PPWR 13 – Supplier, Customer, Importer: Who Must Provide What Information to Whom?

“Please send us the PPWR certificate”

A converter receives an email from a customer:
“Please send us your PPWR certificate.”
The sales department forwards the request to quality.
Quality asks:
“Which certificate?”

And this is where the problem begins. PPWR creates documentation, information and compliance-demonstration obligations, but it does not create one single, universal document called a “PPWR certificate”.

The correct questions are different:
Which requirement?
Which legal role?
Which packaging?
Which evidence?
Which version?

How this connects with the PPWR series

• PPWR 04 established what makes packaging recyclable.
• PPWR 05 examined recycled-content requirements.
• PPWR 09 explained which data and labels become relevant.
• PPWR 10 established who is the manufacturer, importer and distributor, and who proves technical conformity.
• PPWR 11 explained who is the producer for EPR purposes.
• PPWR 12 followed what happens after packaging becomes waste.
• PPWR 13 answers the question connecting all these obligations:
How does the information required for compliance actually move through the supply chain?

Five different things that should not be confused

In practice, five categories are frequently mixed together:

• supplier information;
• the manufacturer's technical documentation;
• the EU Declaration of Conformity;
• EPR reporting data;
• commercial and contractual documentation.

They are not interchangeable.
• A supplier declaration is not the technical documentation for the finished packaging.
• Technical documentation is not the EU Declaration of Conformity.
• EPR data is not proof of technical conformity.
• And none of these categories represents, on its own, a universal “PPWR certificate”.

Article 16 – what must the supplier provide?

Here, PPWR is clearer than commercial discussions sometimes suggest. Article 16 requires suppliers of packaging or packaging materials to provide the manufacturer with all information and documentation necessary to demonstrate compliance with the applicable requirements.

This may include relevant technical documentation under Annex VII for the requirements in Articles 5–11. The information may be supplied on paper or electronically. This is therefore not merely good supply-chain practice.

There is a real legal obligation to provide the information necessary to demonstrate compliance. But this obligation does not mean that any customer may request any information. The supplier must provide what is necessary for the requirement applicable to the packaging concerned.

The converter's problem

A converter buys:

• virgin polymer;
• recycled polymer;
• masterbatch;
• additives;
• adhesives;
• inks;
• labels;
• barrier materials;
• caps and other components.

If the converter is the PPWR manufacturer of the finished packaging, it needs upstream information to build its own compliance file. But this does not mean every supplier must send a complete PPWR dossier. Each supplier must provide the information relevant to its own contribution to the conformity of the final product.

From raw-material supplier to converter

Relevant information may include:

• material identity;
• grade and specification;
• composition information;
• data on restricted substances or substances relevant to PPWR requirements;
• recycled-content information;
• technical properties;
• test reports, where relevant;
• information needed to demonstrate applicable requirements.

Not all these elements have the same legal basis and not all need to be provided in every commercial relationship. The principle remains: the supplier must provide the information the manufacturer needs to demonstrate the applicable requirements.

Recycled material – the evidence chain

The link with PPWR 05 is direct. A converter using recycled polymer needs evidence supporting the calculation and demonstration of recycled content. Depending on the applicable methodology, this may include information on:

• material origin;
• traceability;
• quantities;
• mass-balance systems, where relevant;
• the method or certification used.

There is, however, no universal document called a “PPWR recycled-content certificate” that solves every transaction. And a simple commercial supplier statement is not automatically sufficient in every situation. What matters is which requirement must be demonstrated and which official methodology applies.

Masterbatch, additives and inks – low mass, potentially high impact

A masterbatch or additive may represent only a small percentage of the final packaging mass. But it can affect:

• recyclability;
• colour and optical sorting;
• relevant substances;
• material behaviour;
• food-contact properties, where applicable.

For this reason, the supplier of a minor component may provide information that is essential to the manufacturer's file. A low mass share does not automatically mean low compliance relevance.

From converter to brand owner

A converter manufactures an empty HDPE bottle. The customer fills it with detergent and sells the product under its own brand. Who is the PPWR manufacturer? The answer cannot be based only on who physically produced the bottle. The role must be determined using the legal test discussed in PPWR 10.

Only once that role is clear can the parties determine:

• who prepares the technical documentation;
• who issues the EU Declaration of Conformity;
• who must receive information from other suppliers.

The flow of documents follows the legal roles, not the other way around.

Empty packaging versus packaged product

The information flow may differ when a company sells empty packaging compared with a situation where an operator places an already packaged product on the market.

Before requesting documents, the parties should therefore establish:
What exactly is being placed on the market, and who holds the relevant legal role?
This clarification eliminates many incorrect document requests between converter, filler and brand owner.

