PPWR 101 for suppliers
How to meet the EU packaging regulation requirements your customer is asking for
Your customer sent you this guide. "We" and "our" in it mean your customer.
1. What we need from you
The EU packaging law (Regulation (EU) 2025/40, PPWR) applies to all packaging sold in the EU from 12 August 2026. It concerns the packaging only, not your product. We must hold proof that the packaging meets it, and that proof starts with you.
| # | What | Applies | Example of how it is filled |
|---|---|---|---|
| 1 | Packaging data: every part of the packaging (bag, blister, card, label, box, tape), its material and its weight in grams; box sizes in mm and units per box. Often already prefilled in the portal | Every product | Bag: LDPE, 4.3 g. Label: paper, 0.03 g. Carton: corrugated, 1600 g, holds 100 bags, 400 × 515 × 615 mm |
| 2 | Heavy-metals declaration, signed: lead + cadmium + mercury + chromium(VI) together not more than 100 mg/kg in every part (Art 5(4)). One declaration can cover everything you supply us. The evidence behind it is in section 2 | Every product | One page, signed, stamped and dated: "The sum of Pb, Cd, Hg and Cr(VI) in every packaging part we supply to [customer] does not exceed 100 mg/kg (Art 5(4), Regulation (EU) 2025/40) and none is intentionally added." Your material makers' statements are kept with it |
| 3 | PFAS statement: no PFAS (fluorinated grease- or water-repellents) used, or the test in section 3 | Only packaging that touches food | Food-contact bag: the film maker's letter "grade X uses no fluorinated additives", or a targeted PFAS test report "each PFAS below 25 µg/kg, sum below 250 µg/kg". Not food contact: write "not food contact" |
| 4 | Recycled plastic: the % of post-consumer recycled content per plastic part (0 is a valid answer) and, if above 0, the GRS, RCS, ISCC PLUS or EuCertPlast certificate | Only if you claim recycled plastic | LDPE bag: "0 %". Or "30 %, GRS certificate no. 1234 from [resin supplier], waste collected and recycled in the EU" |
| 5 | EU Declaration of Conformity for the packaging (one page, form in the portal) plus the ticks that the technical file exists and the markings are on the pack | Only products sold under your own brand | Own brand: signed declaration naming the product and item code, plus the two ticks ("technical file exists"; "markings on pack: batch number, our name, address and email"). Customer's brand: nothing to send |
How to send it
Your customer sends you a personal web link to its supplier portal. Everything goes in there; nothing needs to be emailed.
- Open the link, choose your language, fill each product's packaging data and press "Save this product".
- Upload the signed heavy-metals declaration once, under "Packaging compliance declaration" (choose "blanket"); add the PFAS statement, recycled-content certificate or Declaration of Conformity where they apply.
- Press "Submit everything for review". Anything still missing shows again, and you get a reminder listing it.
2. If you buy the packaging material: what to ask your material makers
The law asks for a documented basis that the 100 mg/kg limit is met, not for a laboratory test. Your basis is a written statement from the company that makes each material.
Who covers the printing. The law applies to the packaging as it is sold, with the print on it. A statement or report for the blank material alone does not cover the ink.
| If | Who provides the proof for the print |
|---|---|
| You print on blank packaging yourself | You do. Provide the ink maker's statement for your inks and varnish (see the list below), or a test report on the finished printed packaging. Get the statement for the blank material from your packaging supplier. |
| You order the packaging ready-made, artwork already printed | Your packaging supplier does. Ask for one statement or test report for the finished printed packaging, including ink and varnish. Use the letter below and add those words. |
Ask, for every part of the pack (film or resin maker, board or paper mill, ink maker, varnish and adhesive maker; not the trader):
- A signed statement on their letterhead that names the grade (for inks, the ink series), says lead, cadmium, mercury and chromium(VI) are not intentionally added and that their sum does not exceed 100 mg/kg, and carries a date and the signatory.
- From the ink maker in addition: a statement that the inks conform to the EuPIA exclusion policy, which bans pigments containing those metals.
