What Does the EU Packaging Regulation Require From Suppliers?

From 12 August 2026, Article 16 of Regulation (EU) 2025/40 (PPWR) requires packaging and packaging-material suppliers to give manufacturers the information and documents needed to prove that each package complies.

For each packaging SKU, revision, and manufacturing site, the manufacturer may need to collect:

• Material specifications and the construction of components, layers, coatings, inks, adhesives, closures, and labels
• Substance declarations and test reports, including food-contact PFAS evidence where Article 5 applies
• Packaging weight, dimensions, drawings, and bills of material
• Recyclability, recycled-content, compostability, reusability, or minimization evidence, depending on the packaging classification and the applicable date
• The standards, test methods, calculations, and reports supporting each compliance claim

There is no universal PPWR supplier certificate. The manufacturer, often the brand owner or filler, uses supplier evidence to build the Annex VII technical documentation, completes the conformity assessment, and signs the EU Declaration of Conformity.

The manufacturer must retain two specific records after placing the packaging on the EU market:

• The Annex VII technical documentation supporting the conformity assessment
• The signed EU Declaration of Conformity

The retention period is five years for single-use packaging and ten years for reusable packaging. The clock starts when the packaging is placed on the market.

The Article 16 supplier-information duty applies now. Several other requirements phase in later, including harmonized labels from 2028 or later and detailed recyclability grades, recycled-content targets, and packaging minimization from 2030 or later.

Download the PPWR supplier evidence request template (CSV). It follows Articles 5 through 11 and Annex VII, with rows for packaging identity, materials, substances, recyclability, recycled content, test reports, exceptions, and change control. Use one copy per packaging reference and remove rows that do not apply.

What changed on 12 August 2026?

Regulation (EU) 2025/40 is usually called the Packaging and Packaging Waste Regulation, or PPWR. It entered into force on 11 February 2025 and began to apply generally on 12 August 2026. It replaced the previous directive with directly applicable EU rules for packaging and packaging waste.

The date does not mean every PPWR target took effect at once. The regulation uses a phased calendar:

• The general compliance structure, supplier information duty, and applicable substance restrictions are in effect.
• Food-contact packaging placed on the market from 12 August 2026 must stay below the Article 5 PFAS limits. The Commission has confirmed that there is no stock-exhaustion period for food-contact packaging produced before that date but first placed on the market afterward.
• Detailed recyclability grades apply from 2030 or later, depending on when the Commission adopts the supporting delegated acts.
• Minimum recycled-content targets for plastic packaging apply from 2030 or later.
• Harmonized material labels apply from 12 August 2028 or 24 months after the relevant implementing acts enter into force, whichever is later.
• The full packaging-minimization requirement in Article 10(1) applies from 1 January 2030.

Companies need a technical documentation process now, but the evidence required for a packaging SKU will change as later requirements become applicable.

Who is the manufacturer under PPWR?

The word “manufacturer” is easy to misread. It does not always mean the company that physically converts resin, paper, glass, or metal into packaging.

Under Article 3 and the Commission’s 2026 PPWR guidance, the manufacturer is generally the company that manufactures packaging or a packaged product, or has it designed or manufactured under its own name or trademark. For sales and grouped packaging, this will often be the product brand owner or filler because that company controls the packaging specification and places the packaged product on the EU market.

The company that physically supplies the bottle, pouch, tray, carton, label, coating, or packaging material may therefore be a supplier under Article 16. That supplier has to provide the information the manufacturer needs, but it does not take over the manufacturer’s legal responsibility merely by sending a declaration.

There are special rules for microenterprises, unbranded packaging, importers, distributors that relabel or modify packaging, and some service or transport packaging. Companies should assign the legal role for each packaging flow instead of assuming that the same party is always responsible.

Manufacturer and producer are different PPWR roles

PPWR also uses the word producer for extended producer responsibility. A producer registers and pays for packaging waste management in the Member State where the packaging is expected to become waste. A manufacturer ensures that the packaging meets the sustainability, labeling, and information requirements in Articles 5 through 12.

One company may hold both roles, but the terms are not interchangeable:

• The manufacturer owns the conformity assessment, technical file, and EU Declaration of Conformity.
• The supplier provides the information and documents needed for that work.
• The producer handles national registration, reporting, and extended producer responsibility fees.

The supplier-document request should identify which role the requesting company holds and which packaging units it is assessing.

What does Article 16 require suppliers to provide?

