PPWR and ESRS E5: Why packaging data is becoming mandatory in CSRD reporting

From August 12, 2026, companies subject to the PPWR (Regulation (EU) 2025/40) must maintain a Declaration of Conformity and technical documentation for every packaging unit placed on the market. At the same time, first-wave companies that fall below the Omnibus I threshold but remain subject to reporting obligations are collecting their ESRS E5 data for the 2026 reporting year. Second-wave companies are preparing their first mandatory report for financial year 2027. In both cases, ESRS E5 requires — where material — exactly the packaging data points that must also be collected under the PPWR: recycled content, recyclability, material composition, weight, and reusability.

Two regulations that were historically developed in isolation are now drawing on the same data foundation. Companies that structure packaging data solely for PPWR compliance, and those that structure it solely for CSRD compliance, are effectively building the same data framework twice — with considerable additional effort and the risk that identical metrics diverge across different reports. This article explains where PPWR and ESRS E5 overlap, which data points can serve double duty, how the Omnibus I simplification of the ESRS affects packaging topics, and how companies can set up both requirements within a single integrated process.

Two regulations, one data model

The PPWR is a product-level regulation with operational proof obligations: for every packaging unit, companies must demonstrate compliance with Articles 5 through 12 — covering substance restrictions, recyclability, recycled content, minimization, labeling, and reusability. The CSRD (Corporate Sustainability Reporting Directive, Directive (EU) 2022/2464), operationalized through the ESRS and most recently amended by the Omnibus I Directive (EU) 2026/470, is by contrast a company-wide reporting obligation. ESRS E5 (Resource Use and Circular Economy) requires disclosures on resource inflows, outflows, and circular economy orientation — explicitly including packaging.

The data points required by both frameworks are structurally identical. The difference lies in how they are used: the PPWR uses the data to demonstrate the conformity of a specific packaging unit to market surveillance authorities. The CSRD uses the same data in aggregated form to present a coherent picture of a company's circular economy strategy in non-financial reporting. For the underlying data itself — material, weight, recycled content, and recyclability per packaging type — this means: collect it carefully once, use it twice.

ESRS E5 after Omnibus: what remains, what is removed

As part of the Omnibus process, EFRAG has published a draft for a substantially streamlined set of ESRS standards. The draft proposes reducing the total number of data points from 1,073 to approximately 320, and cutting the data points in ESRS E5 by 71 percent. The standalone disclosure requirement on financial effects (formerly E5-6) would be eliminated and consolidated into ESRS 2. Sector-specific standards are no longer to be mandatory, but would instead be issued as non-binding guidance only.

What remains central for packaging topics:‍

• ‍Double materiality remains mandatory. Companies for which packaging is a material topic — and this applies to most manufacturing companies and brand owners — must disclose under ESRS E5.‍
• Resource inflows are retained as a disclosure requirement. This includes the weight and share of recycled and reused materials incorporated into products and their packaging.‍
• Resource outflows are retained. This includes information on packaging designed according to circular economy principles — recyclable, reusable, compostable.‍
• Waste disclosure is retained: total quantities of waste generated and their composition by stream and material type.

The timeline: the European Commission published the draft for consultation on May 6, 2026; the final delegated act is expected in autumn 2026, with mandatory application beginning at the earliest from financial year 2027. Wave 1 companies (already subject to reporting) continue to report — in the 2026 reporting year, for financial year 2025, under the "old" ESRS. Wave 2 has been shifted to the 2028 reporting year (financial year 2027), with optional early application for financial year 2026. This means the first mandatory reporting period for Wave 2 companies coincides directly with the first full year of PPWR applicability.

The concrete overlaps between PPWR and ESRS E5

The overlap can be reduced to four main topics. In each case, the PPWR data point is the granular individual proof per packaging unit; the ESRS data point is the aggregated metric at company or portfolio level.

Recycled content

Article 7 of the PPWR requires companies to demonstrate the share of post-consumer recyclate in plastic packaging from 2030 onward, with clearly defined minimum quotas — ranging from 10 to 35 percent depending on packaging category, rising to 65 percent by 2040. The calculation methodology will be specified through delegated acts; the underlying data (recycled content per component, supplier evidence, mass balance) already forms part of the technical documentation under Annex VII from 2026.

