If you make packaging and sell it to a brand, the PPWR gives you a role with its own name: supplier. You do not sign the declaration of conformity, but your customer cannot sign it without your data, and the Regulation requires you to provide it. This article explains what that data is, material by material, and which parts depend on rules the Commission has yet to adopt.
Short answer
- A supplier is anyone who supplies packaging or packaging material to a manufacturer (Art. 3(1)(16)). It must give the manufacturer all the information and documentation needed to demonstrate conformity, including the Annex VII technical documentation (Art. 16(1)).
- The one who signs the declaration and keeps the file for 5 years (10 if reusable) is the manufacturer, normally the brand (Arts. 15 and 39).
- The Regulation applies from 12 August 2026 (Art. 71). Already enforceable: the limit on metals and the PFAS limits for food-contact packaging.
- With their own deadlines: recyclability (2030 or 24 months after delegated acts), recycled content in plastic (2030 or 3 years after an implementing act) and harmonised labelling (12/08/2028 or 24 months after an act).
- No notified body and no third-party certificate are required for recyclability: the manufacturer assesses it (Art. 6(3)).
Are you a supplier or a manufacturer?
Your role depends on who you sell to and under whose name the packaging is placed on the market. This table summarises the usual cases under the definitions in Art. 3(1)(13) and (16).
| Your situation | Your role | What you must do |
|---|---|---|
| You sell packaging to a brand that fills it and markets it under its own name | Supplier (Art. 3(1)(16)) | Give the brand the information and documentation needed to demonstrate conformity (Art. 16(1)) |
| You design or make the packaging, or the packaged product, under your own name or trademark | Manufacturer (Art. 3(1)(13)(a)) | Conformity assessment, technical documentation, EU declaration and retention (Art. 15). See our article on the EU declaration of conformity |
| Your customer is a micro-enterprise with its own brand and you are established in the Union | Manufacturer for the purposes of Art. 15 (Art. 15(12)) | Art. 3(1)(13)(b) («the same Member State») and Art. 15(12) («in the Union») do not match: confirm the scope with an adviser |
| You sell neutral catalogue packaging that the customer uses without your name | Manufacturer of the packaging, under the first sentence of Art. 3(1)(13) and the view of Ecoembes (13/07/2026) | The Art. 15 obligations for that packaging (declaration and file). For made-to-measure packaging with no brand, that source assigns the role to whoever orders it and sets the specifications. The text is less explicit: agree in writing who takes each role and confirm with an adviser |
The data your customer will ask you for
Art. 16 does not list the data: it says you must supply what the manufacturer needs to demonstrate compliance with Articles 5 to 11 and to complete the Annex VII file. Turned into a per-reference sheet, this is what comes out of the text:
| Data | Basis | When it is enforceable |
|---|---|---|
| Description of the packaging and its intended use; design and materials of each component | Annex VII, point 2(a)-(c) | From 12/08/2026 |
| Sum of lead, cadmium, mercury and hexavalent chromium in the packaging and its components: maximum 100 mg/kg | Art. 5(4) and 5(6) | From 12/08/2026 |
| PFAS, food-contact packaging only: below 25 ppb for any PFAS (targeted analysis), 250 ppb for the sum and 50 ppm in total (polymeric PFAS included). If total fluorine exceeds 50 mg/kg, proof of the quantity of fluorine, on request | Art. 5(5) and 5(6) | From 12/08/2026 |
| Documentation required by other Union acts for contact-sensitive packaging (for example food contact) | Art. 16(2) | Depends on each act |
| Design data to assess recyclability (grade A, B or C) | Art. 6(3) | 1/1/2030 or 24 months after the delegated acts, whichever is later |
| Percentage of post-consumer recycled content in each plastic part, calculated as an average per manufacturing plant and year, with the origin of the waste | Art. 7(1) and 7(3) | 1/1/2030 or 3 years after the implementing act of Art. 7(8), whichever is later |
| Tests and data justifying the minimum weight and volume | Art. 10(1) and 10(4) | From 1/1/2030 |
| Compatibility with industrial composting, if the packaging is one of those in Art. 9(1) | Art. 9(1) | 12/02/2028 |
| Material composition of each component, for the harmonised label | Art. 12(1) | 12/08/2028 or 24 months after the act, whichever is later |
| Who supplied you (5 years of history, 10 for reusable) and whom you supplied | Art. 22 | From 12/08/2026, on request of the authority |
Two remarks so you do not spend effort needlessly. First: the recycled content of Art. 7 applies to «any plastic part» of the packaging, so a plastic cap, window or lamination on a paperboard pack also counts, unless that part weighs less than 5 % of the total weight of the packaging unit (Art. 7(5)(b)). Second: compostable plastic is outside Art. 7 (Art. 7(4)(e)).
