For manufacturers, importers and own-brand owners
You collect supplier evidence in one place, and the app tracks deadlines and puts the declaration together.
What changed
From that day Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation (PPWR), applies. For manufacturers, importers and brands that place packaging on the market under their own name it changes four things.
You can be the manufacturer of the packaging even if you do not produce it. It is enough that you have it designed or manufactured under your own name or trademark (Article 3(13)). The exception is a micro-enterprise whose packaging supplier is based in the same Member State. In that case the supplier is the manufacturer.
Before placing packaging on the market you must have two documents. The first is technical documentation including a risk analysis, the second is an EU declaration of conformity for each type of packaging (Article 15, Annex VII). The declaration must be in the language required by the country where you sell (Article 39).
When an authority asks, you have 10 days to provide the documents. Calendar days, not working days (Article 15(10)). Documents must be kept for 5 years, or 10 years for reusable packaging.
Marketplaces add their own layer. Allegro asks for a separate EPR number for each country you ship to and for a declaration that your packaging meets EU requirements.
Who this is for
The obligation does not depend on the size of your company or on whether you run your own production. It depends on your role: whether you make the packaging, place it on the market under your name, import it or sell it.
You make packaging. You are the manufacturer, so you carry out the conformity assessment and draw up the technical documentation and the EU declaration of conformity (art. 15). You issue the documents to your customers too.
You own the brand and buy the packaging. Supplements, cosmetics, food, household chemicals. Production may sit at your supplier, but the trademark on the label is yours, so you are the packaging manufacturer (art. 3(13)). Gift sets and shipping cartons with your print are packaging placed on the market too.
You import goods from outside the European Union. Before placing packaging on the market, an importer makes sure the manufacturer has done the conformity assessment and the technical documentation, and that the required documents accompany the packaging (art. 18(2)). It keeps a copy of the declaration for 5 years and gives an authority the documentation within 10 days of a request (art. 18(7) and (8)). If you import under your own name or trademark, you are the manufacturer (art. 21).
You sell other companies' products in ready-made packaging. Before making packaging available, a distributor checks the labels and whether the manufacturer and the importer have met their obligations (art. 19(2)). At an authority's request it provides the documentation it has access to (art. 19(6)). If you sell under your own name, a manufacturer's obligations pass to you (art. 21).
In the free review we will check which role your company has and whether the app is useful to you. The manufacturer documents, the importer and the distributor verify, and they all keep the manufacturers' documents in one place.
10
days to provide the documents after an authority's request. Calendar days, not working days.
Article 15(10) Regulation (EU) 2025/40
What we find in supplier documents
Packaging suppliers are obliged to give you the information you need to demonstrate conformity (Article 16). They usually send something, but it is often not a document that proves your packaging conforms.
DECLARATION OF CONFORMITY · Supplier X · version 1 · fictional example
Dear Customer, 6
Sometimes a technical drawing arrives instead of a declaration.
No list of the products this declaration covers.
Composition adds up to 63%, the weight cannot be calculated for BDO.
"Not for food contact" on a supplement’s packaging.
PFAS test performed on a different item and colour.
Liner excluded from the scope of the declaration.
A general letter, without naming your labels.
A supplier's declaration is evidence in your documentation, not your declaration. The EU declaration of conformity is signed by the manufacturer, often the brand, and the manufacturer takes responsibility for it (Article 39(4)).
Three documents
In the documents we get for review there is usually the third one and neither of the first two. The supplier paper has been sitting in the inbox for years, so the subject looks closed. It is not.
Description of the packaging, list of components and materials, weights, evidence for every requirement and test results. You draw it up on your own responsibility and keep it. Market surveillance can ask for it without notice, and you then have 10 days.
A statement signed by the manufacturer, one per type of packaging, in the language of the country you sell to. The template is fixed and the order of the points is binding, so a buyer checks it at a glance.
Declarations, material data sheets, test reports. Your supplier has to hand them over, but they do not replace the first two. They are the material your documentation is built from, not the documentation itself.
Packaging anatomy
Each component has its own supplier and its own documents. You issue the declaration of conformity for the whole.
Cap
Induction liner
Bottle
Label
Tube
Shipping carton
How we work
A register, supplier requests, technical documentation and BDO from the same data.
Bottle, cap, liner, label, tube and shipping box are separate components from separate suppliers. We describe each one once: material, weight, documents, gaps.
Components are combined into the packaging types that each need a declaration. The same bottle used in five products is a single entry in the register.
Every supplier receives a specific request for the missing documents, citing their obligation under Article 16. We track deadlines. If a supplier stays silent, you keep a documented record of your efforts.
For each packaging type we prepare technical documentation with a risk analysis, and on that basis the EU declaration of conformity in the required languages.
BDO is the Polish waste database with an annual packaging report. We take packaging weights from the same data, so the report is based on actual figures rather than estimates.
We work on our own component register. Each component is described once and every change at a supplier is dated. The data is yours, and a full export is free of charge.
How much of it there is
The most common reason companies postpone PPWR is the belief that there will be as many documents as there are lines in the price list.
Types of packaging count, not products. The same bottle with the same closure and the same label in ten flavours is one type of packaging. Changing the flavour does not change the packaging.