ESRS E5 requires, under resource inflows, disclosure of the weight and percentage share of secondary (i.e., recycled or reused) components, intermediates, and materials incorporated into a company's own products and their packaging. The methodology, data sources, and assumptions used must be described. In practice, this means: the same recycled content declared per packaging unit in the declaration of conformity flows into the E5 report as an aggregated portfolio metric. Companies that capture this data point cleanly at SKU level satisfy both requirements simultaneously.

Recyclability and design for recycling

Article 6 of the PPWR requires, from 2030, classification into recyclability classes A, B, or C (minimum 70 percent recyclability); from 2038, only classes A and B will be permitted. The qualitative recyclability assessment is, however, already part of the technical documentation from 2026.

ESRS E5 requires, under resource outflows, disclosure of materials — including packaging — arising from a company's products and services that are designed according to circular economy principles: reusable, repairable, upgradeable, recyclable, or compostable. For recyclable packaging (§36c), weight and share must additionally be disclosed; for the other circular economy principles, a qualitative description is sufficient under §35. The PPWR classification (A–E) can be directly translated into the E5 recyclability metric; a company with 85 percent of its packaging in class A or B is simultaneously reporting the PPWR classification and the quantitative E5 evidence for recyclable packaging.

Packaging minimization

Article 10 of the PPWR requires companies to reduce packaging to the functionally necessary weight and volume. From 2030, the 50 percent empty space rule applies to grouped, transport, and e-commerce packaging (Article 24). The underlying data — packaging weight per production unit, empty space ratio, total packaging volume in tonnes — forms part of the technical documentation from 2026.

ESRS E5 requires, under resource inflows and reporting on targets and measures, information on the total quantity and share of materials used. Packaging weight per unit and absolute packaging volumes are therefore relevant under both frameworks. Companies that measure empty space and material input per SKU deliver both the PPWR individual proof and the E5 aggregate figure.

Reusability and reuse systems

Articles 11 and 12 of the PPWR govern the requirements for reusable packaging as well as — from 2030 — binding reuse quotas for certain transport and sales packaging. Companies must document their reuse systems, demonstrate circulation numbers, and provide evidence of return rates.

ESRS E5 captures, under resource outflows, products and materials designed for reuse — implicitly including packaging. Reuse systems, deposit solutions, and pooling structures thus become both PPWR-relevant and subject to disclosure. For companies with a high proportion of transport packaging (industrial businesses with B2B logistics, plant manufacturers, chemical companies using IBC containers), this data shifts from voluntary sustainability communication to a regulatory obligation — on two levels simultaneously.

PPWR data as the basis for Scope 3 (ESRS E1)

The packaging topic affects not only ESRS E5 but also directly impacts climate reporting under ESRS E1 — in particular Scope 3 emissions. The PPWR applies leverage across several Scope 3 categories of the Greenhouse Gas Protocol:

• Category 1 (Purchased Goods and Services): Packaging material is part of purchased goods. A higher recycled content share significantly reduces emission intensity per kilogram of material (recycled plastics typically have 30–70 percent lower emission factors than virgin plastics). PPWR recycled content quotas therefore translate directly into a Scope 3 reduction — provided the company captures the recycled content per packaging unit and links it to the corresponding emission factors.
• Category 4 (Upstream Transportation and Distribution): Empty space minimization and weight reduction under Article 10 affect freight density and therefore transport-related emissions. Less volume per production unit means more products per truck, fewer trips, fewer emissions.
• Category 5 (Waste Generated in Operations) and 12 (End-of-Life Treatment of Sold Products): Recyclability and reusability affect end-of-life emissions. Packaging classified as recyclable in class A carries a different end-of-life emission factor than packaging classified in class C or D.

Companies that maintain packaging master data at product and bill-of-materials level and link it to emission factors can sharpen their Scope 3 calculations and simultaneously quantify the decarbonization effect of their PPWR implementation. This is particularly relevant for industrial brand owners, whose Scope 3 typically accounts for 70 to 90 percent of total emissions and for whom packaging can represent a significant share of Category 1 depending on the product.

The Digital Product Passport as a connecting element

With the Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781), the Digital Product Passport (DPP) will become mandatory for an increasing number of product categories in the coming years. While packaging regulation is not a direct part of the ESPR, the PPWR provides central data points that are represented in the DPP of the product or its packaging: material composition, substance declarations under Article 5, recyclability, recycled content, and origin documentation.

These data points are simultaneously core building blocks of the ESRS E5 disclosures and — in aggregated form — of ESRS E1. Companies that structure their PPWR data are thereby building the foundation for three parallel requirements: the operative PPWR proof package, ESRS reporting, and — once DPP obligations take effect — product-level transparency for customers, authorities, and recycling actors.

