PPWR evidence: supplier, lab and technical documentation

It depends on which specific requirement you're confirming. For most parameters (weight, volume, basic construction, recyclability) accurate data from your packaging supplier or your own measurements is enough — the regulation does not require standard lab testing of every single packaging.

But for one specific point, lab testing is mandatory and a supplier's self-declaration is explicitly not enough — this is the PFAS restriction for packaging in contact with food (Article 5 of the regulation). Official Certificates of Analysis from an accredited laboratory are required per packaging type, not a written assurance from the supplier. Limits: 25 ppb per individual PFAS substance, 250 ppb in total, 50 ppm total fluorine.

Critical practical point on timing: several independent sources consistently report that accredited EU labs are currently overloaded, with PFAS test turnaround running 8–14 weeks. If you sell food-contact packaging and haven't submitted samples yet, act immediately — this isn't a theoretical risk, it's a real time shortage.

You need to clearly separate two substance categories here, since the required level of proof differs fundamentally. Formal responsibility for conformity rests with the “manufacturer” under PPWR terminology (the brand owner) in both cases — but the actual evidence standard is very different.

For heavy metals (lead, cadmium, mercury, hexavalent chromium — combined limit of 100 mg/kg, applies to all packaging, not just food-contact) a written supplier confirmation is often sufficient in practice, since this requirement has long been established, carried over from the earlier European Directive 94/62/EC.

For PFAS in food-contact packaging, the situation is fundamentally different. Multiple independent, recent sources agree that a written supplier assurance is explicitly not sufficient: an official Certificate of Analysis from an accredited laboratory is required per packaging type. There is still no single harmonised EU measurement method for PFAS — a stepwise approach via total fluorine analysis is used instead. If your range includes food-contact packaging, do not rely on a verbal or written supplier assurance for this specific point — request the actual lab report.

Yes, some form of test-backed proof is needed for every packaging type with direct food contact — but not necessarily the most expensive option, and the requirement applies not to packaging broadly, but specifically to the layer that physically touches the product.

The regulation sets out a tiered approach: start with a cheap total fluorine screening, costing a few hundred euros. If the result is below 50 ppm, that's sufficient — the packaging is considered compliant and no further testing is needed. Only if the first test comes back above 50 ppm do you need the more expensive targeted substance analysis (LC-MS/MS), checking the 25 ppb per-substance and 250 ppb combined thresholds. For ordinary food packaging without special grease- or water-resistant coatings, the cheaper first tier is usually enough.

The scope is limited to direct contact: the requirement covers the inner layer that physically touches the food (say, a plastic tray) — the outer shipping box around it, if it doesn't itself touch food, isn't covered by this requirement.

If your supplier already has a genuine Certificate of Analysis from an accredited lab specifically for this packaging type, you don't need to commission a separate test yourself — just collect and keep that document. A separate test is only needed if the supplier can only offer their own written assurance without an actual lab report behind it.

You are entitled to rely on your supplier's information — that is the normal path, and Art. 16 PPWR expressly obliges suppliers to provide you with the necessary information. Blind trust with no sanity check at all is risky, though, because legal responsibility for the declaration of conformity stays with you, not the supplier.

A reasonable sanity check looks like this: does the stated material actually match what you are holding? Is the confirmation specific to your product, or does it read like a generic template sent to every customer? Does the supplier actually respond to specific questions?

With established European packaging manufacturers who are themselves subject to the PPWR, the risk is low — they have their own interest in accurate information. With suppliers outside the EU who may not yet have encountered the PPWR, a closer follow-up is worthwhile.

When in doubt: a confirmation that is too generic or cannot be traced back to your material is worth little if it is ever challenged. Insist on specific, material-related information.

No. The 100 mg/kg limit for the sum of lead, cadmium, mercury and hexavalent chromium in packaging is not a PPWR innovation — it already existed under the old EU Packaging Directive 94/62/EC and is essentially carried forward by the PPWR.

What is new is mainly the framework around it: this substance restriction is now part of the mandatory conformity assessment and must be explicitly evidenced in the technical documentation under Annex VII — backed by a formal declaration of conformity that did not exist in this form before.

Also new, and specific to PFAS: since 12 August 2026, food-contact packaging is subject to its own limits for per- and polyfluoroalkyl substances (PFAS) — this was not regulated under the old directive.

In practice: if your material information was already clean under the old rules, the limit itself changes little. What changes is the evidencing obligation — you now have to document it in writing and confirm it in the declaration, not merely be able to prove it if asked.

No. The actual EU Declaration of Conformity under Annex VIII is deliberately kept short — usually one page. The detailed evidence belongs in a separate document: the technical documentation under Annex VII, which you keep on file and produce only if an authority asks for it.

The technical documentation includes, among other things: a general description of the packaging and its intended use, construction drawings and material information for the components, the list of standards and specifications relied upon, and an assessment of the risks of non-conformity.