Article 16 says suppliers must provide all information and documentation necessary for the manufacturer to demonstrate that the packaging and packaging materials comply with the regulation. This includes technical documentation required under Articles 5 through 11. The supplier may provide it on paper or electronically, in one or more languages the manufacturer can easily understand.

Where contact-sensitive packaging is covered by other EU legislation, the relevant documentation from those laws should also form part of the supplier package.

The regulation does not prescribe one universal “PPWR certificate” or supplier spreadsheet. Annex VII defines what the manufacturer’s technical documentation must contain. The manufacturer has to translate that structure into a request that fits the packaging type and the requirements currently applicable to it.

What should you ask each packaging supplier for?

Start with a controlled package of evidence tied to a specific packaging reference. There is no official EU fillable “supplier PPWR form.” These resources serve different parts of the job:

• Bridgecurrent PPWR supplier evidence request template (CSV): a working request organized around Articles 5 through 11 and Annex VII
• Annex VII technical-documentation structure: the official structure the manufacturer must satisfy
• Annex VIII EU Declaration of Conformity model: the official model for the manufacturer’s signed declaration
• Europen PPWR Conformity Assessment Toolkit: guidance for mapping the portfolio, assigning roles, and preparing Annex VII and VIII datasets
• Waste2Wear recycled-packaging supplier checklist (PDF): a third-party procurement checklist focused on recycled packaging
• activaTec editable supplier inquiry: an editable third-party request for product and material information

The two supplier questionnaires are working aids, not prescribed legal forms. Adapt each request to the packaging type and applicable requirements.

A useful request includes the following.

1. Packaging identity and intended use

Ask for:

• The supplier’s packaging SKU, grade, or specification number
• Your corresponding packaging or finished-product SKU
• The packaging type, format, and intended use
• The current revision and effective date
• The manufacturing site or sites covered by the evidence

PPWR requires manufacturers to identify packaging by a type, batch, serial number, or another traceable element. A document that cannot be matched to the packaging you buy is weak evidence, even if its title says “PPWR compliant.”

2. Design, materials, and components

Annex VII calls for a general description, conceptual design, manufacturing drawings, and the materials used in components. Depending on the packaging, the supplier package may need:

• Material and polymer specifications
• Component and layer construction
• Coatings, inks, adhesives, closures, labels, and integrated components
• Drawings, dielines, or bills of material
• Weight and dimensions
• A description of the manufacturing process where it affects compliance

Composite packaging and separate components may need their own recyclability assessments. A high-level statement about the main body of a package may miss a coating, barrier, label, or closure that changes the result.

3. Restricted-substance evidence

Article 5 retains the combined 100 mg/kg limit for lead, cadmium, mercury, and hexavalent chromium in packaging or packaging components. Food-contact packaging must also meet the PPWR PFAS limits that have applied since 12 August 2026.

Ask for the evidence that supports the relevant conclusion, such as:

• Supplier substance declarations
• Material composition data
• Laboratory reports
• The test method, reporting limit, sample identity, and test date
• Evidence explaining total fluorine above 50 mg/kg where Article 5 requires it

Do not request PFAS testing from every supplier without first confirming that the packaging is food-contact packaging and that the evidence is necessary. The request should follow the legal scope.

4. Recyclability evidence

Article 6 states that all packaging placed on the market must be recyclable. The detailed design-for-recycling criteria, assessment method, and performance grades depend on delegated acts that the Commission is due to adopt.

For current files, ask suppliers for the material and design information needed to assess recyclability and for any assessment they have already completed. As the detailed criteria become applicable, the file will need to show the relevant grade and how it was calculated.

The regulation’s main grading dates are:

• Grade A, B, or C from 2030 or 24 months after the relevant delegated acts enter into force, whichever is later
• Grade A or B from 2038
• A recycled-at-scale assessment from 2035 or later

Record which method and version the supplier used. A recyclability claim without the packaging category, components, method, and date will be difficult to defend.

5. Recycled-content evidence

Article 7 sets minimum post-consumer recycled-content percentages for plastic packaging from 2030 or later. The percentage depends on the packaging type. It is calculated per packaging type and format as an average per manufacturing plant and year.

For applicable plastic packaging, the supplier file should eventually support:

• Polymer and packaging category
• Percentage of post-consumer recycled content
• Manufacturing site and reporting period
• Origin and chain-of-custody evidence required by the calculation rules
• Calculation, verification, and any third-party audit evidence required by implementing acts

The Commission’s detailed calculation and verification rules determine the final evidence format. Until those rules are settled and applicable, collect enough structured data to identify gaps without presenting a future target as a current pass-or-fail test.

