Supplier documents PPWR: what counts as evidence

Supplier documents are, in practice, the entire evidentiary basis of a declaration of conformity, because very few companies test every component of their own packaging. The problem is that the documents suppliers send most readily are usually the ones that cannot go into technical documentation. Not because they are untrue, but because they cannot be tied to a specific material, a specific batch and a specific requirement.

There is one test, and it takes ten seconds: does this document let someone reconstruct which material, from which batch, was assessed against which limit, and when and by whom? If any of those four pieces is missing, the document does not close the item in your technical documentation. Below: what qualifies, what disqualifies, a ready request letter and a route to follow when the supplier goes quiet.

Four types of document that actually work#

A material with a high mass fraction deserves stronger evidence than one sitting at one percent. The inverse holds too: a low-mass, high-concentration component — ink, varnish, adhesive, print colourant, pigment — is often the most problematic one, however innocent it looks in the weight table. The calculation mechanism is set out in the post on the heavy metal limits in Article 5.

What disqualifies a document#

• No date of issue. A document with no date cannot be tied to a delivery — this year's or one from two years ago. In technical documentation, dates are what connect the evidence to the batch.
• No batch, heat number or production run. A statement "for material PE-LD 50 µm" describes a product range, not a delivery. With recycled material, batch-to-batch variability is real, and recyclate is exactly what tends to bring heavy metals in.
• A generic "complies with applicable legislation". Which legislation, against which limit, to what extent? A document that names no limit value is not a statement of conformity; it is a statement of goodwill.
• A reference to Directive 94/62/EC alone. The numerical limit is unchanged, but the legal basis has been replaced by the Regulation — the detail is in the post on PPWR vs Directive 94/62/EC. Ask for the reference to be updated; a supplier that will not do it probably has not looked at the topic in years.
• Chromium with no speciation. A result of "Cr: 45 mg/kg" does not answer the Cr(VI) question. Either you go back and ask, or you conservatively treat the whole figure as Cr(VI) and check whether you are still inside the limit.
• A signature with no person behind it. "Quality Department" is not a signature. A name and a position are required.
• A test report with no identified sample. A result detached from any material identification can be attributed to anything, which means to nothing.

A request letter that works#

The letter below outperforms a general request because it names the legal basis, the specific material and a specific deadline. Send it to the account manager, copying the quality department.

Subject: Request for material documentation — Article 16 of Regulation (EU) 2025/40 (PPWR)
Re: [material name / item code / order number / batch or delivery range]

Dear Sir or Madam,

In connection with the obligations under Regulation (EU) 2025/40 of the European
Parliament and of the Council (PPWR), applicable since 12 August 2026, we are
preparing the technical documentation and the EU declaration of conformity for
the packaging in which we use the material you supply.

On the basis of Article 16 of the Regulation, we request the following for the
material identified above:

1. A statement of conformity with Article 5 of Regulation (EU) 2025/40 confirming
   that the combined concentration of lead, cadmium, mercury and hexavalent
   chromium does not exceed 100 mg/kg, together with identification of the
   material and the batch, the date and the signature of an authorised person.
2. A test report from an accredited laboratory giving results for the four
   elements separately, with hexavalent chromium reported on its own, the test
   method used and identification of the sample tested.
3. The material composition with the mass fractions of the individual materials
   and components, including coatings, adhesives, inks and additives.
4. Information on recycled content, where present.
5. For food contact materials, information on the presence of PFAS and the total
   fluorine result, where determined.

We would ask for your reply by [date — 14 days suggested]. Without this
documentation we cannot issue a declaration of conformity for products containing
this material, and further orders will be held until it is provided.

I am happy to answer any questions.

[name, position, company, contact details]

The letter works because of its last paragraph. A request without consequences joins a queue; a note that the next order depends on the document reaches someone who can decide.

When the supplier goes quiet#

Four responses worth recognising immediately:

• "It is all on our website." A web page carries no date of issue, identifies no batch and changes without a trace. Ask for the same document as a dated, signed PDF. If the supplier refuses, keep a screenshot with the date and the URL, record in your documentation that the evidence is supporting only, and treat the item as still open.
• "We are ISO certified." ISO 9001 describes a management system, not the heavy metal content of a material. It is a good signal about the supplier and no evidence at all against Article 5.
• "The material is recycled, so it is environmentally friendly." Recyclate can be a source of heavy metals — one of the reasons the limit exists in the first place. Recycled content is a different question from restricted substance content.
• "Our own supplier never gave us that." That tells you the chain is longer than you assumed. Ask for the document from the party that holds it, and record the actual source of the data in your documentation.

When to commission your own test#

Your own testing makes sense in three situations: the material has a high mass fraction and no credible evidence; the material contains recyclate of variable origin; or the component belongs to a higher-risk category — inks, varnishes, printing colourants, adhesives, pigments, metal parts, coloured plastics. The cost of a single determination is usually lower than the cost of one day of held deliveries.

When you commission the test, tell the laboratory exactly what you need: lead, cadmium, mercury and hexavalent chromium, with Cr(VI) reported separately, as total content rather than migration, referenced to the 100 mg/kg limit on the sum of the four elements. Secure a sample from a specific batch and record its identification — a report without that detail has the same defect as the supplier documents described above.

How this connects to the declaration#

Supplier documents do not go into the declaration of conformity. They go into the technical documentation that stands behind it and that you make available to an authority on request. What remains in the declaration is a single sentence about meeting the requirements; the rest is the evidence trail described in the post on how to issue a packaging declaration of conformity.

To see how many items in your packaging still have no document attached, break one pack down into materials and compare the component list with the list of files in the binder. The difference between them is your task list for the next fortnight — and it is also what is missing before anyone can responsibly sign that document.