Sustainability Perspectives: Navigating PPWR requirements

0:08With this first milestone of August 12th and basically the declarations for Article 5 and 11, it was just a starting point because the data that was asked, it was already a challenge for many companies, I think, but it wasn't very deep into the specs, for example. But what we already saw or the first challenge was here also having the whole data hierarchy of what is my packaging even? How do I identify in my systems what is assigned to primary packaging, secondary, tertiary packaging, right? Like this whole data architecture, I think is a very good starting point for companies to build if they haven't yet to ensure that it works long term.

1:01Hello and welcome to the latest edition of Packaging Europe's Sustainability Perspectives podcast. My name is Elisabeth Skoda, I'll be your host today. So the EU's packaging and waste regulation has become applicable on August 12th, but obviously many challenges and questions still remain there. And in June, software experts Resider have officially launched their dedicated Resider PPWR Navigator, which sets out to be a comprehensive end-to-end compliance solution designed specifically for the PPWR and help clients to navigate that. And today I'm really pleased to welcome back Vivian Loftin to the podcast.

1:45She's a co-founder at Resider and she'll discuss today common challenges around the PPWR and how to overcome them and how companies can get their data in order to deal with any legislation that might also be rolled out later on. So yeah, Vivian, welcome to the podcast. Again, we already spoke last year. So yeah, it's great to have you back. Yeah, thank you, Elizabeth, for having me again. I'm really glad we're now talking about PPWR and the actual execution challenges. So there's a lot to talk about and I'm excited that we get to do this today. Perfect. Yeah, I look forward to a conversation. For anybody who might not be familiar with Resider, could you briefly introduce yourself and the company?

2:29Yeah, happy to do that. So my name is Vivian. I'm one of the founders and managing directors of Resider. We are a German-based software company and we dedicated our lives to packaging sustainability. so we founded a company back in 2020 even before pbwr was there i cannot even believe that because well now i think i use this term 10 times a day at least um but yeah we founded a company actually back then to tackle the whole topic of recyclability and the scattered field across europe and beyond because every country had well their their own methodologies for assessing it we then moved to epr and well then ppwr came and for us it was a logical step to extend our scope to also cover not just recyclability of ppwr but also the other articles so the full on basically end-to-end compliance journey in our software so that's what recider does a software solution for big enterprises and converters who have to deal with these legislations not only in theory but also in practice and yeah we help them to make it manageable and yeah we help them to also make it you know auditable and basically digitally available i'm sure a service that's very much in demand especially these days when we founded the company back in 2020 of course there was already demand for all these these topics and for software to help manage these topics but i think the demand has really increased over the last couple of years with every year it's like more companies are waking up that uh dealing with this on in spreadsheets or manually is not possible anymore i can imagine yes and um in your um day-to-day work what are some of the most common concerns and challenges around the ppwr that companies you work with face yeah so the most common challenges today i think also talking about the first deadline having passed is is not is not anymore about understanding it i think most companies have dealt with it have built up processes have also defined ownership in their companies and their teams like who has to actually deal with this but now it's really about executing all of it and and keeping up to date um i think that most companies have now dealt with okay how do we get our doc signed um if you haven't i think now it's really time but now it's also about getting the whole technical documentation in place, but not only for the articles that have applied now, like Article 5 and 11, but beyond that and getting ready for that because it's very demanding.

5:30And the DOCs, we always say it's just the tip of the iceberg because, well, in the end, that's what auditors will ask for, right? And that's also what you want to have in place. but at the end it's just a PDF documented design. It's just your pledge that, hey, my packaging is compliant. But the real work is, of course, proving that and also documenting all this evidence and making sure that the assessments or the compliance assessments for each packaging are in place and are basically documented. So I think that's actually where the whole challenge starts and where companies have to deal still with the whole data topic.

6:12Because for Article 5, you needed specific data from your suppliers. You needed a lot of documents, basically statements from your suppliers. For example, for the PFAS restrictions. But then, of course, recyclability is coming up soonish. For that, you will need very, very detailed data. So I still think one of the biggest challenges now is getting data in shape to even be able to have all the evidence in place also in the future. Definitely a lot to think about. And yeah, like I mentioned at the beginning, Recider has recently launched its PPWR navigator. Could you tell me broadly, how does it help companies with the challenges?

