Article 16 of the PPWR, Regulation (EU) 2025/40, makes a packaging supplier give the manufacturer all the information and documentation needed to prove the packaging’s conformity with the Regulation. That includes the Annex VII technical documentation. The duty has applied since 12 August 2026. The supplier does not draw up the declaration of conformity, but cannot refuse the documents.
Who counts as a packaging supplier?
Any person that supplies packaging or packaging material to a manufacturer, under Article 3(1)(16). The definition sets no condition on where the supplier is established, so a converter outside the EU is covered. The Commission’s FAQ applies Article 16 to EU importers and distributors that supply packaging material too.
The customer the duty runs to is the manufacturer, usually the brand owner whose name is on the packaging. The manufacturer and producer comparison explains who that is.
What must the supplier hand over?
That includes the technical documentation required under Articles 5 to 11:
| Article | Requirement |
|---|---|
| 5 | Substances in packaging, including PFAS in food-contact packaging |
| 6 | Recyclability |
| 7 | Recycled content |
| 8 | Biobased feedstock |
| 9 | Compostability |
| 10 | Minimisation |
| 11 | Reusable packaging |
The documents come in a language the manufacturer easily understands, on paper or electronically. For contact-sensitive packaging, such as food-contact, cosmetics or medical-device packaging, Article 16(2) adds the documents those laws require. The duty itself covers conformity with the whole Regulation. The PPWR technical documentation answer lists what Annex VII contains.
Which data are needed today?
Data for the rules that already apply. The sum of lead, cadmium, mercury and hexavalent chromium may not exceed 100 mg/kg under Article 5(4), apart from the recycled-glass derogation in Commission Decision 2001/171/EC. Food-contact packaging has PFAS limits from 12 August 2026 under Article 5(5). Data on recyclability and recycled content follow when those rules apply.
Example, with illustrative businesses: a converter outside the EU prints pouches for a Dutch coffee brand whose name is on them. The brand is the manufacturer and the converter its supplier. For pouches placed on the market in October 2026, the converter hands over a description and the material layers of each pouch. It adds heavy-metal and PFAS test results and the food-contact compliance documents.
Is the supplier responsible for conformity?
No. The manufacturer, or its authorised representative, draws up the declaration of conformity, and the manufacturer stays responsible. The Commission’s FAQ still says suppliers “can therefore not refuse” the documents. Suppliers need not appear on the packaging or add batch numbers, the FAQ adds. Under Article 22, every supplier must also name, on request, the businesses it supplied and those that supplied it. It keeps the latter for 5 years, or 10 years for reusable packaging.
Where the brand owner is a micro-enterprise, a supplier located in the same Member State is the manufacturer under Article 3(1)(13)(b). A supplier elsewhere in the Union takes the Article 15 duties under Articles 15(12) and 21.
The importer’s checks and missing supplier data are covered separately.
Sources: Regulation (EU) 2025/40 (PPWR), PPWR FAQ, 2nd edition, Commission guidance document, C/2026/3084
GreenSutra’s PPWR consulting starts with the manufacturer’s request list and matches each item to the supplier’s test reports. The EU PPWR guide covers the manufacturer’s side.