The 2024 amendments to the EU Single-Use Plastics Directive have, in a way, shifted the burden of accountability further upstream in packaging supply chains. For EU retailers, this isn’t just a regulatory adjustment; it’s a prompt—some might say a nudge, others a push—to rethink how packaging origins, compositions, and end-of-life plans are tracked and reported. It’s no longer sufficient to simply engage with direct packaging suppliers and assume due diligence has been done. What these updates demand is visibility, and more than that, structured reporting that national registries can absorb and assess.
At its heart, the updated directive expands producer responsibility for a wider range of single-use plastic packaging. The list of items that fall under extended producer responsibility schemes has grown, as has the expectation for accurate declarations regarding material origins and manufacturing profiles. This isn’t limited to obvious single-use goods like straws or cutlery anymore. Retailers are now tasked with understanding the entire chain of custody for packaging components that may include laminated films, plastic-coated papers, and hybrid materials that weren’t previously in scope. The complexity has increased, and with it, the need for more methodical supplier mapping.
A practical starting point for retailers is to map packaging suppliers according to their International Standard Industrial Classification (ISIC) codes. It sounds simple—and conceptually, it is—but in practice, gathering and verifying these codes across diverse supplier bases can be tedious. For packaging suppliers, ISIC codes such as 1721 (Manufacture of corrugated paperboard and containers of paper and paperboard) or 2220 (Manufacture of plastics products) are common. But suppliers don’t always communicate these codes clearly in documentation. In some cases, they may even be unaware of the specific classifications under which they fall, particularly smaller producers or converters who operate in niche areas.
Retailers might begin by creating a supplier matrix that lists each packaging supplier alongside their confirmed ISIC code, production facility locations, and material types supplied. The matrix should, ideally, be linked to purchase order records, so that packaging declarations can be tied directly to transaction data. This link between commercial documentation and compliance records often proves helpful during regulatory reviews, as it allows retailers to demonstrate that declarations aren’t generated in isolation from actual procurement practices.
Submitting packaging declarations to national registries is the next step. The directive updates emphasize that these declarations should draw on open data sources where possible. For example, packaging producers’ compliance certificates, often lodged in national open-data registries, can serve as primary reference points. Retailers can also look to environmental permit databases or product stewardship scheme participant lists as ways to validate supplier claims. The declarations themselves vary by member state—some require structured XML uploads; others accept CSV files or portal-based form submissions. Regardless of the technical format, the substance remains: the retailer must attest to the packaging’s source, composition, and in some cases, recyclability or reuse potential.
Building a workflow to manage this isn’t trivial. A sensible structure might begin with data collection: procurement teams gather supplier ISIC codes, packaging specs, and relevant certificates. Next comes data validation: compliance teams cross-check this information against national or EU-level open-data registries. After that, the preparation of the actual declaration file, ensuring it meets the technical and substantive requirements of the relevant national registry. Finally, there should be an internal review step—a sign-off process that confirms accuracy before submission. Some companies opt to automate portions of this workflow using compliance management software, though manual oversight is still essential given the reputational and regulatory risks associated with inaccuracies.
It’s worth acknowledging that supplier engagement can, at times, slow progress. Not every supplier is quick to respond to data requests, particularly when the request involves information that, in their view, isn’t strictly necessary for fulfilling a purchase order. Some suppliers may worry that sharing detailed facility or classification data could expose them to competitive risks, even though this isn’t the intent of the directive. Here, communication is key. Retailers might need to explain how the regulatory framework works, why the data is required, and how it will be used (and safeguarded).
There’s also a layer of ambiguity—how deeply must retailers probe their suppliers’ own upstream sources? The directive updates point firmly to direct supplier responsibility, but they leave open, to some degree, the question of how far upstream tracing should go when hybrid materials or outsourced production complicate matters. In practice, many retailers are taking a cautious approach, requesting enough data to cover direct packaging suppliers but stopping short of mapping raw material producers unless required by a specific national implementation rule.
The intersection of these packaging reporting duties with other supply-chain sustainability initiatives should also not be overlooked. Retailers who already report on packaging waste targets, circularity initiatives, or environmental product declarations may be able to harmonize these streams of data, reducing duplication of effort. That said, care must be taken to ensure that data collected for one purpose meets the specific standards and formats required for Single-Use Plastics Directive compliance. A one-size-fits-all data set rarely satisfies multiple regulatory requirements without adjustment.
For EU retailers—and indeed for the entire supply chain that supports them—the updated directive reflects a broader trend: transparency isn’t optional anymore. The reporting rules may continue to evolve, and so too will expectations about how packaging data is gathered, validated, and shared. Preparing for that future begins now, through solid data practices, thoughtful supplier engagement, and workflows that can adapt as the regulatory landscape shifts.