A supplier declaration and PPWR: is it enough?

Who is responsible for the packaging

PPWR, Regulation (EU) 2025/40, applies from 12 August 2026. It makes the manufacturer responsible for the packaging. If you have it designed or made under your own name or trademark, you are the manufacturer (Article 3(13)). It does not matter that someone else made the bottle.

Before placing the packaging on the market, the manufacturer must check it conforms, draw up technical documentation and sign an EU declaration of conformity (Article 15(2)). Signing the declaration means taking responsibility for the packaging (Article 39(4)).

The exception for very small companies

If your company employs fewer than 10 people and has a turnover of up to EUR 2 million, it is a micro-enterprise. When such a company buys packaging from a supplier in the same country, the supplier is the manufacturer (Article 3(13)(b)). The supplier then produces the documents.

Article 15(12) refers to a supplier anywhere in the Union, not just the same country. Until there is official guidance, it is safer to stick to the narrower reading.

The exception does not apply when the packaging comes from outside the Union, for example from China. The Regulation also does not say clearly what happens when the bottle, closure and label come from different suppliers. In that situation, ask an adviser before assuming the obligation does not apply to you.

Why one declaration is not enough

A bottle supplier's declaration covers only the bottle. Your packaging is usually a bottle, a closure, a liner, a label and a carton. Each part often comes from a different supplier.

The declaration of conformity covers the whole packaging (Annex VII, point 4). It has to be backed by documents for every one of its parts. Supplier documents are evidence in your technical documentation. No supplier will do the risk analysis for the whole packaging for you.

What a supplier document has to confirm today

Most PPWR requirements start to apply from 2030 at the earliest. That covers recyclability grades, recycled content and minimisation. Two requirements from Article 5 already apply.

• The sum of lead, cadmium, mercury and hexavalent chromium cannot exceed 100 mg/kg (Article 5(4)).
• Packaging in contact with food cannot exceed the PFAS limits: 25 ppb for a single PFAS substance, 250 ppb for the sum of PFAS, and 50 ppm for total fluorine (Article 5(5)).
• If total fluorine exceeds 50 mg/kg, the supplier must show, on your request, how much of that is PFAS.

Common problems in supplier documents

Suppliers usually send something. Often that document does not actually confirm your packaging conforms.

• The declaration does not name the items it covers.
• The composition does not add up to 100%, so the weight cannot be calculated.
• A supplement's packaging has a note saying "not for food contact".
• The PFAS test was done on a different item or a different colour.
• The closure declaration does not cover the liner.
• The letter is generic and does not name your labels.
• A technical drawing arrives instead of a declaration.
• The declaration covers the sack the supplier ships the goods in, not the item itself.

When a supplier declaration is enough

It is enough on its own only when the supplier is the manufacturer, under the micro-enterprise exception. In every other case you need it, but it is not enough by itself.

It is useful when it names the exact item you buy. It also has to cover heavy metals and PFAS for that item, and the whole component, including the liner or any printing.

Check the dates. Many declarations are valid for a year, provided the composition or construction has not changed. Documents need renewing every year.

What to do when a supplier does not reply

Suppliers are obliged to give you all the information you need to demonstrate conformity (Article 16(1)). Cite this provision in your request, set a deadline and keep a record of every attempt to contact them.

Suppliers outside the Union often find it easier to sign a ready-made statement than to write their own. Prepare one in English, asking about material, weight, heavy metals and PFAS.

Don't leave this until the last moment. On an authority's request you have only 10 days to show the documents (Article 15(10)). These are calendar days, not working days.