6:58Yes, of course. So I think you mentioned it in the beginning quite nicely. why did we even call it a navigator? Because I think it's a journey that you have to navigate. And that's also how we built a solution. So there's various parts to it. And it's also modular. So you can use parts of it if, for example, the DOC generation you've covered in some other place. But basically you could use it from start to end to manage or navigate the whole of PPWR. So understanding for your portfolio where you stand, And if you have thousands of SKUs, that's quite important to have this overview and benchmark of, okay, what part of my portfolio do I have all information available already?

7:44Or where am I missing something? Where have I not issued and signed my DOCs? So that's basically a really helpful overview for companies to manage their portfolios, but then also going through each article. So basically there will be a compliance and scope assessment for each article. Does it even apply? Am I food contact, for example? Then maybe I need to look into the PFAS restrictions or not. Then doing the actual compliance assessment, seeing, okay, what are the different rules or criteria I have to comply with? And then at the end of it, getting the results. And if the result is positive, well, you can generate your DOC and your TD.

8:26so basically having also the documentation in place part of that and that's i keep on talking because it's quite a lot it's a very comprehensive solution part of that is also managing the suppliers because well the one thing is the spec data that you need of course to do these assessments but the other part is also get yeah your your evidence behind that for the technical documentation so also linking documents and things like that from your supplies it's really important and um And last but not least, the actual documentation, so the declaration of conformity and the technical documentation, we are providing templates based on industry work that has been done.

9:09But I also checked with legal representatives to ensure that the guidance or templates we provide are bulletproof. But of course, some companies want their own templates. So that's also something we support. But yeah, so you see, it's a lot to navigate. That's also why we called it a navigator. But in the end, it's supposed to be an all-in-one solution. So not just the documents, not just the data. It's basically from data to the final documents, one solution. And obviously, there are a lot of compliance tools hitting the market right now. And what would you say makes Residers' approach different?

9:47Yeah, I think that's the approach that we chose to have it all in one solution embedded. That's not even just for PPWR, but beyond. So our goal was to not have a separate PPWR solution because, well, PPWR is, I think, the main challenge for many companies right now. But it's only one challenge. So we keep on dealing with EPR. So, for example, the EPR declarations. We also just launched our North American collaboration with the APR. So also going beyond Europe, there are recyclability criteria and EPR criteria to fulfill. So I think that's really important to understand that our solution is not to be supposed to be a siloed PPWR solution, but it's embedded in a bigger system.

10:37So companies, especially international companies, can have one solution for many use cases. I think where we come from, we come from recyclability. So the whole system is already structured in a way that it can deal with the complexity also for recyclability criteria that are coming. So the solution is not just the Declaration of Conformity Generation tool, but it's really like guiding you through also the future articles. And I think that's quite important to think ahead and not just have a short term patch for the challenge, but a long term strategy and a long term solution that companies can integrate into their processes and basically cover various use cases with it.

11:23Would you like to talk a bit more in depth about some of the key features of the PPWR Navigator? Of course. I think one key feature is definitely the whole topic of how we handle mass data. Because, I mean, there are companies that only have to work with a handful of SKUs. And for them, maybe our solution doesn't even make sense because, well, they can manage it manually. But we provide an RP, a standard RP also to companies. So it can be basically, or it can tap into their existing systems to get the data into Reciter and also out. So basically, it's quite interesting to see how companies can deal with mass data to generate and do these assessments at scale and not just manually.

12:17In the end, for compliance, you need to ensure that it's really, everything is checked. Because if the input is not valid, of course, you cannot or you shouldn't confirm your compliance. But the system takes away a lot of effort here already, if you have a large number of SKUs. And that's really, really good to see that this is possible. And yeah, I think another key feature is also that we are already offering now a recyclability benchmark for Article 6 recyclability for companies to start preparing. And it's based on the new CEN standards that were published. so in terms of recyclability our customers don't have to wait until 2028 to start then but they can start now to benchmark their portfolio and identify any packaging that is at risk of falling below grade c and in the end yeah risk a market ban so they can identify data gaps they can identify packaging that is red and start redesigning already or building up their data.

13:29And I think that's also a key feature to mention, even if recyclability, well, it seems like there's time, but we offer a solution already today as part of the PPWR navigator. Yes, there always seems less time than you think, I'd imagine. Yeah, maybe one example on time, it was really eye-opening for me, at least. we just recently had an event and we also have one of our customers is from the pharmaceutical industry and you always think well they are exempt they don't have to deal with this but they basically even they started already because they say like their development processes are even longer so for them it seems like they are already late while the rest of the market says like pharmaceutical packaging they have time but they they realize for themselves our development processes are so long that we need to start today as well.

