. Identify suppliers linked to critical materials or high-risk packaging
2. Define clear, standardized data requirements
3. Track supplier responses and data gaps
4. Prioritize remediation where compliance risk is highest
5. Embed supplier collaboration into regular processes

This shift benefits both sides. Suppliers who understand what is expected and can rely on consistent workflows are more likely to provide accurate and timely information. For companies, structured Supplier Relationship Management reduces friction, improves data reliability, and creates a more stable foundation for compliance. Over time, this shifts supplier management from reactive escalation to proactive risk control.

How osapiens supports supplier risk management under PPWR

Trusted by over 2200 companies worldwide, the osapiens HUB supports companies in managing supplier-related PPWR risks by combining Supplier Risk Management and Supplier Relationship Management – as well as of course PPWR compliance – within an integrated platform. It enables structured data collection, transparent workflows, and continuous tracking of supplier responses and data quality across global supply chains.

By creating clarity around responsibilities and data status, companies can reduce supplier-related risk, improve collaboration, and build a more robust foundation for PPWR compliance. This structured approach is particularly critical as organizations look beyond initial enforcement dates toward the more demanding requirements that will apply by 2030.

Want to explore supplier-related PPWR risks in more depth? Download the osapiens PPWR Readiness Guide for practical guidance on building supplier collaboration and data transparency that scale with regulatory complexity.