Quick summary: Supplier declarations under PPWR are the evidence behind your Declaration of Conformity. See exactly what to request from every packaging supplier before Aug 2026.
What information should you request in supplier declarations under PPWR? Request everything you need to sign your own Declaration of Conformity against Articles 5–12 of Regulation (EU) 2025/40: (1) full material composition for every component (lids, liners, labels, adhesives); (2) substance-restriction evidence a heavy-metals statement (lead, cadmium, mercury, hexavalent chromium ≤ 100 mg/kg combined) and, for food-contact packaging, a PFAS declaration; (3) recycled-content percentages; (4) recyclability / design-for-recycling data; (5) weight and empty-space data for packaging minimisation; and (6) traceability identifiers linking each declaration to a specific packaging item. Under Article 16, your suppliers are obliged to provide this documentation on request.
Supplier declarations under PPWR are the packaging conformity documents you collect from your suppliers the material, substance, and recycled-content evidence that lets you sign your own Declaration of Conformity with confidence. If you fill or brand packaging placed on the EU market, the Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40) makes you the party legally responsible for that declaration. But the data behind it rarely lives in your building. It lives with the converter who made the film, the printer who applied the ink, and the mill that supplied the board. This guide breaks down exactly what to request, why each item matters, and how to collect it at scale before the 12 August 2026 application date.
Supplier declarations under PPWR are written statements and supporting documents from your packaging suppliers confirming what each packaging component is made of and how it performs against the regulation’s requirements. In plain terms: they are the paper trail that proves your packaging meets Articles 5–12 of Regulation (EU) 2025/40.
At a glance, these declarations typically cover:
They are not the same as your Declaration of Conformity. Your DoC is your own self-certified statement of responsibility; these declarations are the underlying evidence that makes that statement defensible under audit.
Your packaging compliance is only as strong as the information your suppliers provide. Learn how to streamline supplier engagement, collect technical documentation, and build an audit-ready PPWR compliance program.
Read our Complete Guide to Supplier Engagement for PPWR
Here is the pain most compliance leads feel first: from 12 August 2026, no packaging may be placed on the EU market without a valid Declaration of Conformity and complete technical documentation. The DoC is a self-declaration under Article 39 by signing it, you assume full legal responsibility for the packaging’s conformity. There is no CE mark to lean on and, for most packaging, no notified body to share the burden.
That shifts the burden of proof onto you permanently. And you can only prove what your suppliers tell you. This is why these declarations are not a procurement side-task they are the foundation of your legal position. Miss one heavy-metals statement or one PFAS declaration for a food-contact film, and your DoC has a hole in it that a market-surveillance authority can drive straight through.
The good news: you are entitled to this data. Under Article 16, suppliers of packaging and packaging materials must provide the information and documents needed to certify conformity, including details of ingredients. The obligation exists. What most teams lack is a repeatable way to request, chase, validate, and store it.
From packaging specifications and material declarations to test reports and Declarations of Conformity, discover what documentation you need to build an audit-ready PPWR compliance program.
Read our Complete Guide to PPWR Technical Documentation
When you build your PPWR supplier-declaration request template, cover six evidence categories. Each maps to a specific obligation you will have to defend in your own technical file.
Ask for a full material breakdown of every component the box and its lid, liner, label, adhesive, ink, and coating. PPWR conformity is assessed at the component level, so a compliant box with a non-compliant label is still non-compliant packaging. Request the material type, grammage or thickness, and supplier and item reference for each part.
You can’t manage what you can’t measure. Learn how to build a complete packaging inventory, centralize packaging data, and create a strong foundation for PPWR compliance.
Read our Complete Guide to Packaging Inventory Data
Two substance requests belong in every PPWR supplier declaration. First, a heavy-metals statement: the combined concentration of lead, cadmium, mercury, and hexavalent chromium must not exceed 100 mg/kg, and this applies to all packaging regardless of material. Second, for food-contact packaging, a PFAS declaration. The Commission’s 2026 guidance describes a graduated approach that starts with a documentary supplier declaration confirming no intentional PFAS addition, before any screening or confirmatory testing which makes the supplier’s written statement your essential first line of evidence.
Request the recycled-content percentage for each plastic component and the supplier’s assessment of recyclability or design-for-recycling grade. Minimum recycled-content thresholds and recyclability grades tighten from 2030, but collecting this data now means you are not restarting supplier outreach from zero when those targets bite. Capture the basis of the claim, not just the number, so the figure is auditable.
Ask for weight, dimensions, and for e-commerce and grouped formats empty-space ratios, since packaging minimisation limits apply from application. Where reuse or refill systems are relevant, request evidence the system exists. Finally, insist on a unique identifier for each declaration a supplier part number, internal item number, or batch reference so every declaration ties back to a specific packaging item in your inventory. Without that link, your technical file becomes an unsearchable pile.

Knowing what to ask for is half the problem. The other half is collecting supplier declarations under PPWR from dozens of suppliers, in inconsistent formats, and keeping them current as materials and vendors change. Spreadsheets and email threads break down fast a single supplier swap means chasing a new declaration and updating records before that packaging can go to market.
This is where TraceX PPWR Solution fits. The platform gives you a structured supplier-declaration workflow: standardised request templates mapped to Articles 5–12, automated supplier outreach and reminders, validation checks that flag missing or expired evidence, and a centralised, version-controlled document store built for the regulation’s multi-year retention requirement. Because every declaration is linked to the specific SKU it supports, your Declaration of Conformity stays traceable and audit-ready rather than reconstructed under pressure.
The benefit is a defensible compliance position with far less manual chasing: fewer gaps, faster onboarding of new suppliers, and a technical file that surfaces the right evidence in seconds when an authority asks.
| Capability | Manual (spreadsheets + email) | TraceX |
|---|---|---|
| Request templates | Ad hoc; each analyst writes their own | Standardised templates mapped to Articles 5–12 |
| Supplier follow-up | Manual chasing; easy to lose track | Automated reminders and status tracking |
| Validation | Eyeballed; gaps found late | Automatic flags for missing or expired evidence |
| Evidence-to-SKU link | Fragile; lives in file names | Each declaration linked to its packaging item |
| Retention & audit | Scattered folders, version confusion | Centralised, version-controlled, retention-ready |
| New supplier onboarding | Restart the whole chase | Reusable workflow; fast onboarding |
Use this checklist to judge whether a supplier declaration is complete enough to support your DoC and whether a compliance tool you are evaluating actually closes the gap:
Supplier declarations under PPWR are the written statements and supporting documents you collect from packaging suppliers confirming material composition and compliance with Articles 5–12 of Regulation (EU) 2025/40. They are the evidence base for your own Declaration of Conformity.
Yes. Under Article 16 of the PPWR, suppliers of packaging and packaging materials must provide the information and documents needed to certify conformity, including ingredient details, on request.
A Declaration of Conformity (DoC) is your own self-certified statement of legal responsibility under Article 39. Supplier declarations under PPWR are the upstream evidence that makes your DoC defensible they are inputs, not substitutes.
For food-contact packaging, request a supplier declaration confirming no intentional PFAS addition. The Commission’s 2026 guidance treats this documentary declaration as the first step, ahead of any screening or confirmatory testing.
The combined concentration of lead, cadmium, mercury, and hexavalent chromium must not exceed 100 mg/kg. This applies to all packaging, regardless of material or category.
Aim to have them complete before the 12 August 2026 general application date, when a valid DoC and technical documentation become mandatory for packaging placed on the EU market. Confirm the current date, as a delay had been discussed.
The PPWR does not provide a general exemption for micro or small enterprises. Core obligations, including documentation, apply regardless of company size.