The Packaging and Packaging Waste Directive, revised in 2018, has had no shortage of commentary over the past few years. But with the release of the first full year of reporting data through the European Pollutant Release and Transfer Register (E-PRTR) in 2021, the conversation shifted—from theory and regulatory text to data, and what that data actually reveals about the state of packaging waste management across the bloc. For beverage companies especially, the moment has been instructive, sometimes uncomfortably so. The numbers offer not just a compliance snapshot, but a window into the practical gaps between policy ambition and operational reality.
The E-PRTR dataset, while by no means perfect (and really, what large-scale environmental database is?), provides a clearer picture than we’ve had before of the flows of packaging waste linked to producers. One notices immediately the wide variance in how packaging producers are reporting. Some firms have integrated reporting seamlessly into their existing environmental management systems; others, if one reads between the lines, appear to be struggling with the technicalities—underreporting, gaps, inconsistencies in material categories. The differences often have less to do with company size than with preparedness, or maybe just organizational will.
For beverage companies, the stakes are rising. Packaging, once regarded as an afterthought in supply chain reporting, is increasingly a core focus of sustainability scrutiny. Consumers are more aware, regulators more demanding. The E-PRTR reporting requirements are just one facet of a growing ecosystem of disclosure obligations. What’s clear is that aligning packaging waste data with Extended Producer Responsibility (EPR) schemes is no longer optional. It is an operational necessity, not just for compliance but for credibility.
One of the more immediate challenges beverage producers face is ensuring that their E-PRTR disclosures match up with national EPR open datasets. The good news is that in many EU countries, these datasets are improving in quality and accessibility. They provide a way to cross-check reported packaging waste tonnages, material categories, and recycling outcomes. But the integration isn’t automatic. It requires companies to map their internal material flow data to the categories and reporting structures used by national EPR schemes, and then further to the E-PRTR framework.
This is where Material Flow Analysis (MFA) comes in—an approach that, frankly, not enough firms in the sector are applying systematically. MFA helps map the physical flow of packaging materials through the production, distribution, consumption, and waste management stages. It forces a discipline on data collection that aligns nicely with both EPR and E-PRTR reporting requirements. And, perhaps more importantly, it can reveal inefficiencies or leakage points that are otherwise invisible in top-level reporting.
For firms looking to bring these elements together, there’s a rough but workable checklist that can guide integration with ERP waste tracking modules. First comes data harmonization. Internal records of packaging material use—whether PET bottles, aluminum cans, glass, or multi-layer composites—must be codified in ways that align with both national EPR categories and the material codes used in E-PRTR submissions. It sounds straightforward, but in practice, it means revisiting how packaging data is captured at procurement, production, and distribution points.
Next, companies should set up automated data feeds wherever possible. For example, linking ERP systems directly with waste management contractors’ reporting feeds reduces manual data entry errors and ensures that real-time or near-real-time waste flow data is available for analysis. Some firms have begun experimenting with IoT-enabled tracking of packaging flows, though adoption is still patchy and often pilot-scale.
A third step is reconciliation—checking that EPR fee calculations, national reporting obligations, and E-PRTR submissions all line up. This step is often overlooked, or at least under-resourced. But without reconciliation, discrepancies can go unnoticed until flagged by regulators or external auditors, at which point they are far costlier to resolve.
Finally, firms should document these processes rigorously. E-PRTR reporting, like most regulatory disclosures, operates on a trust-but-verify model. Having clear internal audit trails and documentation of how data flows were compiled, harmonized, and reported is essential. This isn’t just for the benefit of external regulators; it’s also an insurance policy against internal knowledge loss when key staff move on or when systems change.
What’s emerging, slowly but surely, is an understanding that packaging waste data management isn’t just an environmental compliance issue. It’s a supply chain transparency challenge, a cost-control opportunity, and a reputational risk all at once. And the firms that grasp this multifaceted character early are the ones most likely to thrive as both regulatory demands and public expectations continue to escalate.
One interesting development to watch is how national regulators and the European Commission will use E-PRTR data in combination with EPR scheme reports to target enforcement or to refine policy. Will we see a tightening of reporting standards? Additional verification requirements? It’s hard to say definitively, but the direction of travel seems clear. Data transparency is the name of the game, and companies that treat reporting as a box-ticking exercise are likely to find themselves outpaced by peers that view it as an operational asset.
It would be naive to suggest that all beverage companies are ready for this new data-driven reality. Many are still grappling with legacy systems, fragmented supply chain visibility, or organizational silos that make data integration slow and painful. And some may question the value of investing heavily in improved data systems when the direct commercial return is hard to quantify. Yet as the first full year of E-PRTR reporting demonstrates, the costs of poor data management—whether in regulatory penalties, damaged reputation, or lost market access—are becoming harder to ignore.
And so, in the messy, incremental way that often characterizes regulatory change, the Packaging and Packaging Waste Directive’s reporting provisions are beginning to reshape how beverage companies think about, manage, and disclose their packaging flows. The E-PRTR data from 2021 is just the start of that story.