Implementing EUDR and PPWR together

Companies placing products, raw materials, or packaging on the EU market are facing a growing number of new sustainability and compliance requirements within just a few years: CSRD and ESRS reporting, the German Supply Chain Due Diligence Act (LkSG) and the European CSDDD, the EU Taxonomy, the Digital Product Passport – and, with the EU Deforestation Regulation (EUDR) and the EU Packaging and Packaging Waste Regulation (PPWR), two further regulations that will become mandatory in 2026.

In practice, the EUDR and PPWR are increasingly being viewed together – not because their content is identical, but because they target the same companies, the same supply chains, and in some cases, even the same physical materials. This is particularly evident for companies that manufacture, import, or use packaging made of wood, paper, or cardboard: One and the same cardboard box can simultaneously fall under the EUDR because it consists of wood fibers, and under the PPWR because it is packaging.

Companies in the food and beverage industry, furniture and paper manufacturing, packaging production, retail and wholesale, cosmetics, e-commerce, and the consumer goods industry are particularly affected, as are importers bringing raw materials or packaged goods into the EU.

This guide explains what the EUDR and PPWR each regulate, where the requirements overlap and where they differ, what data companies need for both regulations – and why it is worth managing both topics in a shared database rather than in separate, isolated solutions.

What are the EUDR and PPWR?

The EU Deforestation Regulation (EUDR)

The EUDR (Regulation (EU) 2023/1115, amended by Regulation (EU) 2025/2650) requires companies to prove that raw materials and products derived from them were produced legally and without causing deforestation. Seven raw materials are affected: cattle, cocoa, coffee, palm oil, soy, wood, and rubber, as well as numerous products derived from them such as paper, furniture, chocolate, or leather goods.

• Goal: deforestation-free and legal supply chains for the specified raw materials

• Scope: Market participants placing the raw materials or products on the EU market for the first time or exporting them from the EU, as well as downstream traders

• Key requirements: Geolocation of production plots, structured risk assessment, risk mitigation for more than negligible risk, and submission of a Due Diligence Statement (DDS) via the EU information system TRACES

• Deadlines: December 30, 2026, for large and medium-sized enterprises; June 30, 2027, for micro and small enterprises

• Affected companies: virtually all market participants and traders in the supply chains of the seven raw materials; a simplified, one-time declaration applies to micro-enterprises instead of ongoing reporting

The EU Packaging and Packaging Waste Regulation (PPWR)

The PPWR (Regulation (EU) 2025/40) replaces the previous Packaging Directive 94/62/EC with a directly applicable, EU-wide uniform set of rules for packaging. It aims to reduce packaging waste and make packaging circular.

• Goal: reduce packaging waste, increase recyclability and the use of recycled content, and create a uniform EU internal market for packaging

• Scope: almost all economic operators that manufacture, import, distribute, or place packaging on the market – manufacturers, importers, distributors, fulfillment service providers, and brand owners, with no general SME exemption

• Key requirements: Substance restrictions (Art. 5) including a PFAS ban for food-contact packaging, packaging minimization (Art. 10), Declaration of Conformity (DoC) according to Art. 39 and Annex VIII for every package, and technical documentation

• Deadlines: August 12, 2026, for core obligations (Declaration of Conformity, substance requirements, EPR registration); recyclability, recycled content, and reuse targets apply in stages starting in 2030, with further tightening in 2035, 2038, and 2040

• Affected companies: virtually every company that brings packaged goods onto the EU market – regardless of size or industry

EUDR and PPWR in direct comparison

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Which companies are affected by both the EUDR and the PPWR?

The following overview shows which industries typically need to comply with both regulations simultaneously—and why.

Commonalities between EUDR and PPWR

Although the EUDR and PPWR pursue different goals, their operational requirements are highly similar in several respects.

Supplier data

Both regulations require companies to know which supplier provided which material or raw commodity. Without a reliable supplier base, it is impossible to generate either a due diligence statement or a declaration of conformity.

Product data

For the EUDR, every affected product must be linked to a raw material, while for the PPWR, every package must be linked to a packaging type. In both cases, a structured product or item database is a prerequisite.

Material data

The EUDR asks for the origin of the material, while the PPWR focuses on its material composition and recyclability. The material type itself—such as 'corrugated cardboard made from spruce'—is the starting point for data collection in both cases.

Documentation requirements

Both regulations require records to be kept for several years: at least five years for the EUDR, and also five years for the PPWR (ten years for reusable packaging). Consistent document management is therefore mandatory for both areas.