For industrial companies with complex product and packaging portfolios, this integration approach is not a nice-to-have: the alternative is maintaining the same data points in three separate silos — with a correspondingly high risk that they diverge and cannot be explained consistently in the event of an audit or external materiality assessment.

Overlapping timelines 2026 to 2028

The parallel timelines of PPWR and CSRD Omnibus create a phase during which the same data points must be operationally built out and processed for reporting:‍

• ‍2026: First PPWR applicability (August 12). Wave 1 companies report for financial year 2025 in accordance with the existing NFRD requirements; no ESRS reporting obligation yet exists in Germany, as the CSRD has not yet been transposed into national law. Optional early application of the simplified ESRS for financial year 2026 is possible.‍
• 2027: First full year of PPWR applicability. Optional simplified ESRS reporting for Wave 2 companies.‍
• 2028: Mandatory CSRD reporting for Wave 2 (financial year 2027). Harmonized PPWR labeling becomes mandatory. First implementation phase for modulated EPR fees.‍
• 2030: Central PPWR milestones (recyclability classes, recycled content quotas, 50 percent empty space rule). Data points become binding.

For companies reporting under CSRD for the first time in 2028, this means: the packaging data structure required for their first report must be in place by the end of 2026 at the latest — because financial year 2027 begins in January 2027 and data collection must start prospectively. This means the build-out falls directly in the phase when PPWR implementation is already underway.

The most common integration errors

In practice, six recurring errors can be observed that lead to parallel rather than integrated data structures:

• Separate tools for PPWR and CSRD: Packaging data is maintained in an operational compliance solution for the PPWR, while sustainability data is held in a separate ESG platform — with no interface between them. Changes in one system are not automatically reflected in the other.
• Different aggregation levels: PPWR data exists at bill-of-materials level; CSRD data is approximated from financial data. Both figures are plausible, but not consistent.
• Different recycled content definitions: The PPWR works with clear definitions of post-consumer recyclate; ESG reporting frequently uses broader terms ("recycled," "regenerated") that are not equivalent.
• Missing versioning: When a packaging unit or supplier changes, the declaration of conformity is updated, but the annual ESRS metric is not. Inexplicable discrepancies arise during audits.
• Isolated supplier communication: Declarations of conformity are requested for the PPWR, while recyclate and emissions data are separately collected for the CSRD. Suppliers receive multiple uncoordinated requests about the same materials.
• Missing link to Scope 3: The PPWR data foundation is used only for packaging compliance, not for emissions calculations. The climate benefit of PPWR implementation remains invisible in reporting.

What this means for industrial companies now

For companies with their own production, complex supply chains, and sustainability reporting obligations, integrating both requirements into a single data process is the most efficient path. Three approaches have proven effective:

First: bill-of-materials and material level as a shared data source. Every packaging unit is populated with material composition, weight, recycled content, recyclability, reusability, and supplier. From this base structure, both the declaration of conformity per packaging unit and the aggregated E5 metrics are derived..

Second: consolidating supplier requests. Instead of separate requests for PPWR (conformity assessment) and CSRD (sustainability data), a consolidated questionnaire is issued that covers both requirements. Recycled content documentation, material declarations, and emission factors are collected in a single step.

Third: linking to emission factors. Each material is assigned an emission factor that is automatically updated when the material or recycled content share changes. This makes the PPWR data foundation directly applicable as the basis for Scope 3 Category 1 and for product carbon footprints.

Companies that already operate a product carbon footprint, CSRD, or Scope 3 setup should not treat their PPWR implementation as a separate compliance project, but rather as an extension of their existing data structure. The packaging data points will be needed regardless — the only question is whether they are collected once in an integrated way or three times in parallel.

The PPWR transforms packaging from an operational cost factor into a regulatory product attribute. The CSRD turns the same packaging data into a component of non-financial reporting. And while the Omnibus simplification has reduced the scope of ESRS data points, it has not reduced the relevance of packaging data — these remain in ESRS E5 and are becoming more rather than less important as the focus on circular economy intensifies.

For companies that must satisfy both regulations in parallel, the lever lies in a unified data foundation at product and bill-of-materials level. Companies that maintain recycled content, recyclability, weight, and supplier per SKU in a structured way are not only fulfilling their PPWR proof obligations and ESRS E5 disclosures, but simultaneously creating the foundation for more precise Scope 3 calculations and — in the medium term — for the Digital Product Passport.