- A certificate of analysis or test report, if they have one. It strengthens the file but is not required.
Send this to each material maker:
Subject: Heavy-metals statement for packaging material, EU Regulation 2025/40
Our customer sells in the EU, where packaging must meet Article 5(4) of Regulation (EU) 2025/40 (formerly Article 11 of Directive 94/62/EC): the sum of lead, cadmium, mercury and hexavalent chromium in each packaging material must not exceed 100 mg/kg. For the material(s) we buy from you, grade(s) [grade names], please send:
- A signed statement on your letterhead naming the grade, confirming that lead, cadmium, mercury and hexavalent chromium are not intentionally added and that their sum does not exceed 100 mg/kg, with date and signatory. (Ink makers: also confirm conformity with the EuPIA exclusion policy.)
- If you have one, the analysis report or certificate of analysis for that grade with the results in mg/kg.
Thank you. We keep these in our technical file and share them only with our customer.
主题：包装材料重金属声明（欧盟法规 2025/40）。我们的客户在欧盟销售产品，欧盟包装法规 (EU) 2025/40 第 5(4) 条（原 94/62/EC 指令第 11 条）要求每种包装材料中铅、镉、汞和六价铬的总和不得超过 100 mg/kg。请就我们向贵司采购的材料（牌号：[牌号]）提供：1) 加盖公章的书面声明，注明牌号，确认未有意添加上述四种金属且其总和不超过 100 mg/kg，附日期和签署人（油墨供应商请同时确认符合 EuPIA 排除政策）；2) 如有，该牌号的检测报告或分析证书（含 mg/kg 结果）。谢谢。
Papers that count, and papers that do not:
| Counts | Does not count |
|---|---|
| The maker's signed statement naming the grade or ink series, the four metals, the 100 mg/kg limit, a date and a signatory | RoHS certificate (electrical products, other limits) |
| The ink maker's statement of conformity with the EuPIA exclusion policy for the named inks | REACH SVHC or "REACH compliant" letter (other substances) |
| A certificate of analysis or test report from the maker or an accredited laboratory (SGS, TÜV, Intertek, BV, CTI, any ISO/IEC 17025 lab) with the four metals in mg/kg | EN 71-3 or ASTM F963 toy report (migration, not content) |
| The printer's or converter's statement for the finished printed part | GRS, RCS or ISCC certificate alone (recycled origin, says nothing about metals) |
| A general "no heavy metals" line with no grade, limit, date or signature, or an unsigned email |
3. If a maker cannot give you a statement: the tests to run
Order from any ISO/IEC 17025 laboratory (SGS, TÜV, Intertek, BV, CTI). Send one sample of each packaging part, not the product. One report covers every product that uses the same part from the same source; repeat when the material, printer or ink changes.
| Part | Test to order | The report must state |
|---|---|---|
| Any part where the maker gives no statement | Heavy metals: Pb, Cd, Hg by ICP-OES/MS after acid digestion (EN 13428 / CR 13695-1; IEC 62321 accepted); Cr(VI) by IEC 62321-7 | Each metal and the sum in mg/kg, detection limit, method, our item code, lab accreditation number |
| Food-contact part with no PFAS statement | Total fluorine by combustion ion chromatography, as a screen | Total fluorine in mg/kg. Any fluorine found: order the targeted test below. Above 50 mg/kg, the material maker must show how much of it is PFAS (Art 5(5)(c)) |
| Food-contact part where fluorine was found | Targeted PFAS by LC-MS/MS (EU-regulated PFAS list, optional TOP assay) | Each PFAS and the sum in µg/kg against 25 and 250 µg/kg; this is the test the limit values are defined by |
| Part of unknown material | FTIR polymer identification | The polymer type |
Write on the order: "Packaging compliance test, Regulation (EU) 2025/40 Article 5", the part, the material and our item code. Upload the report to the portal under "Heavy-metal test values & report". Recycled content cannot be tested; the chain-of-custody certificate from the resin supplier is the proof.