PPWR evidence: supplier, lab and technical documentation

Not automatically. The PPWR does not require an external test procedure by a notified body for packaging — the conformity assessment procedure is officially called “Module A, internal production control” (Annex VII). You assess conformity yourself, under your own responsibility.

That does not mean you may make up figures. You need a solid basis: material data sheets and confirmations from your packaging supplier, test reports where they exist, and your own reasoned assessment of whether the requirements of Art. 5 to 12 PPWR are met.

A lab test becomes relevant in practice mainly when you cannot get reliable information from the manufacturer — for instance a supplier who cannot provide material composition or a heavy-metal confirmation on request. In that case, an independent test is often simpler than relying on unsupported assurances.

For most standard packaging — cardboard, film, simple labels — the supplier's information combined with your own assessment is entirely sufficient.

Responsibility for conformity sits with you as manufacturer — but that does not mean you have to run chemical analyses yourself. In practice, most manufacturers rely on written confirmations from their packaging suppliers.

You have a legal basis for this: under Art. 16 PPWR, suppliers are obliged to provide you with all the information and documentation you need for the conformity assessment — in a language you understand, on paper or electronically.

In concrete terms: request written confirmation that the sum of lead, cadmium, mercury and hexavalent chromium does not exceed the 100 mg/kg limit, and — for food-contact packaging — that no PFAS are present above the legal thresholds.

If you do not receive this confirmation, or it looks unconvincing (a blanket statement with no reference to your actual material), treat that as a warning sign. Follow up, or consider an independent test if in doubt.

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.

Not strictly, and for most standard packaging they are not common either. Annex VII requires test reports only “where available” — the procedure is designed as internal production control, not mandatory third-party testing.

In practice, most manufacturers rely on a combination of supplier declarations, material data sheets and their own reasoned assessment of the requirements. That is sufficient for unremarkable standard materials such as corrugated board, unprinted polyethylene or aluminium.

Lab reports become relevant mainly when there is a specific reason: you cannot get reliable provenance confirmation from the supplier, you are using an unusual or recycled material, or the packaging is food-contact and you want to be sure of the PFAS levels.

If you are unsure, weigh the risk: for a simple shipping box made of standard material, a lab analysis is rarely needed. For a novel material or a supplier you do not fully trust, testing is the safer choice.

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.