What changes by material
The limits on substances apply to every material and to each component. The other requirements weigh differently depending on the material.
| Material | Specific data your customer will ask for | Where it usually gets complicated |
|---|---|---|
| Plastic (rigid and flexible) | Metals (Art. 5(4)); PFAS if for food (Art. 5(5)); post-consumer recycled content per plant and year (Art. 7); layer-by-layer structure to assess recyclability (Art. 6(3)) | Multilayer structures: every layer is a data point. Recycled content requires tracing the origin of the waste (Art. 7(3)) |
| Paperboard and paper | Metals and, for food contact, PFAS from barriers and coatings (Art. 5(4)-(5)); plastic parts (windows, laminations) for Art. 7 | The barrier coating: if it contains fluorinated substances, the PFAS limit applies to the packaging |
| Glass | Metals (Art. 5(4)); data on the cap, label and capsule, which are components of the packaging; recyclability (Art. 6) | A plastic cap or label: it falls under Art. 7 unless it weighs less than 5 % of the total weight of the packaging |
| Metal (cans and lids) | Metals (Art. 5(4)); PFAS in the inner coating if for food contact (Art. 5(5)); recyclability (Art. 6) | The inner coating: ask your lacquer supplier for the metals and fluorine proof |
How to organise it: five steps for this week
- Separate your references into those that go into food contact and those that do not: only the first have the PFAS limit.
- Create one sheet per reference with the rows of the data table. It is a working proposal; the Regulation sets the content, not the format.
- Ask your suppliers of raw material, inks, adhesives and lacquers for metals tests and fluorine proof. When total fluorine exceeds 50 mg/kg, Art. 5(5)(c) requires the manufacturer, importer or downstream user of the substance (in the REACH sense) to give that proof to the manufacturer or importer of the packaging who asks for it; having it lets you pass it on to your customer.
- Agree with each customer on the format of delivery and on who gives notice of a change of material, design or supplier: the manufacturer must reassess when design or characteristics change (Art. 15(4)).
- Keep a record of who supplies you (5 years; 10 for reusable) and whom you supply, with dates (Art. 22).
Example: the sheet for a flexible pouch
This is how the sheet for one reference would look, with the data that can be given today and what is noted as pending. The data are fictitious; they show the level of detail, not text to copy.
| Field | Illustrative example |
|---|---|
| Reference and use | BF-250 · pouch for roasted coffee · food contact: yes |
| Structure and weight | Three-layer laminate (PET, aluminium and PE); 9.8 g per unit; thickness and weight of each layer in the technical sheet |
| Metals (Art. 5(4)) | Lab report no. 2026-0412: sum of Pb, Cd, Hg and Cr VI below 100 mg/kg |
| PFAS (Art. 5(5)) | Report no. 2026-0413: below 25 ppb per PFAS, 250 ppb for the sum and 50 ppm in total; ink and adhesive supplier identified |
| Recycled content (Art. 7) | «No data»: not enforceable until 2030 or 3 years after the implementing act; updated once the methodology exists |
| Recyclability (Art. 6(3)) | Grade pending the delegated acts; the layer structure is kept to assess it |
| Labelling (Art. 12) | Pending the implementing act; material composition available |
| Change control | Version 1 · 05/11/2026 · customer notified of any change of material, design or supplier |
What the Regulation does not require of you
- Signing the declaration of conformity, if you are a supplier: the manufacturer signs it (Arts. 15 and 39).
- A notified body: the procedure is the internal production control of Annex VII, module A.
- A third-party recyclability certificate: the manufacturer assesses it (Art. 6(3)).
- An official supplier-sheet format: Art. 16 sets what to provide, not how.
