PPWR: what packaging data should you request from suppliers?

The Packaging and Packaging Waste Regulation, PPWR, is Regulation (EU) 2025/40. Its general application date is 12 August 2026. This does not mean every requirement on labelling, recyclability or recycled content starts at the same time. Read the specific provision, any supplementary acts and conditions for the packaging concerned. Article 71 and relevant substantive provisions.

Establish your role in the chain. Manufacturer and supplier duties differ. Article 15 also contains special provisions, including paragraphs 11–12, that need assessment where relevant. This guide starts data collection; it is not a complete producer-responsibility assessment or recyclability classification.

Identify two special cases early. Article 15(11) exempts certain custom-made transport packaging for configurable medical devices and medical systems intended for industrial and healthcare environments from the duties in Article 15(2)–(3). Under Article 15(12), the packaging supplier must instead be considered the manufacturer for the purposes of Article 15 where the person having packaging designed or manufactured under their own name or trademark is a micro-enterprise and the supplier is located in the Union. Here, micro-enterprise means the definition in Recommendation 2003/361/EC as applicable on 11 February 2025. Check the conditions before assigning the work. The Swedish wording of Article 15(12) was corrected from “the same Member State” to “the Union”. Swedish corrigendum to Article 15(12).

Choose an actual packaging version: for example the box, insert, bag, tape and label used for a particular product delivery. Describe their functions and how they work together. Photographs of the actual set can support the work.

The following matrix is our recommended starting point. Adapt the fields to the packaging and requirements you are working with.

Manufacturers may only place packaging on the market if it meets the applicable requirements in Articles 5–12. Before placing it on the market, the manufacturer must prepare the technical documentation and carry out or arrange the conformity assessment under Article 38 and Annex VII. Once conformity with the applicable requirements has been demonstrated, the manufacturer must draw up an EU declaration of conformity under Article 39 and Annex VIII. Take account of the special case in Article 15(11) described above. A completed material list replaces neither the technical documentation, the assessment nor the EU declaration. Articles 15(1)–(2) and 38–39.

Annex VII describes documentation including a general description and intended use, design and materials, explanations, specifications or solutions applied, and relevant assessments and test reports where applicable. Documentation must also identify applicable requirements and include an adequate analysis and assessment of the risks of non-conformity. Annex VII.

Add an assessment record alongside the data matrix: requirement reference, application date, affected part, evidence, conclusion, gap and owner. These are recommended working fields. A weight value or a supplier’s “recyclable” claim alone does not establish compliance with a particular requirement.

Suppliers of packaging or packaging materials must provide the manufacturer with all information and documentation necessary to demonstrate conformity with the Regulation. This includes the technical documentation set out in Annex VII and required under Articles 5–11. It must be provided on paper or electronically, in a language the manufacturer can easily understand. Article 16(1).

Request evidence for an identified part and revision, not just a brochure about the supplier’s sustainability work. State which materials or designs are concerned and which assessments the information should support.

On receipt, distinguish what has arrived, what has been reviewed and what is missing. Retain the supplier’s wording and limitations. If information concerns another grade or period, make that visible before using it.

Suggested request

We are collecting documentation for packaging [ID and revision], used for [product and intended use]. Please confirm that your response covers part [supplier part number and version].

1. Identify the parts and materials, including relevant coatings, adhesives and additives in the material specification.
2. State the mass of each part in grams, how it was determined and any tolerances.
3. Attach specifications, relevant assessments and test reports for [state the requirements to be assessed]. Identify the material, part and version covered by each document.
4. Explain the limitations of the evidence. Flag information that is missing or not yet verified and when you can provide it.
5. Provide a contact person, document date and how you will notify us of changes to materials, design or supplier.

This is a working template for your request. Adapt it to applicable requirements; the list does not mean each requested data point is a separate legal requirement.

Hypothetical example: A product keeps the same outer box, but its protective insert changes from plastic to a fibre-based alternative. The supplier describes the change as more sustainable.

Create a new packaging revision and record the new insert’s material, mass, supplier and evidence. Check which previous assessments are affected and whether the packaging remains suitable for its intended use. If the change could affect conformity, the manufacturer must carry out a reassessment under Article 38. Article 15(4).

The conclusion should follow from the review, not the material name. A change may be an improvement without automatically proving PPWR conformity. Keep a record of what was checked and which questions remain.

An initial record could look like this. All names, codes and values in this example are fictional.

Record “missing” where evidence is missing. A blank field or a received material specification should not be treated as a completed packaging assessment.

1. Choose one product and its current packaging version.
2. Lay out all parts and complete the data matrix.
3. Link each factual entry to evidence or mark it unconfirmed.
4. Establish the role, requirements and relevant application dates.
5. Review evidence against requirements and prioritise gaps.
6. Assign an owner, a response deadline and a next step to each gap. Decide who will make the decision if the missing information is not provided.
7. Decide which changes trigger reassessment.

The result should be identified packaging, traceable facts and a concrete list of remaining assessments. This is a more useful basis for the next decision than an overall status without evidence.