PPWR compliance guide for packaging suppliers: six steps

⏱ Updated: 2026-10-26 · source: Regulation (EU) 2025/40 + EC Guidance C(2026) 3702

A packaging supplier usually does not issue the declaration of conformity, but the customer cannot draw it up without your data. Six steps from establishing your role to handing over the documents.

In brief

A packaging supplier generally does not draw up the declaration of conformity, but must give the product manufacturer all the information and documentation (Art. 16) and may not refuse to do so.
Six steps: role, material data, substances, recyclability, recycled content (plastics) and handing over on paper or electronically.
The supplier role does not carry Art. 10 and Art. 12; a supplier may add them deliberately.
The product manufacturer's legal responsibility cannot be transferred by contract.

What the European Commission says

As a rule packaging suppliers are not responsible for drawing up the declaration of conformity. Under Art. 16, however, they must give the packaging manufacturer all the information and documentation needed to demonstrate conformity, including all relevant technical documentation.
European Commission, PPWR questions and answers, chapter X, Q4

See how PPWRapka handles it

Role in the PPWR chain — Now the key setting: your company's place in the supply chain. There are five roles, and yours decides whether you issue a Declaration of Conformity or a Supplier Declaration.

Full episode: PPWR #1 — Account setup and your company's role →

The supplier's six steps

Establish your role. Do you supply a material or finished packaging, or do you fill it and place it on the market yourself? In the second case you are the product manufacturer. Packaging made to order without a name or trademark makes the ordering party the manufacturer (chapter X, Q14).
Describe the material. Type, layers, mass, coatings, printing, adhesive. Without it no later step works.
Collect substance data. Heavy metals up to 100 mg/kg (ICP-MS), PFAS 25 ppb and 250 ppb, total fluorine 50 ppm for food-contact packaging. If you have no tests, file a statement backed by data.
Assess recyclability. A DfR class, and from 1 January 2030 at least class C. For composites calculate the share of foreign material (up to 5 % for a mono-material).
For plastics, state recycled content. An annual average per plant and per type of packaging; the producing plant must document it (chapter V, Q2).
Hand it to the customer. On paper or electronically, in their language and with the batch identification.

The Commission explains in chapter III, Q5 that the product manufacturer needs this information from material suppliers or converters to identify PFAS and other substances of concern. A delay on your side therefore stops the customer's declaration.

What a supplier does not do, and may do additionally

The supplier role does not carry Art. 10 (minimisation) and Art. 12 (labelling): these fall on whoever places the packaged product on the market. A supplier may add them deliberately, for example when selling packaging with ready-made printing, but is not obliged to.

The supplier also does not sign the declaration of conformity for the customer. A supplier can issue a supplier declaration confirming the material data, which becomes part of the documentation. The product manufacturer stays responsible for conformity and cannot transfer that responsibility by contract; it may commission the conformity assessment from a laboratory or appoint an authorised representative to draw up the declaration, but the technical documentation remains its own (chapter X, Q9).

What the customer will ask for first

In practice customers ask for five things: a heavy-metals statement, a PFAS statement or report (for food contact), the recyclability class, recycled-content information (for plastics) and data that identify the batch. With them in a single file you shorten the exchange from weeks to a day.

The declaration is drawn up in the language of the Member State to which the packaged products are supplied (chapter XV, Q14), so documents for customers in several countries will need translations. See also the declaration of conformity guide.

What PPWRapka does with it

In PPWRapka you choose the supplier role and the application hides what does not concern you (Art. 10 and 12) and builds from the product register a supplier declaration as a PDF with your logo, in Polish and in English. You upload a test report once and attach it to many products from the same batch.

The application does not verify whether a laboratory is accredited and does not check the truth of a result in a report; you remain responsible for the data. Sending the document to the customer by e-mail and the archive of issued declarations are handled by the application, and Bielik suggests what is missing from the list.

Check this on your own packaging

Choose the supplier role in PPWRapka and prepare the documents your customer asks for.

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The quotation comes from the European Commission document Packaging and Packaging Waste Regulation (PPWR) — questions and answers (chapter X, Q4), in the Polish version of the document, translated here. Commentary, practical conclusions and the description of the application are ours. Only the text of Regulation (EU) 2025/40 is binding.

Frequently asked questions

Must a packaging supplier issue a declaration of conformity?

As a rule, no. It must, however, give the product manufacturer the information and documentation needed to demonstrate conformity (Art. 16).

Can I refuse to hand over technical documentation?

No. Suppliers may not refuse to give the product manufacturer the relevant documentation (Commission Q&A, chapter X, Q4).

Do Art. 10 and 12 concern the supplier?

Not as such. They concern whoever places the packaged product on the market, but a supplier may add them deliberately.

Do I need an English version of the documents?

For customers in other countries the declaration is drawn up or translated into the language required by that Member State.

Sources

ℹ️ This material is informational and educational and does not constitute legal advice. Only Regulation (EU) 2025/40 and national law are binding. PPWRapka is a commercial tool, not a public-administration service.