What a typical PPWR letter from a material maker leaves out

The letter everyone received

It is one or two pages on the maker's letterhead. It says the company is aware of Regulation (EU) 2025/40, that its products are made in accordance with it, that heavy metals are below the limits, and that further information is available on request. It is signed by quality assurance and dated August 2026. It is the same letter for every grade the company sells.

A manufacturer cannot put that letter in its technical file, because the file is per packaging item and the letter is per company. Converters are being flooded with requests they cannot answer from such letters, and retailers have started asking for a declaration per batch.

The five things that are missing

• The packaging reference. Annex VII wants the material identified: grade, code, intended use. A letter that covers the whole range identifies nothing.
• The heavy-metal statement with its report. Article 5(4) sets the sum of lead, cadmium, mercury and hexavalent chromium at 100 mg/kg. The letter says below the limits; the file needs the report number, the laboratory and the date.
• The PFAS statement for food-contact packaging. Article 5(5) sets limits per substance and in total, and most letters do not mention PFAS at all, because the maker has not tested for them.
• The date and the signatory per material. A statement about a material is dated when the material was tested, not when the regulation came in.
• The rest of Annex VII: composition by component, the standards applied, recyclability and recycled content where claimed, and the food-contact declaration where the material touches food.

What to ask for instead

Ask the maker for the information per grade, with the points above, in your language. Article 16 obliges it to give you what you need to show conformity, and it cannot refuse. Name the grade and the code, name the reports you need, and give a date.

Complizer reads every maker's file against the list of the document you are making and names above the file what it does not state, with the article: no heavy-metal statement, no PFAS statement, no date. You see what to ask for before you write, and the request goes out naming exactly what is missing.