Which documents need to be collected from the supplier for the PPWR declaration of conformity?

Which supplier documents are needed for PPWR? A quick checklist

There is no single universal ‘PPWR document package’ appropriate for every packaging item. The starting point should be to collect information enabling you to identify the packaging, reconstruct its design and demonstrate compliance with the requirements applicable to the given type of packaging.

Such a list is a starting point. You should not automatically request every possible certificate and test from every supplier. The scope of evidence should correspond to the requirements applicable to the specific type of packaging.

Article 16 PPWR: the supplier must provide information and documentation

The legal basis for requesting data from a supplier is Article 16 of Regulation (EU) 2025/40. The provision states that suppliers of packaging or packaging materials shall provide the manufacturer with all information and documentation needed to demonstrate the compliance of packaging and packaging materials with the PPWR. The Regulation expressly refers to the technical documentation set out in Annex VII and required pursuant to the relevant provisions of Articles 5–11. Information may be provided in paper or electronic form and in a language easily understood by the manufacturer. For contact-sensitive packaging, where other acts of Union law also apply, the relevant documentation required under those provisions may form part of the information package provided for PPWR purposes. The full text of the Regulation can be checked at EUR-Lex – Regulation (EU) 2025/40 .

Documents from the supplier do not transfer responsibility for the PPWR declaration

Obtaining documents from the supplier does not automatically mean that responsibility for compliance transfers to the supplier. You must first determine who, in the specific case, is the manufacturer within the meaning of the rules on packaging compliance. Pursuant to Article 15 of the PPWR, before placing packaging on the market, the manufacturer carries out or has carried out the conformity assessment procedure specified in Article 38 and draws up the technical documentation in accordance with Annex VII. Having demonstrated conformity, it draws up the EU declaration of conformity pursuant to Article 39. Article 39(4) is particularly important: by drawing up the declaration of conformity, the manufacturer assumes responsibility for the conformity of the packaging with the PPWR requirements. A document received from the supplier may therefore be important evidence, but you must check its scope and determine whether it concerns exactly the packaging or component you use.

1. Start with clear identification of the packaging

Each document should be capable of being clearly linked to a specific packaging item, material or component. A laboratory report concerning a “PET bottle” is of little value if the company cannot demonstrate which exact bottle from the supplier’s catalogue it concerns. It is worth collecting at least:

• the trade name of the packaging or component,
• the supplier’s product code,
• the internal packaging code used in your company,
• the packaging type and format,
• dimensions and weight,
• the version or revision of the specification,
• information on the intended use of the packaging,
• the validity date of the document or product version.

Article 15(5) of the PPWR also requires packaging to bear a type, batch number, serial number or other element allowing its identification or, if this is not possible because of the size or nature of the packaging, for the relevant information to be included in an accompanying document.

2. Request the technical specification and material composition of the packaging

The technical specification is one of the basic input documents for the conformity assessment. It should make it possible to understand what the packaging is made of and how it is manufactured. Depending on the design, it is worth collecting information on the main material, individual layers, additives, closures, labels and other components affecting the properties of the packaging. Annex VII to the PPWR requires the technical documentation to include, where applicable, inter alia, the materials of components. Therefore, simply stating “plastic packaging” will usually not provide a sufficient level of information for sound technical documentation.

3. Collect technical drawings and design information

Annex VII also refers to the conceptual design, manufacturing drawings and descriptions necessary for understanding them. This does not mean that, in every case, you need to obtain the supplier’s complete confidential technical documentation. However, the documentation should enable assessment of the conformity of the specific packaging and reproduction of the key parameters of its design. For multi-component packaging, it is worth identifying separately, for example, the body, closure, label, sleeve, insert or other elements if they are relevant to the assessment of requirements.

4. Test reports: check not only the result, but also the scope of testing

Annex VII lists test reports as an element of the technical documentation, where applicable. This does not mean, however, that every packaging item must automatically undergo an identical set of laboratory tests. Article 35 of the PPWR requires that tests, measurements and calculations used to demonstrate conformity be carried out using reliable, accurate and reproducible methods and take account of the generally recognised state of the art. When receiving a report from a supplier, check:

• who carried out the test,
• which sample the report concerns,
• whether the sample code corresponds to the packaging being purchased,
• which method was used,
• which parameters were tested,
• when the test was carried out,
• whether the material or process has changed since the test,
• whether the result actually demonstrates the required level of conformity.

