Why this matters
Regulation (EU) 2025/40 (PPWR) applies from 12 August 2026 (Art. 71). Two sets of obligations take effect on that date, and they're the focus of this article, Article 5 (substances in packaging, the PFAS ban, heavy metals cap, and minimization of substances of concern) and Article 11 (reusable packaging).
The triggers and data fields below are the minimum you need to fill in for 12 August 2026.
Other obligations, recyclability and recycled content (Art. 6/7, from around 2030) and labelling (Art. 12, from 12 August 2028), phase in later and are out of scope here.
Mandatory field indicator
Mandatory fields are marked with an orange dot at the top of the field, so you can see at a glance what still needs your attention.
How to read this article
Work through it in order.
Section 1, triggers: questions you need to answer first. Until you do, the fields they unlock stay hidden and get skipped.
Section 2, mandatory fields: the answers that need to be valid to declare conformity for 12 August.
1. Answer these triggers first
Answering each of these questions decides whether a related field appears further on.
| Trigger | Level |
|---|---|
| Reusable | Component (the unit level is auto-filled based on component data) |
| Packaging type (GS1 element) | Component |
| Material sub-category | Component |
| Food-contact packaging | Component |
2. Mandatory fields
Packaging identity & declaration (needed to issue the DoC)
| Field | What it captures | Level | PPWR basis | Filled by |
|---|---|---|---|---|
| My role | Manufacturer, importer, or distributor, sets who holds the obligation | SKU/unit | Art. 21 | Simvia user |
| Packaging format | Sales / Grouped / Transport | Unit | Art. 3 (packaging format) | Simvia user |
| Packaging identifier | Used for traceability on the DoC. It's any identification number physically present on the packaging. | Unit | Annex VII | Supplier or Simvia user |
| Packaging description | Plain description of the packaging in the DoC | Unit | Annex VII | Supplier or Simvia user |
| Recyclability status | Only necessary for reusable packaging: recyclable or recyclable at scale | Unit | Requirement (i) of Art. 11 (reusable packaging) | Supplier or Simvia user |
Article 11, reusable packaging (per component and unit)
| Field | What it captures | Level | PPWR basis | Filled by |
|---|---|---|---|---|
| Fulfils all reusable packaging requirements | Whether the reusable component meets the Art. 11 reuse requirements. Yes means evidence documents are required | Component | Art. 11 / Annex VII | Simvia user / supplier |
This field only appears once Reusable = Yes in Section 1.
Article 5, substances (per component)
| Field | What it captures | Level | PPWR basis | Filled by |
|---|---|---|---|---|
| PFAS compliant | Meets the PFAS ban (25 ppb per individual substance, 250 ppb summed, or fluorine below 50 ppm, or organic fluorine below 50 ppm) | Component | Art. 5(5) | Supplier |
| Heavy metals compliant | Sum of Pb + Cd + Hg + Cr(VI) is 100 mg/kg or below | Component | Art. 5(4) | Supplier |
This field only appears once the food-contact packaging trigger has been answered.
3. What you need to do
- Answer the trigger questions first, per component, packaging type, material sub-category, food-contact packaging, and reusable. The rest of the fields appear based on your answers.
- Add your supplier product ID when you onboard. This is your own article number, adding it makes it easy to recognise your products later, and to match them on the packaging request form. This ID carries through to the questionnaire.
- Confirm your role at product level. Confirm your packaging format, packaging ID, and description at unit level. Together, this is what the DoC is issued against.
- Get the material data from your packaging supplier, for every component.
You can set the triggers and add data in bulk using the "add packaging & material data" Excel sheet.
Need help? If a trigger or field doesn't match what you're seeing in your product, reach out to our support team, we're happy to take a look.