Implementation
The PPWR supplier evidence request
Last regulatory verification: 14 October 2026 · 4 official sources
What to ask packaging suppliers for under PPWR, material by material, why each item matters for the technical documentation, and how to read what comes back.
Key facts
- The manufacturer's technical documentation must show how each applicable requirement is met; much of that evidence is held by packaging and material suppliers.(S01)
- PFAS restrictions under PPWR apply to food-contact packaging from 12 August 2026.(S01)
Short answer
Most of the evidence in a PPWR technical file sits with your suppliers, not with you. A good request is specific to each component, asks for documents rather than yes/no answers, and ties each item to the requirement it supports. Vague "Are you PPWR compliant?" questionnaires get vague answers that can't go in a file.
Ask per component, not per supplier
One supplier may make three components of one product. List each component, such as the bottle, closure, label and outer carton, and ask for evidence for each one. A statement covering "all our products" rarely says which grade, coating or ink you actually bought.
What to ask for, by material
| Material | Evidence to request |
|---|---|
| Plastic | Polymer type per layer, additives and colourants, substances of concern statement, recycled content claims with their basis, and food-contact compliance where relevant. |
| Paper and board | Fibre source, coatings and barrier layers, inks and adhesives, PFAS statement for food-contact grades, and the recyclability of any laminated structure. |
| Glass | Glass type and colour, closure and decoration materials, and heavy-metal statement. The closure usually needs its own evidence. |
| Metal | Alloy and lacquer or internal coating, coating substances for food contact, and any non-metal components such as seals. |
| Composite / multi-material | Every layer with its material and weight, how the layers are bonded, and whether the layers separate in recycling. |
| Labels, inks, adhesives | Substance statements and whether they affect recycling of the main packaging. These are often the biggest gap in a file. |
Every request should also cover
Exact identification
Supplier article number, grade or specification, so the statement matches what you buy.
Date and validity
When the statement was issued and what change would make it outdated.
Signatory
A named person responsible at the supplier, not an unsigned template.
Change notification
A commitment to tell you before changing material, coating, ink or sub-supplier.
A request text you can reuse
We are preparing technical documentation under Regulation (EU) 2025/40 (PPWR) for the products listed below. For each component you supply, please provide: (1) the material composition by layer, including coatings, inks and adhesives; (2) a signed statement on substances of concern, including PFAS where the component is used for food contact; (3) food-contact compliance documentation where relevant; (4) the basis for any recycled-content claim; and (5) confirmation that you will notify us before changing the material, specification or sub-supplier. Please reference your article number on each document.
Reading what comes back
Received evidence is not automatically proof. Check that each document names the right article, is signed and dated, and actually covers the requirement. A food-contact declaration, for example, is not a PFAS statement. Common gaps are missing ink and adhesive data, statements for a different grade, and recycled-content claims with no stated method. See PFAS in food-contact packaging and substances of concern for what those statements must cover.
When suppliers don't respond
When documents arrive incomplete
- Accept what is usable and file it against the right component.
- Send one specific follow-up listing exactly what is missing, by item.
- Record the gap in the file with the supplier, date requested and requirement affected.
- If it stays open, decide: commission a test, replace the component, or document why the requirement does not apply.
Who sends the requests
In our projects we draft the requests per supplier and material, and you send them — your suppliers know you, which usually means faster answers. Where you authorise it and it is in the agreed scope, we can coordinate with suppliers directly.
Coordinating suppliers across a portfolio is the core of our managed PPWR service. Evidence then goes straight into the Annex VII technical documentation.
Official sources for this page
Every statement above is written against these sources. Where a Commission document and the Regulation differ, the Regulation controls.
- Regulation (EU) 2025/40 — EUR-LexBinding law
- Commission PPWR GuidanceCommission guidance
- ECHA activities under PPWROfficial implementation / research
- EFSA Food Contact MaterialsOfficial implementation / research
- Sources last verified
- 14 October 2026
- Content last updated
- 14 October 2026
- First published
- 14 October 2026
Written and maintained by the PPWRDeclaration.com editorial team. General information about Regulation (EU) 2025/40 — not legal advice.
Why this matters
What happens if the documentation isn't there
The packaging can be restricted
Packaging without valid technical documentation is treated as non-compliant. Market surveillance authorities can require corrective action, restrict sale, or withdraw it from the market.
Penalties apply per Member State
Each Member State sets its own penalties for non-compliance, and they apply where the packaging is placed on the market — not where your business sits.
Buyers block you first
Retailers, distributors and importers increasingly ask for the Declaration and supporting evidence before onboarding. No file usually means no listing.
Late evidence costs more
Supplier declarations and lab testing have long lead times. Discovering a gap close to a deadline forces rushed testing or packaging redesign.