Every packaging PPWR-compliant, on record

A web page where your suppliers answer your requests. The supplier opens it via the link in the e-mail Certiflow sends them, with no account, login or installation. There they fill in questionnaires such as the PPWR questionnaire, upload declarations and test reports and see what is still missing. Their answers go to your quality assurance for review.

For every packaging you place on the market under your name or trademark, you are the manufacturer within the meaning of the PPWR. You need a conformity assessment, technical documentation and an EU declaration of conformity before the packaging is placed on the market. The basis is the evidence from your packaging suppliers under Art. 16.

Yes, if the packaging or the packaged product is manufactured under your name or trademark. There is exactly one manufacturer per packaging, and the responsibility cannot be transferred to the supplier by contract. The term “producer” in the PPWR refers to extended producer responsibility, i.e. registration and contributing to waste management.

Under Art. 16, all the information and documentation you need to demonstrate conformity, including the technical documentation under Annex VII, on paper or electronically. For packaging in contact with food, the documentation required by food contact legislation is added. There is no exemption for small suppliers.

No. Evidence must refer to a specific packaging or item number and document the material composition, the substance data on PFAS and heavy metals and the recyclability data. That is why Certiflow requests information per packaging and requires the declaration or test report as a file.

Since 12 August 2026, Art. 5(5) sets: 25 ppb for any individual PFAS and 250 ppb for the sum of PFAS, each measured by targeted analysis, and 50 ppm for total PFAS including polymeric PFAS. If the total fluorine content exceeds 50 mg/kg, the origin of the fluorine must be demonstrated on request. The limits apply to the entire packaging, including inks, coatings and adhesives.

The Commission’s guidance describes a tiered approach: first, the total fluorine content is measured. If it exceeds 50 ppm, an analysis for organic fluorine follows and, where necessary, a targeted PFAS analysis. Your supplier’s test reports feed into your technical documentation.

Lead, cadmium, mercury and hexavalent chromium together no more than 100 mg/kg (Art. 5(4)). This applies to all packaging and packaging components, not only those in contact with food.

The unique identification of the packaging by type, batch or serial number, the name and address of the manufacturer, a statement that the manufacturer bears sole responsibility, and the statement that the packaging conforms to Regulation (EU) 2025/40. Plus, where applicable, the standards applied, place, date, and name and function of the signatory.

Yes, if the packagings are identical in all properties relevant to conformity, such as cartons that differ only in size. The declaration then lists the items covered.

The technical documentation and the declaration of conformity for 5 years after placing on the market, 10 years for reusable packaging (Art. 15). On a reasoned request from an authority, you present the documents within 10 days.

Goods placed on the market before 12 August 2026 may continue to be distributed. Anything placed on the market for the first time from that date must comply, regardless of the production date.

Not legally, it is set out in Regulation (EU) 2024/3190. Because it affects the same packaging and the same suppliers, the Certiflow questionnaire asks for the BPA confirmation at the same time.