What ESPR and PPWR mean for packaging design, data infrastructure, and the future of compliant, connected products
Global policy shifts, led by the European Union, are fundamentally reshaping the rules of market access for consumer goods. Regulations such as the Ecodesign for Sustainable Products Regulation (ESPR) and the Packaging and Packaging Waste Regulation (PPWR) are moving circularity from a sustainability ambition to a legal requirement embedded in product and packaging design.
Companies now face enforceable obligations:
- Ecodesign performance criteria
- Packaging recyclability thresholds
- Digital traceability infrastructure
- Cross-value-chain data transparency
For Consumer Packaging Goods (CPG) food companies, this is a strategic inflection point. The PPWR becomes applicable from August 2026, while ESPR is already defining product-specific requirements and timelines through 2030. At the same time, a parallel transformation is unfolding. The global shift toward 2D barcodes powered by GS1 Digital Link, item-level traceability, and AI-enabled data platforms is equipping brands with tools to meet these obligations in ways that generate competitive value beyond compliance.
This article decodes the core requirements of PPWR and ESPR, examines how the right technology infrastructure responds to those requirements, and outlines what CPG food companies should be doing now.
PPWR — Packaging Circularity Becomes Law
The PPWR applies to all packaging materials (plastic, paper, glass, metal, wood) and every entity in the packaging lifecycle: manufacturers, brand owners, importers, distributors, and online marketplaces. If you make, fill, import, or sell packaged goods in Europe, you are in scope. This applies equally to non-EU companies.
These are some of key obligations of the PPWR:
Recyclability
By 2030, all packaging must be recyclable, with performance graded from A to C. By 2038, only A and B-grade packaging will remain on the market, creating a fixed transition window for eliminating non-compliant formats.
Recycled content
Plastic packaging, including food-contact formats, must meet minimum post-consumer recycled content thresholds stepping up in 2030, 2035, and 2040.
Waste minimization and bans
Single-use plastic packaging for individual portions of condiments, sauces, and similar food products is banned from 2030.
Packaging design constraints
Packaging must be optimized in structure and volume. One notable requirement includes eliminating excessive empty space in packaging (empty space ratio).
Labelling and transparency
By 2029, reusable packaging will need a dedicated “reusable” label with information (often via QR code) about how to return or refill it.
Substances of concern
Restrictions on hazardous substances, including PFAS in food-contact packaging, take effect from 2026, with further measures under development.
ESPR — From Product Design to Product Data
The ESPR entered into force in July 2024 and sets requirements for durability, reparability, recyclability, and material transparency across virtually all physical goods placed on the EU market. Its centerpiece is the Digital Product Passport (DPP): a standardized, machine-readable record of a product’s material composition, environmental performance, origin, and lifecycle data, accessible via a data carrier (e.g., QR code) on the product or its packaging.
A critical nuance for food companies: foodstuffs are currently excluded from the DPP mandate. However, the food sector is moving ahead voluntarily. A growing number of retailers and manufacturers are adopting the DPP framework as the architecture for product information disclosure, driven by consumer demand for verified, accessible data on ingredients, sourcing, and environmental impact.
Brands building DPP-compatible infrastructure today are simultaneously preparing for potential future regulatory extension and capturing genuine brand trust advantages now.
1. GS1 Digital Link: One Barcode, Multiple Use Cases
For decades, the linear UPC barcode has been the retail standard. By 2027, it will be progressively replaced by 2D barcodes using the GS1 Digital Link standard. The GS1 Sunrise 2027 initiative sets the global deadline for POS systems to accept 2D codes; 80% of scanners are already upgraded. Major retailers including Tesco have begun trials, and companies including P&G and Carrefour have committed publicly to the transition.
The GS1 Digital Link encodes, in a single scannable symbol, a product’s GTIN, batch number, serial number, expiration date, and a structured web link. Where a traditional barcode identifies a product type, a GS1 Digital Link identifies a specific item and connects it to a live, updated data record.
For CPG food companies, this matters directly. The GS1 Digital Link satisfies ESPR’s data carrier requirement for DPP access. It enables the packaging data collection that PPWR’s reporting requires. And it powers consumer engagement – sustainability information, provenance, allergen details – from a single scan.
One code, simultaneously serving regulatory, supply chain, retail, and consumer use cases.
2. Traceability: From Batch to Item, From Farm to Shelf
Traceability has long been part of food safety. What is new is the granularity and verifiability that PPWR and ESPR now demand. They introduce requirements that cannot be met with fragmented data.
Companies must demonstrate:
- Verified recycled content through supply chain documentation
- SKU-level packaging composition
- Data continuity across multiple actors
This requires item or batch-level serialization: a unique, verifiable digital identity assigned to each product unit or batch at manufacture, carried through the supply chain via authenticated data exchanges, and retained in tamper-evident records.
The implications are significant:
- Targeted recalls become more efficient and precise
- Compliance becomes more precisely auditable
- End-of-life data (recycling, reuse) can be captured and validated
3. AI-Powered Platforms: Making Complexity Manageable
A CPG food company may have hundreds of SKUs, dozens of packaging formats, suppliers across multiple geographies, and reporting obligations across several Member States, each with different scheme structures. The data exists, but is distributed across ERP systems, supplier portals, quality management tools, and unstructured documents.
AI-powered platforms, supervised by regulatory experts, are emerging as the integration layer that makes this tractable:
- Data ingestion and harmonization: collecting, aggregating, and validating supplier and operational data against regulatory schemas, flagging compliance gaps.
- Continuous regulatory monitoring: Regulatory frameworks evolve constantly. AI monitors legislative updates, committee discussions, guidance documents, technical specifications, and public consultations to detect changes early. This allows companies to anticipate new obligations instead of discovering them only after they are enacted.
How Inexto Helps CPG Food Companies Stay Ahead
Inexto has built its platform at the intersection of exactly these capabilities: batch or item-serialization, GS1 Digital Link implementation, supply chain data orchestration, and compliance-grade traceability for CPG food.
Inexto generates unique, verifiable identities for every product unit at manufacturing line speed, encoded in GS1-compliant 2D barcodes, DPP-compatible records, food traceability, and consumer engagement simultaneously. The platform connects brands with packaging suppliers and logistics partners through standardised data exchanges, enabling the upstream collection that PPWR recycled content verification and ESPR supply chain obligations require – without mandating system changes from suppliers.
For brands pursuing voluntary DPP initiatives, Inexto provides the data architecture to structure and serve product information records, accessible via GS1 Digital Link from packaging, to consumers, retailers, and transparency platforms.
The brands that move first on this infrastructure are building a durable operational asset: the ability to know, prove, and communicate what is in their products and packaging across their supply chains.
Ready to act before the deadline?
Understand where your packaging and data compliance stands today. Inexto’s experts can assess your PPWR and DPP readiness, and GS1 Digital Link maturity.