Complizer

Il PPWR in pratica

What the PPWR information must contain

Since 12 August 2026 a supplier of packaging or packaging material owes the packaging manufacturer everything the manufacturer needs for its technical file. Article 16 says what, Annex VII says how much.

Who owes it, and to whom

Regulation (EU) 2025/40, the PPWR, gives the manufacturer of a packaging item the duty to assess its conformity, build a technical file and sign a declaration of conformity (Art. 15). Everyone who supplies that manufacturer with packaging or packaging material has a duty of its own: to give the manufacturer all the information and documentation needed to show conformity (Art. 16). A board mill, a film maker, an ink maker, a converter selling to a brand owner, and a merchant selling board to a converter are all suppliers in this sense.

The supplier's duty is an information duty. It has no prescribed form, no deadline of its own and no declaration of its own, and it cannot be refused. The responsibility for the packaging stays with the manufacturer; what the supplier owes is the evidence.

What the file needs from you

Annex VII lists what the manufacturer's technical file holds, and that list is the list of what your information must cover for your material:

  • the identification of the material: its commercial name, grade, code, and its intended use, including whether it is meant for food contact
  • the composition of the material, by component, and the manufacturing process where it matters for the assessment
  • the heavy-metal statement: the sum of lead, cadmium, mercury and hexavalent chromium at or below 100 mg/kg (Art. 5(4)), with the test report behind it
  • for food-contact packaging, the PFAS statement against the limits of Art. 5(5), with the method and the report
  • the standards applied and the test reports that show the values
  • where you state them, the recyclability of the material and its recycled content, with the basis of the figure
  • the food-contact documentation where the material touches food: the declaration of compliance and what it rests on

The information goes to the manufacturer in a language it understands, on paper or electronically (Art. 16(2)). A letter in German to a Polish converter does not meet that.

What a good PPWR information looks like

It names one material, by its grade and code, not your whole range. It states each of the points above, or says plainly that a point does not apply and why. It carries a date, the issuer and a signatory. It names the test reports with their numbers, so the manufacturer can quote them in its file.

Complizer's PPWR information is built to this list. It fills from the maker's data sheet and reports, and whatever those files do not state it names above the document, with the article, before you send.