You can fill in the Declaration of Conformity right away. In parallel, we recommend asking your packaging supplier for some information: by signing, you declare under your sole responsibility that the packaging meets the requirements (Annex VIII PPWR), and the supplier's information supports that declaration.
How to proceed
- Fill in the Declaration of Conformity now — for example with our PPWR declaration generator.
- Send your packaging supplier the request below. It contains only the points legally needed for the declaration.
- Once the answer arrives, file it with your technical documentation. It is not attached to the declaration.
Request to your packaging supplier
Copy the text and send it to your supplier. Most packaging manufacturers in Asia respond faster in English or Chinese.
What the request asks for — and why
- Material of each component — without it, no requirement can be checked.
- Heavy metals: the sum of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg (Art. 5 PPWR). Applies to all packaging.
- PFAS — food contact only: limits of 25 ppb per substance, 250 ppb in total, 50 ppm total fluorine (Art. 5 PPWR). Laboratory analysis results are needed here.
- Food contact — food contact only: confirmation of compliance with Regulation (EC) No 1935/2004.
What to do with the answer
- Do not attach it to the declaration. The answer belongs in the technical documentation (Annex VII PPWR).
- Keep it: 5 years for single-use packaging, 10 years for reusable packaging (Art. 15 PPWR(3)).
- Provide it on request: if an authority asks for the documents, they must be made available within 10 days (Art. 15 PPWR(10)).
If the supplier does not answer, or answers vaguely
- Answers like "food grade", "EU standard" or "recyclable" do not cover any of the four points. Ask again — point by point.
- Ask for existing documents: material data sheet, test reports, the supplier's own declaration of conformity.
- If no data exist, test only what is missing — not the whole packaging. More in the syrup case study.
FAQ
Do I have to attach the supplier's answer to the Declaration of Conformity?
No. The answer belongs in the technical documentation. You keep it and provide it to an authority within 10 days of a request.
Do I have to wait for the supplier's answer before filling in the declaration?
No. You can fill in the declaration now and send the request in parallel. The supplier's information supports your declaration — so we recommend requesting it and keeping it with your technical documentation.
Do I need PFAS evidence for every packaging item?
No, only for packaging that comes into contact with food. The heavy-metals confirmation, however, applies to all packaging.
General information, not legal advice. As of 29.09.2026.
Sources
- Regulation (EU) 2025/40 (PPWR) — Art. 5, Art. 15, Annex VII, Annex VIII
- Regulation (EC) No 1935/2004 — food contact materials