On 16 September 2026, News1 reported that Korean climate and renewable-energy consultancy Econetwork had established an Ecodesign Center dedicated to the EU Ecodesign for Sustainable Products Regulation (ESPR) and Packaging and Packaging Waste Regulation (PPWR). According to the report, the center plans to combine ESG strategy, life-cycle assessment, resource circularity, and environmental and carbon inventory work to support product and supply-chain data management, recycled-material use, and packaging compliance.
For manufacturers and exporters, the first question proposed here is not which consulting firm to hire, but what information an external team needs, what can be withheld or masked, and what deliverables it will return. A large folder of specifications, test reports, and certificates will still require follow-up if the documents are not linked to the relevant SKU and packaging version. Recording the recipient purpose, disclosure class, data version, and return deliverable makes the handoff easier to control and review.
Evidence cut-off: 17 September 2026, 08:45 KST. The center launch and planned service scope are based on News1 reporting that cited Econetwork’s announcement. Econetwork’s published project record states that it developed an EPR packaging-recycling life-cycle inventory database and a greenhouse-gas calculation methodology and carried out third-party verification. Publicly available sources do not specify the new center’s contract scope, deliverable formats, project timelines, pricing, or any completed engagements.
The problem in practice
The most common handoff failure is not a lack of files. It is a lack of scope and linking keys. A mill certificate, adhesive SDS, finished-product drawing, and box weight sheet may all exist, but they are difficult to use as evidence if they do not show which SKU and packaging version they cover.
PPWR and ESPR should be separated before their points of overlap are addressed. PPWR applies to packaging placed on the EU market and to all packaging waste, and it has generally applied since 12 August 2026. ESPR is a framework that covers nearly all physical goods, subject to specified exclusions; product-specific and horizontal ecodesign requirements are set through subsequent rules. The fact that ESPR is in force does not mean that every product already requires a Digital Product Passport or that the same DPP fields apply to every product.
The handoff package should separate legal-scope questions from technical-data questions and keep PPWR and ESPR materials clearly organized.
Evidence and checks
Separating source-backed facts from company decisions reduces both exaggeration and omission.
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| Observation | Source of the criterion | Status | Responsible role | Concrete action |
|---|---|---|---|---|
| PPWR applies to packaging placed on the EU market and to all packaging waste, regardless of material or sector, and has generally applied since 12 August 2026 | European Commission PPWR page and Regulation (EU) 2025/40 | Confirmed | Export and regulatory owner | Define EU sales SKUs and primary, secondary, and transport packaging scope |
| ESPR is framework legislation for subsequent product-specific or horizontal rules | European Commission ESPR implementation page and Regulation (EU) 2024/1781 | Confirmed | Product and regulatory owner | Check the ESPR Working Plan, applicable delegated act, and application date separately |
| Technical preparation for the DPP is underway; whether a product requires a DPP and what data it must contain are determined by the applicable delegated act | European Commission ESPR implementation page and Regulation (EU) 2024/1781, Article 9 | Confirmed | Product-data owner | Confirm applicability and required data fields before commissioning a company-wide DPP build |
| The Ecodesign Center plans to support product and supply-chain data, LCA, circularity, and packaging response | News1, 16 September 2026 | Announced plan | Client and external team | Confirm actual deliverables, responsibility boundaries, and verification route in the proposal |
| Econetwork reported completing a project to build an EPR packaging-recycling LCI database and a greenhouse-gas calculation methodology, including third-party verification | Econetwork project post, 28 August 2026 | Company-published project record | LCA owner and verifier | Treat this as evidence of relevant experience, not proof that a new engagement will have the same scope |
The existence of a law, product-level applicability, sufficiency of company data, and scope of a service provider are four different decisions. One press release or proposal cannot settle all four.
Practical deliverable: the handoff control sheet
Set the disclosure boundary before listing data fields. The classes below are editorial recommendations for starting an applicability review while protecting trade secrets and personal information. They are not statutory classification labels.
| Disclosure class | First-handoff rule |
|---|---|
| Minimum | Send a scope card, component-level packaging summary, and evidence index with document status |
| Conditional | Send detailed BOM data, calculation support, and supplier evidence only for the SKU and packaging version tied to a confirmed question, with the recipient purpose recorded |
| Restricted | For formulations, cost, customer drawings, or personal data, define NDA, access, retention, and masking controls before release |
| Not provided externally | Do not provide system credentials, unrelated customer or SKU data, or a complete source repository without a documented need |
Record data ID, applicable SKU and version, source and owner, recipient, recipient purpose, disclosure class, masking, transfer date, retention or deletion rule, expected return deliverable, and internal approver in each control-sheet row. The following five work packages can serve as a starting point. They are an editorial minimum for applicability review and evidence tracing, not a statutory submission form or a complete list of requirements.
1. Scope card
Record the following on one page:
- product name, SKU, model, HS code, and product group
- EU destination countries, sales channel, buyer, and importer
- PPWR economic-operator status, producer-registration responsibility, and current contractual division of work among the manufacturer, importer, and distributor
- packaging version, effective production date, and planned change date
- inclusion of primary, secondary, transport, e-commerce, and return packaging
- links to other regimes, such as food contact, cosmetics, dangerous goods, or electrical equipment
- questions to be decided in the engagement and the internal approver
Without a scope card, the provider has to re-sort the same evidence by country, SKU, and packaging version.
