Supplier PPWR Declarations: What Counts as Evidence — and What Doesn't
Can a Company-Wide "PPWR Declaration" From Your Supplier Prove Your Packaging Complies?
No. Under Article 39(2) of Regulation (EU) 2025/40, conformity is declared for packaging, not for companies: the EU declaration of conformity follows the model in Annex VIII, and that model identifies the specific packaging covered by a unique identification. A letterhead statement that a supplier "complies with the PPWR" names no packaging, so it demonstrates nothing about yours.
Since Regulation (EU) 2025/40 became generally applicable on August 12, 2026, buyers have been asking suppliers for "your PPWR declaration" — and suppliers have been answering with company-wide PDFs. In August alone we were sent a company-level "PPWR declaration" by a packaging supplier asking customers to file it, and a company told us that a per-packaging declaration template "describes a packaging, not a company". That observation is exactly right. It is also the entire point of this article.
Key Facts
- The EU declaration of conformity is drawn up per packaging and follows the model in Annex VIII of Regulation (EU) 2025/40, as required by Article 39(2).
- The Annex VIII model requires a unique identification of the packaging covered — a declaration that identifies no packaging does not follow the model.
- Behind every declaration sits technical documentation as described in Annex VII — the data, not the letterhead, is what an inspector or a customer can actually check.
- A company-level "PPWR certificate" appears nowhere in the regulation: the text attaches conformity obligations to packaging placed on the market, reference by reference.
- The two statements above about Article 39(2) and Annex VIII are confirmed by our dated PPWR referential (baseline of August 31, 2026); every other regulatory statement in this article links the exact provision it is read from.
Why Are Blanket "PPWR Declarations" Suddenly Everywhere?
The pattern is a chain reaction. A brand owner or distributor hears that the regulation has applied since August 12, 2026 and emails every supplier: "please send your PPWR declaration". The supplier's sales team does not have a per-reference conformity file at hand, so it produces the document it can produce in an afternoon: a letter, on letterhead, stating that the company takes the regulation seriously and complies with it. The buyer files the PDF and considers the box ticked. Nobody in that chain has produced or received evidence about any specific packaging.
The wave is understandable, and it is not harmless. A file of company letters creates the feeling of compliance while leaving every packaging reference exactly as undocumented as before. When the file is eventually read — by a market surveillance authority, a large customer's compliance team, or an acquirer's due-diligence lawyers — it is read reference by reference, because that is how the regulation is written.
What Is an EU Declaration of Conformity Under the PPWR?
The EU declaration of conformity is the document in which the responsible operator declares, on its own responsibility, that a specific packaging meets the requirements of Regulation (EU) 2025/40. It is drawn up under Article 39, follows the Annex VIII model, and is backed by the technical documentation described in Annex VII. One declaration covers one packaging — which is why our guide to drawing up the Declaration of Conformity starts from the packaging reference, never from the legal entity.
| What you received | What it attaches to | What it demonstrates under Regulation (EU) 2025/40 |
|---|---|---|
| Company-wide "PPWR declaration" on letterhead | The company | Nothing about any packaging: no unique identification, so the Annex VIII model is not followed |
| Marketing or scheme certificate ("certified sustainable packaging") | The scheme's own criteria | Nothing by itself: the regulation's route is the declaration plus the technical file, and a certificate can at most feed that file |
| EU declaration of conformity for one packaging reference | One identified packaging | The conformity statement the regulation actually provides for — this is the document you can file |
| Underlying packaging data (materials, substances, recyclability information) | The packaging you actually buy | The evidence that lets you draw up your own documents where you are the responsible operator |
What Should a Valid Declaration Contain?
A declaration you can rely on identifies the packaging first. Reading the Annex VIII model, the elements to look for before filing a supplier's declaration are concrete:
- A unique identification of the packaging — a reference, a name, a description that maps to the packaging you buy, not to a product family in the abstract.
- The identity of the operator taking responsibility — name and address, so the declaration binds someone.
- The regulation named in full — Regulation (EU) 2025/40, not a vague "applicable EU packaging rules".
- A conformity statement about that packaging — not about the company's intentions, processes or values.
- Place, date and a named signatory — a declaration is signed by a person, for a date, and that date matters when a packaging changes.
The red flags are the mirror image: no packaging identified, "all our products" as scope, no reference to the regulation's number, or a signature block replaced by a marketing footer. One test catches most blanket letters: if the same PDF could be sent to every customer of the company without changing a word, it does not identify your packaging.
Does a Supplier Declaration Replace Your Own Obligations?
No. A supplier document is input evidence, never a transfer of responsibility: the operator that places the packaging on the market answers for that packaging's conformity. If that operator is you, you draw up your own declaration backed by your own Annex VII technical documentation — and what you need from your supplier is data, not reassurance. Three families of data dominate in practice: composition by material and weight; substances information under Article 5 — the provision carrying the 100 mg/kg limit for the sum of lead, cadmium, mercury and hexavalent chromium, and the restriction on intentionally added PFAS in food-contact packaging that has applied since August 12, 2026 — and the design data your recyclability assessment under Article 6 depends on.
What Should You Ask Your Supplier for Instead?
- Ask per reference, not per company. Name the packaging reference or SKU in the request. A request that names no packaging invites an answer that names no packaging.
- Ask for the declaration that identifies that packaging. Point to the Annex VIII model. A supplier who has one produces it in minutes.
- Ask for the data behind it. Material composition by weight, Article 5 substances information, and the recyclability-relevant design data — the Annex VII themes, stated for that reference.
- Log what is missing, and refuse silent substitutions. A second letterhead PDF is not an answer to a per-reference request. Record the gap against the reference; an honest open point is worth more than a filed blanket letter.
- Anchor it contractually going forward. Make per-reference conformity documentation a condition of purchase, so the next packaging change arrives with its evidence instead of after it.
- File everything against the packaging reference. Registrations, declarations and data live together per reference — the same structure EPR producer registration already forces on your portfolio.
Frequently Asked Questions
Is one declaration for the whole company enough under the PPWR?
No. Article 39(2) of Regulation (EU) 2025/40 requires the EU declaration of conformity to follow the Annex VIII model, and the Annex VIII model requires a unique identification of the packaging covered. A declaration scoped to a company rather than to identified packaging does not follow the model.
Is a third-party certificate the same as an EU declaration of conformity?
No. The route Regulation (EU) 2025/40 provides is a declaration drawn up by the responsible operator, backed by Annex VII technical documentation. A certificate from a scheme or a laboratory can support the technical file, and it never replaces the declaration.
We only received a blanket PDF. Can we still buy from this supplier?
Buying is a commercial decision; the compliance file is a separate question. A blanket PDF leaves the file for that packaging reference open, so the practical answer is to keep purchasing decisions and evidence collection apart: request the per-reference declaration and data, record the gap until it closes, and treat a supplier who cannot ever produce packaging-level data as a risk signal in its own right.
How PPWR Connect Helps
Collecting supplier evidence is a per-reference data problem, and it stays manageable only if the requests, the documents and the gaps live in one place. PPWR Connect lets you send supplier data requests at SKU level, receive documents into a review queue instead of an inbox, and keep material composition, substances information and recyclability data filed against each packaging reference — so your own Declarations of Conformity are generated from evidence, not from letterhead. To see which of your references still rest on a blanket letter, start with our PPWR compliance software or a quick, free PPWR readiness assessment.
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PPWR Connect is published by Rutherford, a European team building production-control software for offset printing and packaging converters (ColorLoop). Veoria, from the same group, develops inline spectral colour measurement systems for label and packaging presses (DeltaOne).