In practice this means: you file supplier declarations, material data sheets and test reports in your own records — digital or paper — and keep them ready to hand. You do not need to attach them to the declaration itself.

What matters is that you can produce these documents quickly if needed. At the bottom of this page you will find a template for a structured request to your supplier that asks for exactly the information that later feeds into this documentation.

Annex VII point 2 of the PPWR lists six elements. First, a general description of the packaging and its intended use. Second, designs, manufacturing drawings and material specifications of the individual components.

Third, explanations needed to understand these drawings and how the packaging functions. Fourth, the list of harmonised standards, common technical specifications or other specifications applied.

Fifth, a qualitative assessment of the requirements that already apply at the relevant point in time — from August 2026 initially mainly the substance restrictions under Art. 5. Sixth, test reports and evidence where available, plus an analysis of the risks that the packaging might not be conforming.

The level of detail should match the risk: a simple corrugated box needs only a few pages, while more complex packaging with several material layers needs correspondingly more substance in the documentation.

There's no longer a simple “no” here — it depends on the specific requirement. For most standard packaging parameters (weight, construction, base material) lab reports genuinely aren't required — technical documentation from the supplier is enough.

For PFAS content in packaging that touches food, lab reports are mandatory without exception. Multiple recent, independent sources agree that a supplier's self-declaration is explicitly not recognised as sufficient evidence for this specific requirement — an official Certificate of Analysis from an accredited laboratory is needed.

Practical advice given the real lab backlog: if your range includes food-contact packaging and you haven't commissioned testing yet, do it now, without further delay — with typical turnaround running 8–14 weeks, any delay directly translates into lost time. This specific point doesn't apply to non-food packaging, but the heavy metal limit (100 mg/kg combined) applies to all packaging without exception — though a supplier statement is usually enough there, without a separate lab report.

The retention period depends on the type of packaging. For single-use packaging it is 5 years; for reusable packaging it is 10 years — in each case counted from the placing on the market of the last unit of that packaging.

This applies to both documents together: the EU Declaration of Conformity under Art. 39 and the underlying technical documentation under Annex VII. You must keep both for the same period.

In practice: as long as you are still selling a packaging or it is still in stock, the clock has not started yet — it only begins once that specific packaging is no longer newly placed on the market. For packaging you use unchanged for years, the practical retention obligation extends accordingly.

Electronic storage is sufficient — a physical binder is not required. What matters is that the documents can be found quickly if needed.

No. Unlike, for example, LUCID registration, you do not have to actively submit, upload or register the PPWR Declaration of Conformity anywhere. You draw it up, keep it available, and only show it if a competent authority asks for it.

This sets the declaration of conformity apart from many other evidencing obligations familiar from German packaging law. There is no central portal and no filing deadline for the declaration itself.

In practice this does not mean less responsibility, just a different kind: instead of a one-off filing, you must be able — at any time, even years later — to produce a complete and correct document when a market surveillance authority asks for it.

Some business partners and marketplaces are now asking for the declaration voluntarily to cover themselves. So keep it not only ready for authorities but also ready to hand for such requests.

Under Art. 15(4) PPWR, you must use appropriate procedures to ensure that your packaging remains conforming during series production. If something changes about the packaging itself or about the underlying requirements, you must update the declaration accordingly.

Concrete triggers for an update include: a change in material composition, a change of supplier with different material specifications, a change in the construction or size of the packaging, or a change in the underlying standards and technical specifications your declaration relies on.

If only the supplier changes but material, weight and construction stay identical, no substantive change is usually needed — though it is good practice to file the new supplier confirmation in your technical documentation.

There is no fixed rule like “review once a year” — the obligation is triggered by events. In practice, it is worth briefly checking whether the existing declaration still holds whenever the packaging changes, before the new batch goes on the market.

Yes, the limit covers every packaging component without exception, not just the primary material. This is confirmed directly: the threshold "applies to inks, adhesives, coatings, closures, labels, and every other packaging component, not just the primary packaging material." So tape (as an adhesive component) and a jar label both fall under the requirement, just like the jar or box itself.

In practice this means the combined limit of 100 mg/kg (lead, cadmium, mercury, hexavalent chromium) is calculated across all packaging components together, not just the "main" material like cardboard or glass.

If the material was bought at an ordinary retail shop rather than a specialised B2B supplier, the legal compliance obligation doesn't disappear — but getting a formal confirmation letter from a cashier or shop simply isn't realistic. Practical workaround: check the brand manufacturer's own website (not the shop's) — large manufacturers often publish general REACH compliance statements without a personal request. Document your own reasoning in writing too (e.g. "standard clear tape with no pigments or coating, exceeding the limit is technically implausible") — this doesn't replace a formal document but shows a genuine attempt at assessment. For regular, higher-volume purchases, switching to a dedicated packaging supplier who can issue a formal confirmation on request is the more robust long-term fix.