With less than two weeks to go to the implementation of the new rules, Nico Broerson, CEO of Simvia (formerly Agriplace) sets out a readiness blueprint for produce companies
From 12 August, the PPWR (Packaging and Packaging Waste Regulation) applies to almost every punnet, net, bag, tray, crate and pallet hood placed on the EU market. A June survey by compliance platform Simvia (formerly Agriplace) found that only 35 per cent of food and beverage companies in the EU feel confident about the deadline.
For fresh produce businesses, the remaining two weeks are not about reading the regulation again. They are about building an evidence file that holds up when a retailer or an inspector asks. The obligation follows the market, not the company address. Any grower, packer, importer or exporter placing packaged produce on the EU market falls within scope, so British and other non-EU suppliers are affected through their EU trade.
For most of them the first sign of PPWR will not be an inspector but a customer asking for material composition data at component level. That is a different question from UK packaging EPR or the plastic packaging tax, which ask about weights and volumes rather than what each layer is made of.
Evidence is harder to produce in fresh produce than in almost any other food category. Under the PPWR, you need to know what your packaging is made of, at which level (sales, grouped, transport) and for which product. For many packaged goods the unit is obvious, but fresh produce often sits in a grey area: a box of cucumbers can be sales packaging or grouped packaging, depending on whether the cucumbers can be sold loose. The packaging itself does not always fit neatly into the categories the regulation assumes.
That is why PPWR readiness in this sector is not only a packaging redesign project. It is a data and evidence project.
It also does not all have to be finished by 12 August, and treating the date as an all or nothing cut-off leads to the wrong priorities. Two things have to be true on the day: you know which packaging you are placing on the EU market, and you are not placing anything on it that is prohibited, with PFAS above the limits as the clearest case. The technical file and the declaration of conformity are an obligation from day one, but in practice they are built out and improved over the following weeks.
That splits the work into four steps: two in the two weeks left, and two in the weeks after.
Before 12 August: Build your packaging inventory
A “plastic punnet” is rarely one thing. A strawberry punnet with an absorbent pad and top seal film is three components, possibly three suppliers, each with its own material composition and its own evidence to request. List every packaging format that stays active after 12 August, by SKU, customer and market. Most companies underestimate how many they actually have.
A company does not have to pack anything itself to carry PPWR obligations. Importing packaged products, or selling under your own label, can make you the responsible economic operator, with the accompanying duty to hold a technical file and a declaration of conformity (DoC). Most fresh produce businesses therefore fill several roles at once. Set out a responsibility matrix per packaging family, supplier and market, and name an internal owner of the technical file for every own brand and import flow.
Before 12 August: Ask suppliers for evidence, not reassurance
A standard question such as “are you PPWR compliant?” usually produces a reassuring one-line answer that no auditor accepts. What you need is the full material composition, including films, coatings, inks, adhesives and labels, plus evidence on PFAS and heavy metals, and dated test reports or declarations of conformity tied to the exact format. PFAS deserves priority: food contact packaging that exceeds the PPWR limits cannot be placed on the EU market from 12 August.
Build a supplier tracker: requested, received, reviewed, rejected, missing. Review responses as they come in, rather than waiting for the last supplier to reply. Where evidence for a format is still missing on 12 August, take a decision rather than leaving it open: commission testing, pause the format, or formally accept and escalate the risk. A documented decision is defensible. Silence is not.
After 12 August: Turn documents into a technical file
A folder of supplier PDFs is not compliance. Every packaging family needs a specification linked to the evidence, with a score: red, amber or green. Red where composition or substance evidence is missing, amber where it has been requested but not yet validated, green where scope, evidence and documentation are all confirmed. This is the part that realistically runs past 12 August. Build a prioritised list of open points, with an owner and a date for each, and work down it from red to green. What matters is that the list exists, that someone owns it and that it is shrinking, not that it was empty on the deadline.
After 12 August: Lock in a process
Packaging in fresh produce changes constantly: new season, new origin, new retailer specification, a supplier adjusting film thickness. An inventory that is correct on 12 August can already be incomplete in October. One rule closes that gap: no new format goes live without composition data and a supplier declaration.
Add version control for material or supplier changes, expiry alerts for declarations and test reports, and name an owner so that the next phase of PPWR obligations does not arrive as a surprise.
The realistic goal
No fresh produce business will have solved every PPWR requirement in two weeks, and the deadline does not ask for that. What it asks by 12 August is that you know where your risk sits and that you are not placing prohibited packaging on the market. What the weeks after ask is that the evidence behind it gets organised into something you can hand over, and that new formats stop arriving without data.
Companies that structure the classification and material data properly once find that every following retailer request becomes a lookup, rather than a repeat of the whole exercise. That is the real return on the next month, and it lands after the deadline rather than on it.
Want to know where you stand? Simvia’s PPWR page sets out what the regulation asks for depending on your role in the chain, which data you need per packaging component, and where to start if you are behind: https://www.simvia.com/packaging-ppwr?utm_source=fruitnet&utm_medium=pr&utm_campaign=ppwr
Simvia structures packaging data by SKU, customer, market, packaging level, component and material, and keeps supplier declarations and test evidence linked to the format they apply to, so QA teams can see in one view which packaging is covered and which still needs action. Built for fresh produce, where exceptions are the norm.