6. Compostability, reusability, and minimization

Where relevant, request:

• Compostability test reports and applicable standards for packaging covered by Article 9
• Evidence that reusable packaging meets the design, safety, reconditioning, and rotation requirements in Article 11
• The specifications, standards, tests, studies, modeling, or simulations used to justify packaging weight and volume under Article 10
• An explanation of which functional requirements prevent further material reduction

The full Article 10(1) minimization duty applies from 1 January 2030. Article 10(2), which addresses designs that only increase perceived product volume, is a separate requirement. Keep the two parts distinct when building the evidence request.

7. Standards, assessment methods, and test reports

Annex VII requires a list of the harmonized standards, common specifications, and other technical specifications used. It also requires an explanation when only part of a standard was applied or when the manufacturer used another solution.

Each supplier document should make it possible to answer:

• Which packaging, material, and revision does this cover?
• Which PPWR requirement does it support?
• Which method, standard, or specification was used?
• Is the conclusion based on testing, calculation, material knowledge, or upstream evidence?
• Who issued and approved the document?
• When must it be reviewed?

This information is an operational recommendation for maintaining a defensible file. PPWR does not prescribe those exact field names.

What belongs in the Annex VII technical file?

Annex VII uses the internal production control procedure. The manufacturer establishes technical documentation that identifies the applicable requirements and covers the design, manufacture, and operation of the packaging where relevant.

The file must include, where applicable:

1. A general description of the packaging and its intended use
2. Conceptual designs, manufacturing drawings, and component materials
3. Explanations needed to understand the drawings and packaging operation
4. The standards, common specifications, or other technical specifications used
5. A qualitative description of the recyclability, minimization, and reusability assessments
6. Test reports

The manufacturer must also analyze the risk that the packaging does not conform. Supplier evidence feeds this file, but the manufacturer has to decide whether the evidence is complete and applicable.

Who signs the EU Declaration of Conformity?

The manufacturer signs it.

Once the conformity assessment shows that the applicable requirements have been met, Article 39 requires the manufacturer to draw up and continuously update the EU Declaration of Conformity. By signing it, the manufacturer assumes responsibility for the packaging’s compliance.

The declaration identifies the packaging, the manufacturer, the applicable EU legislation, and the standards or specifications used. A supplier can prepare supporting material, and another party can carry out testing or an assessment on the manufacturer’s behalf. Those arrangements do not transfer responsibility for the final declaration.

Manufacturers must keep the technical documentation and declaration for:

• Five years after single-use packaging is placed on the market
• Ten years after reusable packaging is placed on the market

A national authority can require the manufacturer to provide the relevant information and technical documentation within ten days of a reasoned request.

Are pharmaceutical and medical-device packages exempt?

Some are exempt from particular requirements. There is no blanket PPWR exemption for pharmaceutical or medical-device packaging.

Article 6 excludes immediate medicinal packaging, certain necessary outer medicinal packaging, and contact-sensitive medical-device and in vitro diagnostic packaging from the recyclability requirements. Article 7 provides similar targeted exceptions from the minimum recycled-content requirements.

Those exceptions do not automatically cover:

• A secondary carton that is not necessary to preserve the medicinal product’s quality
• Shipping cases and other transport packaging
• Grouped packaging
• Packaging components outside the contact-sensitive or immediate package
• Article 5 substance requirements
• The general need to document why an exception applies

The technical file should identify the exact packaging component, legal exception, and evidence supporting its use. Writing “medical packaging” in a spreadsheet does not establish that the carton, tray, pouch, label, and shipper all receive the same treatment.

PPWR also provides limited labeling relief where immediate or outer medical packaging has no space because of other legal labeling requirements, or where the packaging label could jeopardize safe use. The exception depends on those conditions.

What do companies commonly get wrong?

”All PPWR requirements started in August 2026”

The regulation applies generally, but major design, labeling, recycled-content, and reuse requirements have their own dates. A useful compliance file separates requirements that apply now from future requirements that still need preparation.

”Our packaging supplier owns compliance”

The supplier owes you information under Article 16. The manufacturer remains responsible for the conformity assessment, technical documentation, and declaration.

”A one-page PPWR declaration is enough”

A declaration can summarize a conclusion. It does not replace the drawings, material data, assessment method, test reports, and other evidence needed to support that conclusion.