14:24That makes sense, yes. You hinted that August is obviously just the first hurdle with declarations of conformity and article 5. How does a company build a data foundation today that will survive when the recyclability and article 6 secondary legislation will add later? Yeah, I think with this first milestone of August 12 and yeah basically the declarations for article 5 and 11 it was basically just the starting point because the data that was asked um yes it was already a challenge for many companies i think but it wasn't very deep into the specs for example um but what we already saw or the first challenge was here also having the whole data hierarchy of what is my packaging even how do i identify in my systems, what is assigned to primary packaging, secondary, tertiary packaging, right?

15:21Like this whole data architecture, I think is a very good starting point for companies to build if they haven't yet to ensure that it works long-term. So at what level do I even have to issue my DOC, for example? And I think that was a great starting point or is a great starting point for the ones who have dealt with Article 5 and 11 in a different way. And then of course, now starting to understand what, for example, the SEND standards ask for in terms of recyclability criteria would be a next step because this is already super detailed, but it really helps in risk assessment of, okay, are we far from data completeness or what are our data issues?

16:07Is it that we basically only have our data in a bit of an unstructured way or are we really missing a lot of attributes. And I think that's very important to me to highlight. It's not just about getting your suppliers to share the data with you, because I think that's a common critique also along the value chain that the state, yeah, that basically suppliers don't provide enough data. But at the same time, I think that many can also prioritize in a better way what data is even necessary or how in what form do they need it to be able to answer all these questions looking ahead at recyclability epr and so forth and um i mean we have a lot of evidence already what kind of data is being asked or will be asked right so that's not going to be a complete surprise i think but um of course there's a lot of uh work that can also be done today um not just asking the suppliers for more data, but in setting up the system, so they are structured and they basically cover, or they, we can also work with heuristics, right?

17:18And making smart rules. If you're a cosmetics producer, maybe you don't have information about food contact packaging, but that can be a rule to automatically fill out such questions, right? And knowing your portfolio there, I'm sure there are always more rules that can, can be filled. But I think in this whole thing it's clear to say it's a journey you will never start and have 10 missing data fields and the next day they are filled so it's definitely something where we advise our customers to start early start in the structured way and then go step by step and yeah understand that it's an iteration or an iterative process to follow to get this robust data for the future to wrap up our conversation today um it would be one tip you give to companies when it comes to tackling the challenges of the ppwr just nailing it down to one tip is but um for me what is um what i really like in conversations if um if yeah basically market players don't see it as a one-time project if they don't see it as like okay now we're done with august 12th like what next um but they see PPWR as a whole journey.

18:35I think that's one thing for me from a strategic point of view that's very relevant and in that whole strategy and mindset about how to deal with PPWR I also always advise to communicate it internally also as a as an opportunity as a long-term project as something that needs a lot of resources because of the potential impact if you fail that it also has high relevance. And yeah, basically companies don't need to build their own solutions. They don't need to build their own templates for the DOC. They don't need to build everything from scratch themselves. There are solution providers like us. There are many industry associations and initiatives that also build working groups to exchange on best practices on how basically companies can manage it successfully.

19:31And I think participating in that and learning from each other and yeah, working with someone like us also to really manage it and not have lots of spreadsheets and manual work is definitely something I would advise. Yeah. And hopefully we won't get very sick of PPWR or saying and talking about PPWR too soon. maybe some are already sick of it but um yeah i think it's we've now survived august 12th i think that's positive so uh let's look at it in a positive way and and see the opportunities of yeah also achieving of course more sustainable packaging uh through that absolutely yes that's of course the end goal that's very important great um that brings us to the end of our conversation today thank you very much vivian for being here today and for sharing your uh your insights yeah thank you elizabeth always nice to be here thank you very much and if you'd like to hear more from recider they'll also be at packaging europe sustainable packaging summit and obviously they will also discuss ppwr but also a lot of other packaging sustainability topics and yeah the standard packaging summit will again take place in interact in the Netherlands from November 10th till November 12th.

20:51So we look forward to seeing many of you there, hopefully. And yeah, also make sure you subscribe to the podcast on whatever platform you might be listening to it so you don't miss out on any of the latest episodes. Thanks very much. Goodbye.

21:18Thank you.

21:48Thank you.