EU PPWR Compliance Steps for Businesses: Change Control

A supplier changes a tray’s coating. A buyer picks a lighter box. A design team changes a bottle’s shape. Each choice can affect the evidence behind a packaging review.

A business needs to track what changed and decide what to check again. It also needs to know which version is in use.

Our EU PPWR compliance steps for businesses guide covers the first assessments. This article builds on it with a process for changes to packaging sold in the EU market.

Why packaging changes need a compliance review

The EU packaging and packaging waste requirements cover the full life of packaging. They support a circular economy that keeps resources in use and cuts waste.

The Packaging and Packaging Waste Regulation (PPWR) generally began to apply on 12 August 2026. Some requirements take effect later. Check the dates and scope to see which requirements apply. The European Commission’s overview provides useful background.

Article 15 says manufacturers must consider changes in packaging design and other traits.

They must keep series production in line with the requirements.

An earlier approval has limits. It covers a set version, use and body of evidence. A change may mean that some of that evidence needs a fresh review.

Which packaging changes should trigger a review?

Route proposed changes to a named reviewer before staff place an order or approve a new design. The reviewer can then decide what needs checking.

Ask suppliers to flag changes before they ship the new version. Make this part of the buying process so news from the supply chain reaches the right staff.

These are suggested review triggers. The scope of each review depends on the change and the requirements that apply.

A repeatable workflow for reviewing packaging changes

Take a hypothetical example: a food brand’s supplier wants to change the coating on a paper tray. Four packaged products use the tray.

The tray looks the same, but the brand needs to check whether its evidence still covers the new coating.

Record the proposed change and affected products

Open a change request and record what you will change, why you need it, and when the supplier plans to introduce it.

Link all four products to the request and name the supplier, markets and person in charge of the review.

Keep the old and new versions apart, and do not replace approved packaging information while the new version is still under review.

Decide which requirements need reassessment

Ask a qualified reviewer to check the change against relevant PPWR requirements. For the tray, this may mean a fresh look at substance limits and food-contact requirements.

State which assessments need to be repeated. If old evidence still applies, record why it covers the new version.

For sales in several EU member states, also check whether the change affects local reporting data or other duties.

Review evidence and record the decision

Ask for the evidence needed to close each gap and check that files cover the right coating, use and version.

Link the files to the change request and the relevant conformity assessments. Record who checked them, when and what they found.

Manufacturers must prepare technical documentation and draw up EU declarations of conformity once the required assessment shows compliance. Check which records need an update. See Regulation (EU) 2025/40 for the full duties.

Use clear outcomes: approved, rejected or more evidence needed. Keep open questions visible.

Introduce the approved version and preserve its history

Record the date the approved version takes effect and tell buyers and production staff which version to use.

For the tray, note the first relevant batch with the new coating and keep the old files and decision for reference.

An audit ready process lets staff trace the change, evidence, reviewer and date of use.

Manage packaging changes with Baserow’s PPWR template

The Baserow PPWR compliance template gives teams a ready-made starting point. It connects products, packaging units, components, suppliers and evidence in one workspace. These links help reviewers find the records behind a packaging decision.

• Start with connected records and review tools

The template includes tables for requirements, documents, assessments and actions. Document records hold files, versions, issue dates, expiry dates and review status. Assessments link packaging units to requirements, evidence and reviewers.

Teams can use the assessment board to follow reviews and the action board to track follow-up work. A document submission form provides a shared route for collecting evidence.

The included portal offers product and packaging pages, a personal action list and a review form. This gives staff a practical way to find their work and record decisions.

• Use the included compliance automations

The template includes automations that create assessments for new packaging units, open corrective actions after failed assessments and flag documents 60 days before expiry.

Review these workflows when setting up your process. The requirements library also needs checking against your packaging, legal role and applicable dates. It provides a starting point for review rather than a legal conclusion.

• Adapt the template for packaging change reviews

For the paper tray example, start by finding the packaging unit, its components and the four products that use it. Check which supplier files support the current coating.

When the supplier proposes a replacement, keep the approved specification available. Add the new evidence with a clear version label and assign a reviewer to check its scope.

To make the change process easier to follow, you could add fields for:

• Change reason: Why the supplier proposes the new coating.
• Affected version: Which specification the request would replace.
• Decision owner: Who coordinates the review and approval.
• Planned introduction: When the new coating is expected to enter use.
• Handover status: Whether purchasing and production have received the decision.

These are suggested additions to the template. Agree on their meaning before the team starts using them.

If the evidence leaves questions open, record an action with an owner and due date. Once the review is complete, record the decision and confirm which version staff should use.

Explore Baserow’s PPWR compliance solution for the wider approach, or start with the template and adapt it to your review process.

Measure whether the review process works

Start with a few measures that reveal where work gets stuck:

• Open evidence gaps: Which requests still lack the proof needed for a decision?
• Overdue reviews: Which tasks have passed their agreed due date?
• Time to decision: How long does a request spend at each review stage?
• Repeat issues: Which suppliers or packaging types lead to the same questions?

Review these measures with procurement, packaging and compliance staff. Use them to improve the process. A fast approval alone does not show that packaging meets the rules.

Frequently asked questions

• Can one review cover several SKUs?

Yes, as an internal process, if the same change affects them. List every linked SKU and check for differences in use, markets or specifications. Record any cases that need a separate decision.

• How should teams handle confidential supplier specifications?

Agree on a secure way to share them. Restrict access to staff who need the files, and confirm that reviewers can obtain enough detail to assess the proposed change.

• Should trial samples follow the same approval process?

Use an internal trial route that records the sample’s purpose and limits on use. A trial label alone does not decide which legal duties apply. Check those duties before use or supply.

• How should old and new packaging stock be tracked?

Give each version its own ID. Record stock and batch details, where relevant, so staff can distinguish them during the changeover. Make the approved switch date clear.

• Who should approve a change that affects several departments?

Name one person to coordinate the review. Assign checks to staff with the right knowledge, then define who can give final approval. Make sure this process reflects the company’s legal responsibilities.

• What happens when a proposed change is rejected?

Record the reason and tell the teams involved. Keep the rejected version and its evidence for reference. If the supplier proposes a fix, link the new request to the earlier decision.

Put your packaging change process into practice

Start with one packaging change and test the full review process. Check that staff can trace the request, evidence, decision and version in use.

Explore Baserow’s PPWR compliance solution to support your EU PPWR workflow. Sign up for Baserow to build a shared process for packaging changes and reviews.