”Every package needs every test”

The required evidence depends on the packaging and its use. The food-contact PFAS limits do not turn every industrial shipping case into a PFAS testing project. Recycled-content requirements do not apply to paper packaging. Start by classifying the packaging and its applicable requirements.

”Medical packaging is outside PPWR”

The regulation includes narrow exceptions for defined packaging and defined requirements. The rest of the packaging system may still be in scope.

A practical supplier documentation campaign

If you are running supplier outreach, keep the evidence map next to the chase list. Use the PPWR supplier evidence request template (CSV) for what each packaging reference still needs. Use the supplier engagement campaign tracker (CSV) for contacts, follow-ups, blockers, and escalation.

1. Build a packaging inventory

List packaging by type, SKU or specification, component, material, intended use, manufacturing site, supplier, and finished product. Include primary, grouped, transport, e-commerce, and service packaging where applicable.

2. Assign PPWR roles and requirements

Identify the manufacturer and producer for each flow. Map the PPWR requirements that apply now, the requirements that apply later, and any exception that needs documented support.

3. Request evidence by packaging reference

Send suppliers a controlled request that names the packaging SKU, revision, and required documents. Avoid a generic company-level questionnaire when the evidence varies by coating, component, plant, or product use.

4. Find the person who owns the data

Sales contacts and general inboxes often cannot answer technical packaging questions. Depending on the evidence, the owner may sit in regulatory affairs, product stewardship, quality, packaging engineering, materials compliance, or sustainability.

5. Validate each return

Check that the document matches the requested packaging, material, site, and revision. Confirm that tests identify the sample and method, calculations state their basis, and claimed exceptions cite the packaging component they cover.

6. Follow up on specific gaps

“Please complete the questionnaire” gives the supplier little direction. Ask for the missing test report, unsupported polymer percentage, unidentified coating, absent revision, or unclear manufacturing site.

7. Set a change and review process

Article 15 requires manufacturers to reassess conformity when changes in packaging design, characteristics, standards, or specifications could affect compliance. Require suppliers to notify you when materials, formulations, sites, or production methods change, and reopen the technical file when they do.

TL;DR

When did PPWR begin to apply?

Regulation (EU) 2025/40 began to apply generally on 12 August 2026. Several specific requirements apply later, including harmonized labeling, minimum recycled content, and detailed recyclability grades.

What must packaging suppliers provide?

Article 16 requires suppliers to provide all information and documentation the manufacturer needs to demonstrate conformity, including applicable Annex VII technical documentation under Articles 5 through 11.

Is there a standard PPWR supplier certificate?

No universal certificate or supplier spreadsheet is prescribed. Annex VII defines the technical file the manufacturer must build. Supplier declarations need supporting evidence tied to the correct packaging and requirement.

Who issues the EU Declaration of Conformity?

The manufacturer. Supplier documents support the declaration but do not transfer legal responsibility.

How long must manufacturers keep PPWR technical documentation?

Manufacturers must keep the Annex VII technical documentation and signed EU Declaration of Conformity for five years after single-use packaging is placed on the market, or ten years after reusable packaging is placed on the market.

Is medical or pharmaceutical packaging exempt?

Certain immediate, necessary outer, and contact-sensitive packages are exempt from specific recyclability, recycled-content, or labeling requirements. The exemptions are limited and do not remove the whole packaging system from PPWR.

How Bridgecurrent helps collect PPWR supplier evidence

Bridgecurrent finds the regulatory, quality, product-stewardship, or packaging contact who owns the requested supplier evidence, sends the request, follows up until a usable return lands, and checks that each document matches the packaging reference, revision, material, and manufacturing site. Your team still decides which PPWR requirements apply, completes the conformity assessment, and signs the EU Declaration of Conformity. Book a 20-minute call and bring a packaging-supplier list. We will show you who we find and how the open document requests would move.

Sources

1. Regulation (EU) 2025/40 on packaging and packaging waste. Article 5 covers substances, Article 6 recyclability, Article 7 recycled content, Article 10 minimization, Article 11 reusability, Article 15 manufacturer obligations, Article 16 supplier information, and Articles 38 and 39 conformity assessment and declaration.
2. Commission Notice C/2026/3084: Guidance document for Regulation (EU) 2025/40. This explains manufacturer and producer roles, application dates, food-contact PFAS stock treatment, recyclability timing, minimization, and labeling.
3. Annex VII to Regulation (EU) 2025/40. This sets the technical documentation and internal production control procedure.
4. Annex VIII to Regulation (EU) 2025/40. This provides the model structure for the EU Declaration of Conformity.