Suppliers of packaging and packaging materials must give the manufacturer all the documentation needed to demonstrate conformity. A blanket letter is not enough.
The manufacturer bears the responsibility, but rarely knows its packaging down to the last detail. That is why Art. 16 of the PPWR obliges suppliers of packaging and packaging materials to provide all the information and documentation the manufacturer needs to demonstrate conformity. This includes the technical documentation under Annex VII, on paper or electronically and in a language the manufacturer understands.
For packaging in contact with food, the documentation required by food contact legislation is added. The Regulation provides no exemption for small suppliers.
What useful evidence contains:
- a reference to a specific packaging or item number
- the material composition, including closures, liners and coatings
- the substance data on PFAS and heavy metals, backed by a declaration or test report
- the data on recyclability and recycled content
A general letter saying “We are PPWR-compliant” with no reference to the packaging will not help when it matters. That is why the PPWR questionnaire in Certiflow requests information per packaging and requires the documents as files.
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