PPWR in Focus: Article 5 and Articles 38 & 39 – What Companies Must Implement by August 2026

August 2026 – it is no longer a distant date.

In many of my current projects as an SAP RDP consultant, one thing is becoming crystal clear: the PPWR (Packaging and Packaging Waste Regulation) is still being massively underestimated by many companies.

Specifically, three articles are emerging as the critical pillars:

• Article 5 (Substance restrictions)
• Articles 38 & 39 (Declaration of Conformity & Documentation)

Article 5 – The Gamechanger for Packaging Data

What many people don’t have on their radar yet:

this isn’t just about “a few limit values.” It is about genuine data transparency.

• Focus on Heavy Metals & PFAS
• Companies need to know: What is actually inside my packaging?

This is where it gets interesting:

As requirements differ depending on the scenario:

• Purchasing packaging
  → You need a Declaration of Conformity (an aggregated view).
• Manufacturing packaging yourself
  → You need a detailed chemical composition by mass
  → an approach very similar to REACH

The Reality:
Many companies simply do not have this data in the required depth today.

Crucial from an SAP perspective:
Within the framework of SAP Responsible Design and Production (RDP), SAP plans to deliver functionalities for Article 5 in Q1 2026.

This means the first system-side support for substance transparency and assessment will be available early enough to prepare.

Articles 38 & 39 – No Compliance Without Documentation

This is where “nice to have” quickly turns into a serious audit issue.

• Article 38:
  Creation of a Declaration of Conformity (DoC).
• Article 39:
  Establishment of technical documentation.

And here is the part that is often overlooked:

Retention Obligations

• 5 years for single-use packaging
• 10 years for reusable packaging

This is no longer a task for Excel. This requires structured, audit-proof data management.

SAP Roadmap Insight:
Support for these requirements is currently planned to be provided in the RDP environment in H1 2026.
This leaves companies with a relatively short window between system availability and the regulatory deadline in August 2026.

The Reality in SAP Projects (RDP & S/4HANA)

I am currently seeing the same pattern over and over again:

• Management of substance and material data
• Support for Declarations of Conformity (Outbound)
• Leveraging existing REACH data models
• Integration into existing compliance processes

While SAP S/4HANA Product Compliance and RDP already provide a strong foundation:

• Data is scattered
• Suppliers only provide PDFs
• There is no consistent structure for substance information

And importantly:

• The Declaration of Conformity can be generated directly within the system.

• Archiving is handled via PLM or DMS (whether SAP or a 3rd-party provider).

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#PFAS #HeavyMetals #REACH #EURegulation #Compliance

#SAP #SAPHANA #S4HANA #SAPRDP #ProductCompliance #DigitalCompliance
#SupplyChain #DataDriven #MasterData #RegulatoryCompliance

#PLM #DocumentManagement #DigitalTransformation #SAPConsulting
#ESG #SustainablePackaging #GreenTransformation