A new material creates a new type, a new print usually does not. Swapping glass for PET or fitting a different closure gives you a new type and a new declaration. A different print colour on the same label usually does not.
That is why the subscription is priced per type of packaging. Ten types in the lowest tier, whatever the number of items in your catalogue. We do not charge per supplier or per user. A long catalogue can collapse into a handful of types, but how many there are shows only once the packaging has been reviewed.
The time goes into collecting evidence, not into issuing declarations. One type of packaging means several components from several suppliers, and each component is a separate set of documents to obtain and check. That work stays on our side.
A declaration is issued per type of packaging, not per product. The first thing we do in the free review is to reduce your catalogue to a list of types.
Pricing
We start with a free documentation review. Then you choose: the app you run yourselves, the done-for-you service with an account manager, or the audit only. Pay yearly and get 2 months free.
You work in the app yourselves and suppliers upload documents via a link.
The app plus an account manager who runs the documentation for you.
Readiness check
Six questions take about two minutes. Your answers are not sent anywhere.
Your result appears once you answer all the questions. Book a free review
What we do not do
We organise the documents. Testing, registrations and the signature stay with those responsible for them.
We do not run laboratory tests. If supplier documents are missing and a test is needed, we arrange it with an accredited laboratory. Whoever ordered the packaging pays for the test.
We do not register you in EPR schemes abroad. We prepare the data used by the company that does.
We do not replace your environmental consultant. If you have one, we work alongside them. We organise the data and documents, they are responsible for interpreting the law.
We do not sell a subscription when it does not pay off for you. With one type of packaging, one supplier and complete documents, a spreadsheet plus a solid procedure is enough. We say so in the first conversation and leave you with a checklist.
We do not sign the declaration for you. Nobody except the manufacturer can. Our job is to bring the documentation to a state where that signature is backed by evidence.
Kto za tym stoi
Lajf sp. z o.o. organises compliance documentation for companies that do not have their own department for it. We build the aPPWR app, in which you keep the documentation yourselves. If you would rather hand it over, we collect documents from suppliers, check them, prepare the declarations and keep track of deadlines for you.
Lajf sp. z o.o. · KRS 0001265327 · NIP 632-204-51-64 · kontakt@ppwrdlafirm.pl · +48 880 133 640
From the guide
Who is the packaging manufacturer under PPWR: brand, contract manufacturer, importer or wholesaler, and how it differs from a national EPR producer.
Read →PPWR gives a manufacturer 10 days to show technical documentation and the declaration to an authority. What it can ask for and how to prepare.
Read →When a supplier declaration for a bottle or a closure is enough under PPWR, when it is not, and what it has to confirm. Includes the micro-enterprise exception.
Read →FAQ
No. A supplier's declaration covers their item, while you are responsible for the whole packaging of your product, which consists of several components. Supplier documents are evidence in your technical documentation. On that basis you draw up your own declaration.
Your consultant knows the law. Collecting documents from a dozen suppliers, checking them and keeping them up to date takes weeks, and consultants rarely have capacity for it. We do that part, and interpretation stays with your consultant.
No. BDO is the Polish register and annual report on the weight of packaging placed on the market. PPWR sets EU requirements for the packaging itself and the documents that prove it. Much of the data is the same, which is why we handle both together.
The declaration must be in the language required by the country of sale. On top of that comes EPR registration in each country you ship to. Registration is done by a specialised company. We supply the data and documents in the languages needed.
The audit takes 5 working days from receiving the documents. Implementation depends mainly on how quickly suppliers respond. We give a timeline in the quote after the audit.
One per packaging type, not per product. The same bottle with the same cap in ten flavours is usually one packaging type. A new material or a new component usually means a new type.
No. A micro-enterprise buying its packaging in Poland may not have this obligation at all. With one or two packaging types, an audit and a well-kept spreadsheet are sometimes enough. We will tell you so in the free review.
Because documentation ages. Supplier declarations are usually valid for a year, suppliers change materials and you add new products. The app shows which documents are out of date, and the set is always ready for an inspection within 10 days.
Usually not. Conformity is demonstrated first with documents from the supply chain. A test is needed when those documents are missing or do not cover your item.
We repeat the request with a deadline, citing Article 16 PPWR. If that does not help, you have a documented record of your efforts, and our report indicates whether it is worth considering another supplier.
The manufacturer draws up the declaration. Before placing packaging on the market, an importer makes sure the manufacturer has done the conformity assessment and the documentation, keeps a copy of the declaration and provides the documentation within 10 days of an authority's request (Article 18). A distributor checks the labels and that the manufacturer and the importer have met their obligations (Article 19). If you sell under your own name or trademark, or modify the packaging, a manufacturer's obligations pass to you (Article 21). In the app you keep the manufacturers' documents in one place, with their expiry dates.
The manufacturer. Usually that is the brand, but it can also be a packaging producer that places the packaging on the market. The exception is a micro-enterprise whose packaging supplier is based in the same Member State: then the supplier is the manufacturer. The manufacturer takes responsibility for the conformity of the packaging and cannot transfer the obligation to draw up technical documentation to anyone else.
Contact
The call takes 30 minutes and comes with no obligation. Tell us how many products you have and where you sell. We will reply within one working day.