PPWR Supplier Assessment: Which documents will I be asked to provide?

Last updated: September 25, 2026

PPWR Supplier Assessment

As of 12 August 2026, the EU Packaging and Packaging Waste Regulation (PPWR) takes effect. Companies that place packaging on the EU market must prove it meets strict requirements on materials, substances, recyclability, and labeling.

To do so, your customer, a company selling products into the EU, needs detailed data about the packaging they use. Because you supply or manufacture that packaging, they may need specific information from you.
Your customer has invited you to Coolset to collect and share this data efficiently. Read this guide to be prepare for the information that you will be asked to provide in our assessment.

What kind of information can I expect to be asked?

Under PPWR, whoever designs a piece of packaging, or whose logo or trademark appears on it, is the "manufacturer" of that packaging unit. Since you are likely the supplier to your customer, who qualifies as the manufacturer, we will ask you to provide the following information to make sure the packaging unit is PPWR compliant:

  • General packaging information to assess compliance (packaging type, materials, recyclability, etc.)

  • Technical documentation as evidence

In case you receive this article, but have not been invited to the Coolset platform to fill in the PPWR supplier assessment yet, you may treat this guideline as an indication of future information requests you will receive. Ideally, you start compiling the required information and listed documents as soon as possible to have them on file when asked to provide them.

This guide goes through the different sections of our PPWR supplier assessment and outlines which information and documents we will ask about in each section. You will have to complete the assessment for every packaging product that you supply to your customer, so be sure to have your data assembled per packaging item.

Do I hold a valid PPWR DoC?

This question only applies if you are the manufacturer of the packaging under the PPWR. Only the manufacturer must carry out the conformity assessment and draw up the DoC (Article 15(2)), and there is only one manufacturer per packaging item.

Under Article 3(1), point (13), you are the manufacturer if:

  • the packaging bears your name or trademark. This applies even if another company physically produces or fills it, and even if other trademarks also appear on it.

  • the packaging is unbranded and you manufacture it, or you manufacture the packaged product.

There are two exceptions:

  • Micro-enterprise buyer: if the company whose name or trademark is on the packaging is a micro-enterprise, and you supply it that packaging from the same Member State, you are the manufacturer.

  • Importers and distributors: an importer or distributor becomes the manufacturer if it places packaging on the market under its own name or trademark. It also becomes the manufacturer if it modifies packaging in a way that could affect compliance (Article 21).

If you are not the manufacturer, you do not issue a DoC. Instead, you must provide the manufacturer with the information and documentation it needs to demonstrate compliance (Article 16).

If you are the manufacturer, we will ask whether you already have a valid Declaration of Conformity (DoC). This refers exclusively to a DoC under Annex VIII of the PPWR. It is not the same as a CE-marking DoC or any other compliance declaration. Letters of intent, compliance commitments, and supplier statements do not qualify as a valid DoC.

If you can present a valid DoC, you will have to provide any supporting technical documentation held alongside it.

Basic information

If you are the manufacturer and do not yet hold a DoC for the packaging item, or if you supply packaging to the manufacturer, you will be asked for the information below. It forms the general description of the packaging and its intended use required in the technical documentation (Annex VII, point 2(a)).

Packaging item description

  • General description: the physical form, structure and primary function of the packaging.

  • Intended use: which product the packaging is designed to contain, protect, handle, deliver or present.

  • Packaging category: which PPWR category the packaging falls under

    • sales packaging

    • grouped packaging

    • transport packaging, including e-commerce packaging

    • service packaging (packaging filled at the point of sale)

Characteristics of packaging type

  • Is the packaging reusable or single-use? Reusable packaging must be designed for multiple rotations and meet the requirements of Article 11.

  • Is the packaging intended to come into contact with food, within the meaning of Regulation (EC) No 1935/2004?

Which documents can I provide as evidence?

  • Product and packaging specifications or data sheets

  • Packaging specifications, drawings or customer orders showing how the packaging is used

  • For reusable packaging: design specifications showing the intended number of rotations, and evidence of participation in a re-use system

  • For food-contact packaging: the food-contact declaration of compliance, for example under Regulation (EU) No 10/2011 for plastics

Materials, design and diagrams

You will be asked to list each component of the packaging and the material categories it contains, for example glass, paper/cardboard, metal, plastics, wood/cork, textile, or ceramics/porcelain stoneware (Annex II, Table 1). A single component can contain several materials, such as a multilayer film. For each component, you will also be asked for its weight. See the table below for an example.

