On 16 September, COVERE² joined packaging manufacturers, food and beverage companies, retailers, certification bodies, regulators and industry associations at the “Focusing on legislative changes regarding packaging materials” conference at the Hungaroring in Budapest.

The timing could hardly have been more relevant. The EU’s packaging regulatory landscape is undergoing significant change, with the Packaging and Packaging Waste Regulation (PPWR) now entering its implementation phase alongside changes affecting food-contact materials, BPA restrictions, EUDR requirements and existing national compliance obligations.

Across ten presentations and a closing policy roundtable, one message surfaced repeatedly: for companies working with packaging, the challenge is no longer simply understanding individual regulations. It is understanding how they interact, what evidence needs to be collected, and how to turn an increasingly complex set of requirements into manageable operational processes.

Here are the themes that stood out most to us.

The Regulatory Challenge Is Becoming a Systems Challenge

One presentation described the current situation as navigating a new regulatory “jungle.” That description captured the mood in the room remarkably well.

Packaging producers and companies placing packaged products on the European market are increasingly dealing with several regulatory tracks simultaneously: PPWR, EUDR, BPA-related restrictions, EU food-contact-material requirements, and national extended producer responsibility systems, among others.

Individually, each regulation can already require significant technical interpretation. Together, they create a much harder problem.

Companies need to understand which obligations apply to which products, materials and suppliers; when different requirements enter into application; which documentation must be collected; and how one regulatory requirement interacts with another.

Even experienced industry professionals acknowledged how difficult it has become to keep this landscape straight.

This has an important implication for sustainability and compliance teams. Regulatory management can no longer rely on isolated spreadsheets, documents and individual specialists remembering which requirement applies where.

The underlying problem is increasingly one of information architecture. Companies need structured ways to connect regulations with products, suppliers, materials, evidence and internal responsibilities.

Compliance Is Moving Beyond Certification

Another recurring theme was a shift in what companies expect from certification bodies and sustainability advisers.

Traditionally, much of the compliance market has focused on proving that a company or product meets a particular requirement: conduct an assessment, prepare the necessary documentation, complete an audit, obtain a certificate.

But companies increasingly need something broader. They need help deciding what to do next.

When several regulations overlap, the hardest questions are often not binary compliance questions. They are prioritisation questions:

• Which requirement should we address first?
• Which supplier information do we need?
• Which packaging formats will remain viable?
• What evidence will an auditor expect?
• How should we document the reasoning behind a decision?

The ability to interpret regulation and translate it into operational decisions is therefore becoming at least as important as certification itself.

For sustainability professionals, this represents a wider shift we see across many regulatory areas: compliance functions are gradually becoming decision-support functions.

The value is no longer simply in proving that something was done. It is in creating a reliable process for deciding what should be done in the first place.

Documentation May Be the Real Bottleneck

One of the conference's most practical discussions focused on the Declaration of Conformity for food-contact materials.

The message was clear: documentation is frequently where otherwise well-developed compliance systems break down.

Declarations of conformity sit at the intersection of product specifications, supplier information, regulatory requirements, certifications and audits. Missing information, inconsistent versions or poorly maintained records can quickly become audit findings.

The same challenge appears in other regulatory frameworks. Under EUDR, for example, companies must manage due-diligence information linked to the geographical origin of commodities and retain relevant records over extended periods.

Each individual document may appear manageable. The complexity emerges when organisations have hundreds of suppliers, materials and products, with documentation changing over time and different teams responsible for different parts of the process.

At that point, compliance becomes a data-governance problem.

• Who owns the information?
• Where is the latest version stored?
• How is it linked to the relevant supplier or product?
• Can the company reconstruct why a particular decision was made?
• Can the evidence be retrieved quickly during an audit?

Without a structured system behind the process, the administrative burden increases rapidly.

Digitalisation Is Becoming Part of Compliance Infrastructure

Digitalisation appeared throughout the conference not simply as a way of reducing administrative work, but as an increasingly important part of compliance itself.

One particularly interesting example came from SPAR Hungary, which described using artificial intelligence to identify packaging signals that may not comply with the Empowering Consumers for the Green Transition (EmpCo) directive requirements.

It is a practical example of where regulatory compliance is heading. Instead of relying exclusively on manual reviews after information has been collected, digital systems can increasingly help companies identify inconsistencies, missing information and potential compliance risks earlier in the process.

This matters because the volume of sustainability and regulatory information companies need to manage is growing much faster than most sustainability teams. The answer cannot simply be to add more spreadsheets or ask employees to manually check more documents.

Companies need systems that help them:

• centralise regulatory and sustainability information;
• connect documentation with products, suppliers and reporting requirements;
• identify missing or inconsistent information;
• maintain traceable records;
• and turn collected data into actionable decisions.

Digitalisation therefore becomes more than an efficiency project. It becomes part of the organisation's compliance infrastructure.

Packaging Decisions Are Becoming Sustainability Decisions

The conference also highlighted how quickly packaging itself is evolving.

Companies are facing growing demand for lower-impact packaging alongside new functional solutions such as biodegradable materials, edible packaging and active or intelligent packaging capable of responding to product conditions.

At the same time, product-safety considerations remain fundamental. Discussions around migration and cross-contamination showed why replacing one packaging material with another is rarely a straightforward sustainability decision. A material that performs better according to one environmental metric may introduce different technical, safety, durability or supply-chain considerations.

Extended producer responsibility adds another dimension. Packaging choices increasingly create financial, reporting and operational consequences long after a product has been designed. This is precisely why lifecycle thinking matters.

Instead of asking whether one packaging material is simply “more sustainable” than another, businesses increasingly need to evaluate trade-offs across the full system: material sourcing, manufacturing, transport, product protection, food waste, recyclability, reuse and end-of-life treatment.

Good sustainability decisions require this wider perspective.

Regulation Is Moving Faster Than Organisational Systems

Perhaps the most important takeaway from Budapest was not about one particular regulation. It was the gap between the pace of regulatory change and the systems companies currently use to manage it.

PPWR will continue to introduce requirements over the coming years. EUDR, food-contact-material legislation, green-claims rules and sustainability reporting requirements will continue interacting with product design and supply-chain decisions.

The organisations best positioned to navigate this environment will not necessarily be those with the largest compliance teams. They will be those that build better systems for collecting information, connecting requirements, documenting decisions and turning data into action.

For us at COVERE², the conference reinforced something we increasingly hear across industries: businesses do not simply need more sustainability data. They need a way to make that data usable.

As environmental regulation becomes more interconnected, the distinction between sustainability reporting, compliance management and strategic decision-making will continue to narrow.

The objective should therefore not be to create another layer of reporting around the business. It should be to build an information system that helps the business make better decisions in the first place.