PPWR creates a new packaging traceability challenge for Italian wineries

Italian wineries producing long-aged wines are facing new packaging compliance challenges under the European Union’s Packaging and Packaging Waste Regulation (PPWR), as producers may need to document the characteristics and origin of packaging components purchased years before a wine reaches the market.

The issue is particularly relevant to wineries that keep wines in cellars for extended periods, creating a significant gap between the moment packaging materials are purchased and the moment the finished product is released for sale.

Bottles, closures, labels and outer packaging may all be affected by the growing documentation and traceability requirements.

Packaging information may need to be reconstructed years later

For long-aged wines, the packaging used at the time of release may have been purchased under commercial conditions that predate the current regulatory framework.

Suppliers may have subsequently changed product specifications, internal systems or ownership, making it more difficult for wineries to retrieve the information required for current compliance documentation.

This creates a particular challenge for producers holding significant stocks of wines that were packaged or supplied before the PPWR became generally applicable.

PPWR increases documentation requirements

The Packaging and Packaging Waste Regulation became generally applicable across the European Union on 12 August 2026.

The regulation introduces new requirements affecting packaging throughout the supply chain, including provisions concerning chemical substances, material composition and conformity documentation.

For wineries, compliance therefore extends beyond the finished wine bottle to the different packaging components used to bring the product to market.

PFAS and heavy metals add further requirements

Among the issues affecting food-contact packaging are restrictions concerning per- and polyfluoroalkyl substances, or PFAS, as well as limits relating to certain heavy metals.

Wineries may therefore need to obtain reliable technical information from suppliers to demonstrate that packaging components meet the applicable requirements.

This can become particularly difficult when the packaging was purchased several years earlier and supplier documentation is no longer readily available.

Traceability extends beyond bottles

The compliance challenge is not limited to glass bottles.

Corks, labels, cartons and other packaging components may also require appropriate documentation and traceability information depending on their role within the packaging system.

This means wineries increasingly need to maintain a more complete record of the materials used across each packaging format.

Long maturation creates a specific compliance gap

The wine sector illustrates a broader problem that can affect products with long production cycles.

When products remain in storage for several years, packaging decisions made at the beginning of the process may need to be assessed against regulatory requirements that apply when the product is eventually placed on the market.

This time gap can make conventional procurement records insufficient for demonstrating compliance.

Packaging suppliers also face greater documentation demands

The new requirements affect packaging suppliers as well as wineries.

Manufacturers of bottles, closures, labels and cardboard packaging may increasingly be asked to provide detailed declarations and technical information to their customers.

For smaller packaging suppliers, the additional administrative burden can be significant, particularly where customers require information at batch level.

Batch traceability remains an open question

Industry representatives have also raised questions about how far batch-level traceability should extend and whether packaging families could be covered by simplified declarations.

A more standardised approach could reduce repetitive administrative work while still providing regulators and customers with sufficient evidence of compliance.

However, the precise requirements and available simplifications remain an area of discussion as implementation develops.

Packaging becomes part of long-term wine inventory management

The issue demonstrates how packaging compliance is becoming connected to inventory management.

For wineries with long-aged products, packaging records may need to remain accessible for years rather than only for the period immediately following procurement.

This creates a stronger need for structured digital records covering suppliers, materials, specifications, declarations and batch information.

Wine sector prepares for PPWR implementation

Italian wine producers are now working to understand how the new requirements should be applied to packaging already in use and to products that remain in cellars before release.

The immediate challenge is identifying documentation gaps and obtaining reliable information from packaging suppliers before affected wines enter the market.

The situation illustrates a broader consequence of the PPWR: packaging compliance is increasingly becoming a long-term data and traceability issue rather than a requirement limited to the moment when packaging is purchased.

Long product cycles expose new packaging compliance risks

The Italian wine sector provides a clear example of how regulatory changes can create challenges for industries with long production and storage cycles.

As European packaging rules become more demanding, companies will need to maintain access to packaging information throughout the entire product lifecycle.

For wineries, that may mean treating bottles, closures, labels and other packaging components as traceable elements of inventory rather than simply as procurement items.