What is not settled yet
Several rules depend on acts that the Commission must adopt. Before redesigning anything, check on EUR-Lex whether they are already published. At the end of September 2026, FoodNavigator (28/08/2026) and PPWR Connect (September 2026) reported that the harmonised label of Art. 12(6), with a legal deadline of 12/08/2026, had not yet been adopted and that adoption was expected in the fourth quarter. These are secondary industry sources and have not been confirmed on EUR-Lex.
| Act | Legal deadline | What changes for you |
|---|---|---|
| Harmonised label and digital marking methodology for material composition (Art. 12(6)-(7)) | 12/08/2026 | Which material composition you will have to declare for the label |
| Methodology for calculating and verifying recycled content (Art. 7(8)) | 31/12/2026 | How to prove the recycled percentage and in what format |
| Design-for-recycling criteria and grades (Art. 6(4)) | 1/1/2028 | When you will be able to assign grade A, B or C to each pack |
| Penalty regime of each Member State (Art. 68(1)) | 12/02/2027 | Which fine applies to an incomplete declaration or file |
The Commission has also published a guidance document on the Regulation (June 2026) and frequently asked questions (July 2026), as reported by the Packaging Cluster of Valencia (05/08/2026). This article is based on the text of the Regulation and does not cover those documents in full: consult them for doubtful cases.
And if your customers already ask you for this data
Retexcycle's free PPWR assessment helps you identify your role and the obligations that apply to you, and the PPWR Compliance Hub organises the documentation per reference: who issues each document, its status and when it expires.
Frequently asked questions
Am I a supplier or a manufacturer under the PPWR?
A supplier is anyone who supplies packaging or packaging material to a manufacturer (Art. 3(1)(16)). A manufacturer is whoever puts its name or trademark on the packaging or on the packaged product, even if someone else makes it (Art. 3(1)(13)(a)). If you sell packaging to a brand that uses it under its own name, you are a supplier. If you sell generic packaging with no brand, the first sentence of Art. 3(1)(13) makes you the manufacturer of that packaging, and Ecoembes reads it that way; the text does not detail it, so agree in writing who takes each role and confirm with an adviser.
Do I have to sign the declaration of conformity if I am a supplier?
No. The manufacturer draws up the declaration and, by doing so, assumes responsibility for compliance (Art. 39(4)). What the Regulation requires of you is to give it the information and documentation needed to demonstrate it (Art. 16(1)).
What happens if I do not give the information to my customer?
Art. 16 is a supplier obligation. In addition, if the manufacturer's technical documentation is not available, is incomplete or contains errors, the Member State must require the operator concerned to put an end to the non-compliance (Art. 62(1)(d)). Penalties are set by each Member State, which must adopt them before 12 February 2027 (Art. 68(1)); there are no verified amounts.
Is a third-party recyclability certificate needed?
The text does not require one. The manufacturer assesses recyclability using the acts the Commission adopts and expresses it in grades A, B or C (Art. 6(3)). Those delegated acts must be adopted before 1 January 2028 (Art. 6(4)), so the official criterion for assigning a grade does not exist yet.
From when do I need to have this data?
The Regulation applies from 12 August 2026 (Art. 71). The limits on metals and PFAS apply from that date; recycled content, recyclability and harmonised labelling have their own deadlines, which depend on Commission acts.
What if my customer is a micro-enterprise?
If the brand is a micro-enterprise and the supplier is in the Union, the supplier is considered the manufacturer for the purposes of Art. 15 (Art. 15(12)). The manufacturer definition in Art. 3(1)(13)(b) requires it to be in the same Member State. The two texts do not match: ask for confirmation before assuming you sign the declaration.
How long must I keep the data on whom I supply?
If the authority asks, you must be able to identify who supplied you with packaging for 5 years (10 for reusable) from the date of supply, and also whom you supplied (Art. 22); the text sets the period only for the former. The declaration and technical file are kept by the manufacturer for 5 or 10 years (Art. 15(3)).
Keep reading
- PPWR EU declaration of conformity: model, content and technical file
- PPWR in packaged food: what each packaging format requires
- Private label and the PPWR: what to ask your packaging supplier
- PPWR 2026: what the Packaging Regulation requires from 12 August
Verified on 5 November 2026 against the official English text of Regulation (EU) 2025/40 (Arts. 3, 5, 6, 7, 9, 10, 12, 15, 16, 22, 39, 62, 68 and 71 and Annex VII). General information, not legal advice. The recommendations in this article (sheets, clauses, internal deadlines) are Retexcycle working proposals, not text of the Regulation. Source: Regulation (EU) 2025/40.