2. Packaging BOM
Use one row for every packaging component. Minimum columns should include:
- packaging component ID and applicable SKU
- packaging level and function
- material composition, composites, coatings, adhesives, inks, and labels
- component weight and the measurement or calculation method
- dimensions, tolerance, and packaging unit
- separable parts and expected waste or recycling route
- supplier, manufacturing site, lot, or specification version
- recycled-content claim and supporting evidence
- linked specification, declaration, test report, and certificate IDs
Do not stop at a line such as “paper box, 120 g.” If paper, coating, window film, label, and tape are combined, the reviewer needs the composition and separability of each part.
3. Evidence register
Send a register that explains the files before sending the files themselves. If the index is enough to frame the applicability question, release the source file conditionally only after that question is defined.
| Field | Example record |
|---|---|
| Document ID | PKG-BOX-014-EV-03 |
| Document type | Specification, supplier declaration, test report, certificate, or LCA input |
| Applicability | SKU, component, plant, supplier, lot, and period |
| Issuer or verifier | Supplier, laboratory, certification body, or internal approver |
| Standard or method | The actual method and edition stated in the document |
| Issue and expiry dates | Date plus planned renewal date |
| Source location | Controlled document-system link or managed path |
| Status | Confirmed, conditionally confirmed, unconfirmed, or not applicable |
Certificates are useful only within their stated scope. Fiber-sourcing documents such as FSC or PEFC certificates, substance test results, recyclability assessments, and LCA results are not interchangeable.
4. Gap and decision log
Do not fill unknown values with estimates that look final. Keep them in a separate log:
- unconfirmed field and affected SKU or packaging component
- missing source data or test
- data owner and target response date
- temporary assumption, if any, and its approver
- provider question, answer, and source URL or document ID
- final decision, decision date, and change-control impact
A controlled status list such as confirmed, conditionally confirmed, unconfirmed, and not applicable makes it easier to trace the difference between a report and its source data.
5. Deliverable specification
In the proposal, replace “PPWR and ESPR consulting” with a list of named deliverables. Every output should link back to the data IDs in the handoff control sheet:
- applicability matrix by product, country, and operator role
- packaging BOM gap table and remediation priorities
- mapping of requirements to evidence documents
- weight, recycled-content, and environmental calculation sheets with defined boundaries
- testing and verification list with samples and prerequisites
- DPP field mapping only where an applicable product rule has been identified
- change-control procedure, internal owners, and next review date
The provider should deliver reusable tables and records, not just a slide deck, so the company can update them when the packaging changes.
Responsibility boundary
A contract that transfers every responsibility to an external team weakens traceability between source data and the final claim.
- Manufacturer or exporter: accurate source data, confirmed SKU and version scope, final claim approval, and change approval
- External compliance team: framing applicability questions, analyzing data gaps, designing calculation methods and document structures, and preparing an implementation roadmap
- Laboratory or verifier: testing or independent verification under an agreed method, with documented results
- EU buyer or importer: confirmation of its EU economic-operator role, the contractual reporting unit, and applicable Member State registration or filing requirements
- Legal counsel: separate review where a formal opinion is needed on legal responsibility or statutory interpretation
Econetwork’s published account of its cooperation with IGSC assigns LCA and consulting to Econetwork and independent third-party verification to IGSC. The statement of work should also distinguish consulting, calculation, testing, verification, and legal interpretation.
When to withhold compliance claims
Do not use claims such as “compliance work complete,” “PPWR compliant,” or “DPP ready” while any of the following remains unresolved:
- target product, destination, sales route, importer, or operator role is not confirmed
- the packaging BOM is not broken down by component weight and material
- supplier evidence is not linked to SKU, packaging version, lot, or validity period
- recycled-content, recyclability, or environmental claims lack a method and supporting evidence
- the same DPP fields are requested for every product without first identifying the applicable ESPR delegated act
- one generic “PPWR certificate” is presented as a substitute for every requirement
- consultation, testing, verification, and legal interpretation roles are not separated
- unknown values were replaced with estimates without recording the assumption and approver
Seven questions to send before the first meeting
- What criteria will you use to confirm which of our products and packaging are in scope?
- Which legal provisions and subsequent acts will you use to assess compliance under PPWR and ESPR, respectively?
- Which conclusions can be reviewed from our current data, and which require new source data?
- Which parts of calculation, testing, third-party verification, and legal review do you perform directly?
- Which NDA, access, masking, retention, and deletion controls apply to restricted data?
- Beyond the slide deck, which tables, calculation files with formulas, and evidence indexes will you deliver, and how will they link to the data provided?
- When a product, packaging specification, or applicable rule changes, who updates the records, how will versions be controlled, and what triggers a new review?
An external compliance organization should define the scope, organize source data for verification, and track unresolved issues in a decision log. Preparing a handoff control sheet that records disclosure class, recipient purpose, version, retention rule, and return deliverable and links to the scope card, packaging BOM, evidence register, gap and decision log, and deliverable specification allows the company to retain the work as a reusable internal management system.
About the Author
PackingMaster: Editor of PaperPackLog, covering market trends, product information, and technical insights in the paper-packaging industry.
References
- News1, Korean consultancy establishes Ecodesign Center for EU product and packaging rules (2026-09-16)
- Econetwork, EPR packaging-recycling life-cycle inventory database and commercialization strategy project (2026-08-28)
- Econetwork, expanded cooperation with IGSC on environmental regulation response (2026-09-04)
- European Commission, Packaging waste
- European Commission, Implementing the Ecodesign for Sustainable Products Regulation
- Regulation (EU) 2025/40 on packaging and packaging waste
- Regulation (EU) 2024/1781 establishing a framework for ecodesign requirements