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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