PPWR at a merchant or a printer: what customers ask for since August 2026

Where you stand in the chain

Mill, merchant, printer or converter, brand owner, retailer: the PPWR runs along this chain. The brand owner that fills the packaging is normally the manufacturer with the file and the declaration (Art. 15). Everyone upstream of it is a supplier with an information duty (Art. 16). Everyone downstream is a distributor with a checkpoint duty (Art. 19).

A merchant is a distributor when it resells finished packaging, and a supplier when it sells board or paper to a converter. A packaging printer or converter is a supplier to the brand owner for everything it makes to order, and the manufacturer for stock packaging it sells under its own name. A commercial printer of brochures and books is outside the PPWR for its products, with producer duties only for the transport packaging it ships in.

What your customers now ask for

The request arrives by mail and reads the same everywhere: send us the data sheet, the PPWR information and the food-contact declaration for this grade. Behind it is the brand owner's file: it needs your material identified, its composition, the heavy-metal statement with the report (Art. 5(4)), the PFAS statement for food contact (Art. 5(5)), the standards and, where the material touches food, the declaration of compliance. Some retailers now ask for it per batch.

What you hold is the mill's or the ink maker's documents: in their layout, often in another language, with their name on them. The customer wants yours.

What happens if you do not

The pressure comes from customers before authorities. A missing document holds up a shipment regardless of any deadline, because the brand owner cannot place packaging on the market without its file. Authorities follow: Germany's packaging act has applied since 12 August 2026 with fines up to 10 000 euro per breach of the manufacturer's, importer's and distributor's duties; Poland's implementing act is a government draft with fines of 10 000 to 2 000 000 złoty for a missing assessment, file or declaration, and the producer register applies today. Member States must have penalties in place by 12 February 2027.

What to have ready

• a data sheet per grade, in your layout, with the values and the standards
• a PPWR information per grade, to Annex VII, with the heavy-metal and PFAS statements and the reports named
• a food-contact declaration per grade that touches food, resting on the mill's declaration
• each in the languages your customers write in, and a new version whenever the mill sends a new sheet

Complizer makes the three from the maker's files in seconds, in your template and your customer's language, and names what the files do not state before you send.