Proof of compliance

Both the due diligence statement and the declaration of conformity must be available for submission to authorities if requested. Both proofs are declaration-based: the company actively confirms compliance with the respective requirements.

Supply chain transparency

Both regulations shift responsibility upstream into the supply chain. Companies must ask their suppliers targeted questions and document the answers—a process that is structurally almost identical for both EUDR- and PPWR-relevant suppliers.

Compliance processes

Both regulations require clearly assigned internal responsibilities, approval processes, and a traceable history of all verification steps—regardless of whether the focus is on a cultivation area or a packaging specification.

Master data as a foundation

Supplier, product, and material master data form the foundation for both regulations. Establishing this master data correctly from the start reduces the effort required for both EUDR and PPWR—as well as for any future regulations that may arise in the coming years.

Differences between EUDR and PPWR

Despite their structural similarities, EUDR and PPWR differ significantly in terms of content.

What data do companies need for both regulations?

Much of the required information for both EUDR and PPWR can be drawn from the same data source—provided the data structure is designed for it from the outset.

The key point: Supplier, product, and location data are required for both regulations and can be captured once and used multiple times. Only the regulation-specific documentation—geocoordinates for EUDR, recycled content for PPWR—needs to be collected separately.

Why isolated solutions for EUDR & PPWR become a problem

Many companies initially address new regulations with ad-hoc solutions: an Excel spreadsheet for EUDR, another for PPWR, and perhaps specialized software for each topic. This approach quickly reaches its limits.

• Excel files: Supplier and product data are maintained manually, versioning drifts, and errors go undetected

• Duplicate data entry: The same supplier and material information is requested separately for EUDR and PPWR—doubling the workload for procurement and suppliers

• Multiple software solutions: Each tool comes with its own user interface, login, and export formats—making integration a project in itself

• Media discontinuities: Data must be manually transferred between systems, which wastes time and creates sources of error

• Lack of transparency: Without a central overview, it is unclear which suppliers or products still have outstanding documentation for which regulation

• Inconsistent data: If a supplier is updated in one system, the old status remains in the other

• High manual effort: Every new supplier request or regulatory audit requires the manual re-compilation of information

• Sources of error: Media discontinuities and manual processes increase the risk of contradictory or incomplete documentation—leading to direct compliance risks

Why companies should manage EUDR and PPWR in a single software solution

A central platform for EUDR and PPWR offers several structural advantages over isolated solutions that go beyond mere convenience.

• A single data foundation: Supplier, product, and material master data exist in one place and are used by both modules

• No duplicate maintenance: Changes to supplier or product data automatically apply to all affected regulations.

• Unified supplier management: A single supplier portal for all requests reduces the workload for both your company and your suppliers.

• Centralized product data: Every product stores its relevant attributes—raw materials, components, and packaging—in one place.

• Centralized documentation: Due diligence and compliance declarations are always accessible and auditable.

• Better collaboration: Procurement, product development, sustainability, and legal teams work from the same data foundation instead of in separate silos.

• Scalability: New suppliers, products, or countries can be integrated without needing to build additional systems.

• Future-proof compliance: A modular data foundation can be expanded to include further ESG topics like CSRD, LkSG/CSDDD, or the Digital Product Passport without starting from scratch.

This platform-based approach—managing EUDR, PPWR, and other ESG modules on a shared data foundation rather than in separate tools—is exactly what the modular cubemos ESG platform offers: supplier and product data are captured once and are available for both EUDR due diligence statements and PPWR compliance declarations.

Checklist: Am I prepared for EUDR and PPWR?

The following questions will help you assess your current level of preparedness.

• Have I checked whether my products contain any of the seven EUDR raw materials (cattle, cocoa, coffee, palm oil, soy, wood, rubber)?

• Do I know whether my company is classified as an operator (first placer on the market) or a trader under the EUDR?

• Have I checked my packaging to see if it falls under the PPWR, regardless of the product being packaged?

• Do I know my role under the PPWR (manufacturer, importer, distributor, fulfillment service provider, brand owner)?

• Are the geolocation coordinates for the production plots available for all EUDR-relevant raw materials?

• Do I have a process in place to submit due diligence statements via the EU information system (TRACES)?

• Have I compiled the necessary data for the compliance declaration according to Art. 39 and Annex VIII of the PPWR for every piece of packaging?

• Have my suppliers been identified and systematically surveyed regarding their origin or material certifications?

