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Packaging and packaging waste maturity · Directive 94/62/EC

Your packaging practices placed on the Directive 94/62/EC scale, plus the action plan that moves them forward.

10 themes, a 5-level scale. And the action that moves each level to the next.

The framework’s 10 themes, already written from L1 to L5. One company, one business unit, or 300 at once.

Packaging and packaging waste maturity · Directive 94/62/EC

Governance and packaging responsibilitiesN1 → N5
Essential design requirementsN1 → N5
Hazardous substances and heavy metalsN1 → N5
Packaging inventory and bill of materialsN1 → N5

10 themes, 5-level scale.

Nordhavn Industries

53 / 100

Governance and packaging responsibilities6484
Essential design requirements5379
Hazardous substances and heavy metals6182
Packaging inventory and bill of materials3773
IAIndustrialised: your interview notes are enough, the AI fills in the audit.

They measure their maturity with Datamensio

  • Agri Sud-Ouest Innovation
  • ODA
  • Chambre de commerce et d'industrie
  • Eurobiomed
  • Enterprise Europe Network
  • HGK, Chambre de commerce croate

An example

This could be your situation.

Take one company as an example: three sites, three spreadsheets, no shared answer.

01

Nobody can consolidate.

Nordhavn Industries, 2,400 people in Hamburg, Lyon and Porto. A client asks where the group stands. Each site answers in its own spreadsheet, with its own scales.

02

Three weeks, a single base.

One Directive 94/62/EC of 20 December 1994 on packaging and packaging waste assessment launched across all three sites at once, from the managers’ interview notes. The framework was already written, its 10 themes and levels L1 to L5 too.

03

Two costs avoided before being committed.

A score of 53 out of 100, with the gap concentrated on three themes. The AI companion spotted that two actions duplicated those of another audit. The committee report took one sentence to request.

What it saved them

  • 3sites measured on the same base, instead of three questionnaires to reconcile
  • 2duplicate actions caught before the spend
  • 1committee report, with no manual rework

These figures are an example. They could be yours.

The standard imposes processes. Datamensio says where you stand.

01

The framework is already written

Themes, questions and levels L1 to L5, all written. You do not start from an empty spreadsheet.

02

The score lands the same day

Online, by self-assessment link or in interview. Theme by theme, comparable over time.

03

The gap becomes a costed plan

Every step up carries its action. The AI prioritises on expected effect, not on the order of the standard.

04

Progress can be demonstrated

Campaign after campaign, against your target and against your own past. That is what your board asks for.

The maturity scale

One level, the next, and the action that links the two.

It is this mechanism, one level, the level above, and the action that links the two, that turns a finding into a trajectory.

Is compliance with the heavy metal threshold established and kept up to date for every packaging item?

  1. N1

    No evidence available. The subject is not assigned to any identified function and relies on trust in suppliers.

  2. N2

    Attestations exist for some items, obtained as customer requests arise. The scope covered is not known.

  3. N3

    Every item has an attestation covering the substrate and printed components. Tracking is centralised and gaps are identified.

  4. N4

    Attestations are required by contract, renewed on schedule and checked on every specification change. Targeted analytical tests confirm the declarations.

  5. N5

    The system is reviewed periodically, informed by test results and regulatory changes, with a documented history of revisions and resolved non-conformities.

Action to move from level 2 to level 3

Build the full list of packaging items from the bills of materials, send a single attestation request covering substrate, inks, varnishes and adhesives, and resolve gaps at the monthly quality review.

« With Datamensio, we meet our objectives far more efficiently. The ERDF inspection services and our supervising ministry particularly appreciated an approach that gives them reliable data. »
Chambre de commerce et d'industrie

Director, CCI 94CCI Île-de-France

« We believe this is the most suitable solution to scale our transformation project and measure impact according to our needs. »
Interreg Danube Region

Maja SucekChief Operating Officer, Interreg Danube

Take your first measurement

What this framework covers

Directive 94/62/EC pursues two joint objectives: preventing the production of packaging waste and organising its reuse, recycling and recovery. It sets essential design requirements covering weight and volume reduction at source, restriction of hazardous substances, and suitability for reuse or recovery. It caps the sum of lead, cadmium, mercury and hexavalent chromium concentrations at 100 mg/kg. It also requires member states to set quantified recycling targets by material and a take-back system for used packaging.

