How PPWR, EPR, CSRD, and ESPR fit together
Four laws, one underlying problem: without accurate packaging data, you can't comply with any of them. Below you'll find what each law requires, and for whom.
The PPWR (see the PPWR page) is the European foundation: requirements for the design and recyclability of packaging, with a declaration of conformity as proof. EPR is how that gets handled financially in the Netherlands, through the waste management contribution to Verpact (the Dutch packaging waste fund). CSRD is a separate, broader obligation: a sustainability report covering your entire operation, of which packaging is just one part among many. ESPR doesn't affect the packaging itself but the product inside it, and raises the same underlying question: structured, traceable product data.
For most organizations, PPWR is the most immediate issue, while EPR mainly hits your wallet. CSRD is mandatory only for a smaller group of companies, but can still trigger requests for packaging data through the supply chain. ESPR only comes into play once your product category is up, but if your packaging data is already in order by then, you're ahead.
EPR
EPR means that as a producer, importer, or distributor, you pay for the waste processing of your own packaging. In the Netherlands this runs through Verpact (formerly the Afvalfonds Verpakkingen): you pay a waste management contribution, with a rate per material type.
If you place packaging on the market in multiple EU countries, different rules apply per country. Some countries have a threshold before you need to pay, others (such as Germany) don't.
The opportunity: well-recyclable plastic packaging qualifies for a discount through tariff differentiation, potentially up to 60 cents per kilogram. To claim that discount, you need to supply detailed material data: weights, specifications, photos, and proof that the packaging meets the technical criteria. Exactly the kind of detail most organizations don't have readily at hand.
CSRD
CSRD requires companies to report on their impact on people, the environment, and society. The rules have been relaxed recently: from financial year 2027, the obligation only applies to companies with more than 1,000 employees and revenue above 450 million euros. Many companies that previously expected to be in scope now fall outside the obligation, at least for now.
Still, CSRD isn't without consequences for smaller organizations. Companies that must report ask their suppliers for sustainability data through the supply chain, even if those suppliers aren't themselves obligated. Packaging falls under a specific part of the reporting standard (ESRS E5: resource use and circular economy), so if you produce or supply for a large customer, you'll run into this either way.
DPP
The ESPR (Ecodesign for Sustainable Products Regulation) has been in force since mid-2024 and increasingly requires product groups to have a Digital Product Passport: a digital, searchable record covering materials, origin, environmental impact, and information on repair and recycling. This obligation doesn't apply to everything at once, but is phased in per product category, from 2026 to 2030.
This is separate from the data carrier that the PPWR will require for packaging itself, expected from 2028, covering material composition, recycled content, substances of concern, and sorting instructions. Two distinct obligations, then, but with the same core: structured, traceable data you must be able to show.
Why this affects you: if the product you package falls under the ESPR, your packaging data will eventually need a place in that product's Digital Product Passport too. If your packaging data is already in order now, you won't have to redo that step later.
Not sure which legislation applies to you?
Your role, your market, and your customers determine which obligations are relevant. Request a free scan and we'll map it out for you.