• Is there a central supplier and product database that can be used for multiple regulations simultaneously?

• Are responsibilities for EUDR and PPWR clearly defined within the company across procurement, sustainability, and legal departments?

• Have I established a process for retaining supporting documentation for at least five years?

• Am I aware of the deadlines relevant to my company (December 30, 2026/June 30, 2027 for EUDR, August 12, 2026 for PPWR)?

• Have I checked whether my EPR registration for packaging is prepared for all relevant EU countries?

• Is my company prepared to provide proof of recyclability and recycled content quotas starting in 2030?

Frequently Asked Questions about EUDR and PPWR (FAQ)

Are EUDR and PPWR linked?

Legally, they are two independent regulations. However, they overlap in terms of content where packaging is made of wood or paper—in these cases, the same materials are relevant to both EUDR and PPWR.

Does my company have to comply with both regulations?

That depends on your product portfolio. Companies that process one of the seven EUDR commodities and simultaneously place packaging on the market generally have to comply with both regulations.

Which companies are affected by both regulations?

Those most frequently affected include food and beverage manufacturers, paper and packaging producers, furniture manufacturers, as well as wholesalers and retailers with corresponding product ranges.

Which data overlaps between EUDR and PPWR?

Supplier, product, and material master data are required for both regulations. Regulation-specific data, such as geocoordinates (EUDR) or recycled content (PPWR), must be collected in addition.

Do I need two separate software solutions?

Not necessarily. A modular platform that centrally manages supplier and product data can cover both regulations and reduce redundant data entry.

Can I document EUDR and PPWR together?

The due diligence statement (EUDR) and the declaration of conformity (PPWR) are legally separate documents. However, the underlying data can be managed in a single, shared system.

Which departments are involved in the implementation?

Typically procurement, sustainability or ESG departments, product development, legal/compliance, and, in larger companies, IT.

What deadlines apply to the EUDR?

December 30, 2026 for large and medium-sized enterprises, June 30, 2027 for micro and small enterprises, as established by Regulation (EU) 2025/2650.

What are the deadlines for the PPWR?

Core obligations—declaration of conformity, substance requirements, and EPR registration—apply from August 12, 2026. Recyclability and recycled content targets take effect from 2030.

What documentation must companies retain for the EUDR?

Geolocation data, risk assessments, due diligence statements, and associated reference numbers must be kept for at least five years.

What documentation must companies retain for the PPWR?

Technical documentation for the declaration of conformity must be kept for five years, or ten years for reusable packaging.

What happens if I do not submit a due diligence statement?

A product may not be placed on the market without a valid due diligence statement. In addition to regulatory fines, you face civil liability risks toward business partners.

What happens if there is no declaration of conformity?

Packaging without a valid declaration of conformity does not meet PPWR requirements and may no longer be placed on the market as of August 12, 2026.

Does the EUDR also apply to paper and cardboard packaging?

Wood- or paper-based packaging may fall under the EUDR if it falls under the relevant customs tariff codes of the regulation. Certain printed products were excluded from the scope in 2026.

Is there an SME exemption for the PPWR?

No, the PPWR does not provide a general exemption for small and medium-sized enterprises. Almost all economic operators are affected.

Is there an SME relief provision for the EUDR?

Yes. Micro and small enterprises are granted a longer deadline (June 30, 2027) as well as a simplified, one-time due diligence statement.

How are recycled content targets and deforestation-free requirements related?

They are not directly related. However, for paper-based packaging, the same material stream may be subject to both PPWR recycled content targets and EUDR proof-of-origin requirements.

Which authority is responsible for the EUDR in Germany?

The Federal Office for Agriculture and Food (BLE) is the authority responsible for monitoring EUDR compliance in Germany.

Which authority is responsible for the PPWR in Germany?

The market surveillance authorities of the federal states are responsible for monitoring PPWR compliance; the VerpackDG adapts the German Packaging Act to the PPWR.

How can I reduce the implementation effort for both regulations?

The most effective lever is a centralized supplier and product database from which both EUDR and PPWR documentation can be derived, rather than conducting separate surveys for each regulation.

When should I start the implementation?

Since building EUDR-compliant supply chains typically takes 12 to 18 months and the core PPWR obligations take effect as early as August 2026, there is an immediate need for action.

Can I reuse existing supplier data from other ESG processes?

Yes. Supplier data already collected for CSRD, LkSG, or CSDDD can generally be used for EUDR and PPWR processes, provided it is maintained centrally.