In practice, the difficulty lies not in the text but in the decision chain. Packaging is designed by marketing, purchased by procurement, specified by R&D and declared by quality or the environment department. Who holds the documented evidence of compliance with essential requirements for each item placed on the market? Do suppliers’ heavy metal attestations cover inks, varnishes, adhesives and labels, or only the substrate? Are the tonnages declared to the compliance scheme reconstructed from actual bills of materials, or estimated at year end?

One point of context is often overlooked. The directive was substantially revised by Directive (EU) 2018/852, which raised recycling targets and extended extended producer responsibility. It is now on course to be replaced by a European regulation on packaging and packaging waste, directly applicable, which extends the scope to recyclability assessed against design criteria and to the reduction of unnecessary packaging. Another common confusion: the directive falls under environmental law, not food safety. It does not replace food contact material rules, it adds to them.

The maturity assessment does not answer the same question as a compliance audit. An audit concludes with a gap or a compliance finding for a given item. The assessment places practice on a progressive scale: is design eco-evaluated from the brief stage, or corrected afterwards? Are declarations industrialised, or rebuilt every year? It then points to the specific action that moves you to the next level. It measures maturity and prepares for inspections, it does not issue any certification.

In Datamensio, the framework is ready to use and adaptable. The AI adjusts themes, questions and levels to your packaging portfolio and markets, or builds a variant from your specifications, technical data sheets and eco-contribution declarations. Assessments run across multiple sites or business units are consolidated into a single cross-cutting roadmap.

Reference standard: Directive 94/62/EC of 20 December 1994 on packaging and packaging waste

The themes assessed

  • Governance and packaging responsibilities

    Formalised packaging policy, roles across quality, procurement, R&D, marketing and environment, regulatory monitoring, documented decisions.

  • Essential design requirements

    Weight and volume reduction at source, justification of the minimum necessary, suitability for recovery, evidence files per item.

  • Hazardous substances and heavy metals

    Control of the 100 mg/kg threshold for lead, cadmium, mercury and hexavalent chromium, scope of supplier attestations, inks, varnishes, adhesives and pigments.

  • Packaging inventory and bill of materials

    Inventory of primary, secondary and transport packaging, unit weights, materials, updates on item changes.

  • Reuse and reusable packaging

    Identification of reusable flows, return and deposit systems, number of rotations, hygiene conditions for reuse.

  • Recyclability and material choices

    Mono-materials and multilayers, compatibility with existing sorting streams, separability of components, seals, sleeves and labels.

  • Extended producer responsibility

    Membership of compliance schemes in relevant markets, scope of declarations, tonnage reliability, traceability of supporting evidence.

  • Marking and user information

    Material identification, sorting instructions by market, consistency between artwork, technical data sheet and declaration.

  • Suppliers and specifications

    Contractual packaging clauses, supplier assessment, management of specification changes, audits and receiving inspections.

  • Steering, indicators and improvement

    Monitoring of tonnages placed on the market, recycled content rate, periodic reviews, comparison over time and across sites.

A short version of the framework is available for the online self-assessment.

Frequently asked questions

Can Directive 94/62/EC be certified?

No. It is a directive transposed into national law, compliance with which is checked by competent authorities and verified by compliance schemes and customers. The assessment measures your maturity and prepares you for these checks, it does not issue any certification.

What is the difference between this assessment and a packaging compliance audit?

An audit examines items and concludes with a gap or a compliance finding. The assessment places your practices on a maturity scale and points to the trajectory for progress. The two complement each other: the assessment prepares the audit, the audit validates it.

How long does the assessment take?

The short version takes 20 to 30 minutes to complete. The full version, run collaboratively with quality, procurement and packaging development, usually spans one to two weeks, with most of the time spent gathering technical data sheets and attestations.

Does the framework cover the future European packaging regulation?

The themes of prevention, recyclability by design and reuse form a reusable foundation. You can have the AI adjust the questions and levels to incorporate the regulation’s criteria, then compare the two assessments over time.

Can the framework be adapted to our portfolio?

Yes. Themes, questions and levels can be modified, and the AI can produce a variant by material family or by market from your own documents. You retain full control of the framework.

Does this assessment replace the evaluation of food contact materials?

No. The directive addresses packaging from an environmental angle: prevention, recovery, hazardous substances. Suitability for food contact falls under a separate body of rules and must be assessed independently.

How can several sites or business units be compared?

Each entity completes the same assessment, scores are compared by theme, and a cross-cutting roadmap consolidates action plans to avoid duplicating the same work from one site to another.

Where is the data hosted?

In France, with OVH, backed up at Scaleway. No transfer outside the European Union. The AI models used can be selected, including from European solutions.

Take your first measurement