A PDF file simply entitled “certificate” should not be treated as sufficient evidence without checking its scope.

5. Harmonised standards and technical specifications must also be documented

Technical documentation should indicate the basis on which conformity was assessed. Annex VII lists, among other things, harmonised standards, common specifications and other relevant technical specifications used for measurements or calculations. If a supplier declares conformity on the basis of a specific standard, it is worth establishing whether it has been applied in full or only in part. If a standard or common specification has not been applied, the documentation should describe the solution adopted to meet the relevant requirement.

6. Food contact packaging may require additional documentation

For packaging sensitive to contact, the scope of documents does not end with the PPWR itself. Article 16(2) indicates that, where applicable, the documentation and information required under other EU legal acts concerning such packaging should form part of the information provided to the manufacturer. Therefore, before preparing a checklist for the supplier, the actual intended use of the packaging should be established. One set of evidence may be needed for a transport carton, another for a cosmetic bottle, and yet another for material intended for direct contact with food.

7. Recyclability, minimisation and reuse: check the relevant date

The PPWR covers a range of requirements concerning, among other things, recyclability, packaging minimisation, recycled content and reuse. However, not all obligations start to apply on 12 August 2026. Therefore, the list of documents from the supplier should be developed not only by material, but also by the requirements applicable to a given type of packaging at a specific time. Annex VII itself provides, among other things, for a qualitative description of how the relevant assessments arising from Articles 6, 10 and 11 were carried out. As further requirements and implementing acts enter into force, the scope of data needed may therefore change.

Is it enough to ask the supplier for a “PPWR declaration of conformity”?

Not always. If the supplier is the manufacturer of a finished packaging type and has correctly carried out the conformity assessment, its EU declaration of conformity may be a very important document. However, it should comply with the PPWR template and requirements and clearly identify the packaging to which it relates. If, on the other hand, you purchase only material or a component from the supplier, for example a specific raw material or an element of larger packaging, the situation may be different. In that case, you primarily need data and documentation enabling you to use that component in the conformity assessment of the final packaging. Therefore, instead of sending all business partners one question: “Please provide a PPWR certificate”, it is better to specify exactly what information you need and to which type of packaging it will be assigned.

What should you collect from a supplier outside the EU? Importer obligations are broader

An importer should not assume that responsibility ends with receiving one document from a foreign manufacturer. Article 18 of the PPWR requires, before placing packaging on the market, verification, among other things, that the manufacturer has carried out the conformity assessment procedure and drawn up technical documentation in accordance with Annex VII. The importer must also keep a copy of the EU declaration of conformity and ensure that the technical documentation can be made available to the competent authorities upon request. In practice, when directly importing packaging or products in packaging from outside the EU, it is worth establishing already at the purchasing stage whether the foreign business partner will be able to provide complete, identifiable and up-to-date technical data.

What should you do if the supplier does not have the documents required under the PPWR?

Missing documents should not be “remedied” by issuing a declaration without evidence. A declaration of conformity is the result of the conformity assessment process, not a substitute for it. If the documentation is incomplete:

1. specify exactly which information or evidence is missing,
2. identify to the supplier the packaging or component to which the request relates,
3. request documentation on the basis of Article 16 of the PPWR,
4. check whether the gap can be filled with other reliable evidence,
5. where necessary, carry out an appropriate assessment, measurement or test,
6. do not finalise the conformity assessment until you have a sufficient basis to demonstrate fulfilment of the relevant requirements.

A particularly risky situation is one in which a company has a declaration but cannot demonstrate the technical documentation on which it was based.

How do you check whether a supplier document is genuinely suitable for PPWR documentation?

Scope, traceability and currency are key. Each document received should be assessed using the same set of questions.

