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Packaging supplier evidence checklist for PPWR

Practical guide

A focused reading of the regulation, translated into practical documentation decisions.

PPWR guideReviewed 6 September 2026Based on primary sources

Short answer: Packaging suppliers do not discharge the manufacturer’s conformity duty, but their controlled evidence is often essential. Evidence should identify the supplied component or packaging version, state what was assessed, describe the method and remain traceable to the material actually supplied.

Identity and specification

  • Supplier legal entity and manufacturing location where relevant.
  • Part number, version, batch or other controlled identifier.
  • Component description, material composition and weight.
  • Layer, coating, ink, adhesive and closure information where applicable.
  • Intended application and limitations.

Substance evidence

Ask for evidence addressing the relevant heavy-metal and other Article 5 requirements. For food-contact packaging, the PFAS evidence should state the scope, analytical or assurance method, detection limits where testing is used, the packaging version and the date. “PFAS free” without a definition or evidence trail is not a complete conformity basis.

Performance and design evidence

Collect the calculations, test reports and design data needed for the manufacturer’s applicable-requirements assessment. Evidence must be interpreted in the finished packaging context; a resin or paper certificate alone may not establish conformity of a converted, printed or assembled pack.

Document controls

  • Issue date, revision and approval.
  • Clear scope and exclusions.
  • Referenced methods and standards.
  • Change-notification commitment.
  • Retention and retrieval contact.
  • Link between evidence and delivered part number.

Customer handover

Provide a structured evidence index rather than an unlabelled archive. Clearly distinguish facts supplied by the supplier from conformity conclusions reserved for the PPWR manufacturer. A useful handover lets the customer update the file when a material, formulation, plant, process or sub-supplier changes.

Official sources

  • Regulation (EU) 2025/40 — Articles 5, 15 and Annex VII
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