Applied substances are not listed as separate components. This covers inks, varnishes, lacquers, adhesives and glues. However, the heavy-metals figure reported for a component must include any heavy metals contributed by substances applied to it. The combined concentration of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg (Article 5(4)). Glass packaging made with recycled glass may exceed this limit only where none of these metals is intentionally introduced.

Which documents serve as evidence?

  • Heavy-metals concentration data per component (mg/kg), including applied substances. Typically this is a laboratory test report.

  • Material composition per component: material types and weights, for example from supplier material specification sheets.

  • Conceptual design diagrams, showing the packaging's structure, components and how they fit together. Spec sheets and technical descriptions can support the diagrams but do not replace them (Annex VII, point 2(b)–(c)).

  • Technical manufacturing drawings. These should be drawn to true scale, with a scale bar or stated ratio. They should give dimensions, wall thickness, layer composition, tolerances and the structural specifications used in production.

Optional documentation:

  • Supplier material specification sheets to confirm the exact material types and weights of your packaging

What information must I submit regarding Substances of Concern (SoC)?

Substances of Concern (SoC) refers to heavy metals that is relevant for all packaging, and PFAS in food contact packaging. The following limits apply under PPWR:

  • Heavy metals (all packaging): the combined concentration of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg in the packaging and in each of its components (Article 5(4)).

  • PFAS (food-contact packaging only): 25 ppb for any individual PFAS, 250 ppb for the sum of PFAS, and 50 ppm for total PFAS including polymeric PFAS (Article 5(5)). The limits apply to the whole packaging unit, including inks and adhesives.

We will ask you about:

  • Steps you have taken to minimize SoC concentration in your packaging. The Commission recommends documenting these in line with Annex C of EN 13428:2004.

  • Heavy-metals concentrations for each component. Each component must comply on its own.

  • PFAS concentrations, if the packaging is intended to come into contact with food.

Which documents should I provide as evidence?

  • Heavy-metals test results. The same per-component data entered in the Materials section applies.

  • For food-contact packaging, PFAS test reports. Typically these start with a total fluorine analysis, followed by further testing where needed, in line with the Commission guidance.

  • Minimization assessment. A written description of the steps taken to minimise SoC.

Recyclability

Recyclability requirements under the PPWR apply from 1 January 2030 (Article 6). From then, packaging must meet design-for-recycling criteria and will receive a recyclability performance grade. The detailed criteria are still being set by the Commission.

No recyclability evidence is required yet. We ask about it now because redesigns and supplier changes take time to plan. We will ask:

  • whether a recyclability assessment has been carried out for the packaging.

  • which method or scheme was used, and the result.

  • any known features that hinder recycling, such as material combinations, coatings or components that are hard to separate.

Which documents should I provide as evidence?

A recyclability assessment / design-for-recycling report, ****following EN 13430:2004 or an equivalent standard and if available. Other recognized frameworks to follow in the interim are industry schemes such as RecyClass (plastics), CEFLEX (flexible plastics) and 4evergreen/Cepi (fibre-based packaging). For now, EN 13430:2004 may still be used as guidance, but no longer demonstrates conformity under PPWR.

Harmonized standards & specifications

A harmonized standard is a European standard developed by a European standardization body such as CEN at the Commission's request. Packaging that meets such a standard is presumed to conform with the PPWR requirements it covers (Article 36). Using harmonised standards is voluntary. Where none exist, the Commission can adopt common specifications, which have the same effect (Article 37).

No harmonized standards have yet been published under the PPWR. The standards used under the previous Packaging Directive (EN 13427 to EN 13432) can still be used as guidance, but they no longer create a presumption of conformity. The one exception is EN 13428 on packaging minimisation, which does so until the end of 2029.

Which documents should I provide as evidence?

The list of standards and specifications applied, including which parts were applied if only partly, or a description of the solutions adopted where none were applied. This is recorded in the technical documentation (Annex VII, point 2(d)), and applied standards are also referenced in the DoC.