A change of supplier, material or design may require reassessment

Article 15(4) of the PPWR requires changes to the design, packaging characteristics and relevant standards and specifications on the basis of which conformity is declared to be taken into account. If a change may affect packaging conformity, a reassessment must be carried out in accordance with Article 38. Therefore, it is worth agreeing a mechanism with the supplier in the procurement process for notifying changes. It is not sufficient to collect documents only once and retain them indefinitely, regardless of subsequent changes. The following changes, among others, may require review:

• the material supplier,
• the type of material or formulation,
• the packaging mass,
• the design and dimensions,
• layers or components,
• the manufacturing process affecting characteristics,
• the standards or specifications used.

How do you manage supplier documents when the company has hundreds of SKUs?

At a larger scale, the issue is no longer simply storing files, but linking the right evidence to the right packaging type. One packaging type may be used by many products or SKUs. Conversely, one product may use several packaging elements from different suppliers. Therefore, it is worth building the relationship: supplier → component → packaging type → version → technical documentation → conformity assessment → declaration. Such a model makes it possible to answer not only the question “do we have this PDF?”, but above all “for which packaging is this document the basis for conformity?”.

PPWR documentation must be retrievable during an inspection

Article 15(10) of the PPWR provides that, following a reasoned request from a national authority, the relevant information and documents needed to demonstrate conformity should be made available within 10 days of receipt of the request. The manufacturer should therefore be able to move quickly from specific packaging to the technical documentation and evidence on which the conformity assessment was based. A corresponding deadline is provided for importers in Article 18(8). This is one reason why storing hundreds of files in inconsistent folders, email inboxes and spreadsheets can become an organisational problem.

How long must technical documentation and the PPWR declaration be retained?

In accordance with Article 15(3), technical documentation and the EU declaration of conformity shall be retained for:

• 5 years from placing on the market in the case of single-use packaging;
• 10 years from placing on the market in the case of reusable packaging.

It is also worth retaining information on the version of the documentation, its validity period and the packaging to which it applied.

Most common mistakes when collecting documents from suppliers

The biggest mistake is treating PPWR documentation as a collection of random certificates. The documents should form coherent evidence for a specific packaging type.

• requesting only a “PPWR certificate” without specifying its scope,
• no packaging identifier on documents,
• retaining reports without information on which variant they concern,
• no version control for documentation,
• no information on changes on the supplier’s side,
• automatically treating one report as evidence of all requirements,
• confusing technical documentation with the declaration of conformity itself,
• no link between the packaging and the products or SKUs in which it is used.

What should the process for collecting PPWR documentation from suppliers look like?

For a larger number of packaging types, a consistent, repeatable process works well instead of a one-off campaign of emailing business partners.

1. Identify the packaging type and its components.
2. Assign a supplier to each component.
3. Determine the applicable PPWR requirements.
4. Define the required data and evidence.
5. Collect documents from suppliers.
6. Check the scope, identification and currency of each document.
7. Complete any missing assessments, calculations or tests.
8. Compile the technical documentation in accordance with Annex VII.
9. Carry out the conformity assessment in accordance with Article 38.
10. Once conformity has been demonstrated, prepare the EU declaration of conformity.
11. Link the declaration to the relevant packaging type.
12. Monitor subsequent changes to the documentation and packaging.

When is it worth automating the management of PPWR documentation and declarations?

With a few packaging types, documentation can be managed manually. With several dozen or several hundred packaging types, however, an additional problem arises: suppliers, versions, components, documents, declarations and products using a given packaging type must be controlled. In this case, automation should cover not only the generation of the final PDF, but the entire data chain leading to the declaration of conformity. For example, the system can identify missing data, retain source documents, link them to specific packaging types, control versions and generate a declaration on the basis of structured documentation.

Supplier documents for PPWR – key conclusions

You do not need a collection of random certificates. You need complete and identifiable evidence for a specific packaging type. Article 16 of the PPWR provides a clear basis for obtaining from suppliers the information and documentation needed to demonstrate conformity. Annex VII, in turn, indicates the elements that technical documentation should contain. Ultimately, these documents serve to carry out the conformity assessment and, once compliance with the relevant requirements has been demonstrated, to prepare the EU declaration of conformity. The key point is therefore to link the document to the specific packaging, its version, material, PPWR requirement and the evidence that actually confirms that requirement.

FAQ – PPWR documents and declaration of conformity

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