Technical documentation – suppliers feed it, the manufacturer builds it

The technical documentation required by Annex VII must allow the conformity of the packaging to be assessed. Depending on the case, it may contain:

• a description of the packaging;
• design and manufacturing information;
• applicable requirements;
• standards or specifications used;
• calculations;
• assessments;
• test reports and other relevant evidence.

The central principle is simple:
supplier information enters the technical file, but does not automatically become the technical file.
A resin technical data sheet is not evidence of conformity for the final packaging as a whole.

EU Declaration of Conformity

The EU Declaration of Conformity follows the model in Annex VIII and confirms compliance with the relevant requirements of Articles 5–12. It is issued under the sole responsibility of the manufacturer. The manufacturer may draw it up directly, or it may be prepared by the authorised representative where the mandate allows. Responsibility for packaging conformity nevertheless remains with the manufacturer.

The Declaration does not need to be printed on every packaging unit and should not be confused with:

• a supplier declaration;
• a material certificate;
• a laboratory report;
• EPR documentation.

It is a distinct legal document with a specific purpose.

“PPWR compliant” on an offer – what does it actually prove?

A supplier writes:
“Material PPWR compliant.”
What does this statement prove?
Very little if it is not linked to:

• a specific PPWR requirement;
• an identified material or product;
• a specific version or specification;
• an assessment method;
• verifiable supporting evidence.

“PPWR compliant” written on an offer is not, by itself, evidence of conformity.
The wording may be used commercially. But there must be something behind it.

The importer – it is not enough for the supplier to say the documents exist

Before placing packaging from a third country on the EU market, the importer must verify that the manufacturer has carried out the conformity assessment and prepared the required technical documentation. The importer must also verify the applicable labelling and identification requirements and fulfil its own identification obligations. Following a reasoned request from an authority, the importer must be able to provide the relevant information and documentation, including the necessary technical documentation, within the period set by the Regulation.

Therefore:
“Our supplier in Asia says it is compliant”
is not enough.
The importer has its own verification obligation.

Chinese manufacturer, Romanian importer, European customer

A Chinese packaging manufacturer sells to an importer in Romania. The importer then sells to a customer in the EU. If the authority requests documentation, the importer cannot simply answer:
“The factory in China probably has it.”

There must be real access to the necessary information. This is why document verification should begin before purchasing, not after a compliance problem emerges.

The distributor – more limited obligations, but real ones

The distributor does not normally prepare the manufacturer's technical documentation. But it has its own verification duties before making packaging available on the market.

Depending on the situation, it must verify:

• the relevant EPR registration requirements;
• labelling;
• identification of the manufacturer and importer.

If it has reason to believe that packaging is non-compliant, it cannot simply continue selling it. But it is also not required to repeat the manufacturer's complete technical assessment from scratch.

When the importer or distributor becomes the manufacturer

If an importer or distributor places packaging on the market under its own name or trademark, or modifies it in a way that may affect conformity, manufacturer obligations may become applicable to that operator.

This has an important consequence: it is not only the name on the packaging that changes. Who must demonstrate conformity and hold the required documentation may also change.

Private label

A converter manufactures the packaging. A retailer sells it under a private label. The legal role is not determined solely by the physical manufacturing step. The PPWR test discussed in PPWR 10 must be applied. Documentation responsibilities then follow the result of that test.

Traceability – who supplied it and to whom?

PPWR imposes separate obligations to identify economic operators in the chain.

Relevant operators must be able to identify:

• who supplied them with the relevant packaging or materials;
• to whom they supplied them further downstream.

These records must be retained:

• for 5 years for single-use packaging;
• for 10 years for reusable packaging.

These periods are separately established for economic-operator identification obligations. They coincide with the periods applicable to technical documentation and the EU Declaration of Conformity, but the legal basis and purpose are different.

Most importantly:
traceability does not mean mandatory individual serialisation of every packaging unit.
PPWR does not introduce a general pharmaceutical-style serialisation system for all packaging.

Document retention – there is no single rule for everything

For technical documentation and the EU Declaration of Conformity, the manufacturer must retain the documents:

• for 5 years for single-use packaging;
• for 10 years for reusable packaging.

For economic-operator identification records, Article 22 separately establishes the same 5- and 10-year periods. But this should not be extrapolated into a universal rule:
“keep every PPWR document for 10 years.”
Each category of document should be linked to the legal obligation from which it arises.

When the authority requests documentation

Documentation must be retrievable. It is not enough for it to exist somewhere in an old email chain. Following a reasoned request from the competent authority, manufacturers and importers have specific duties to provide the necessary information and documentation. For the manufacturer and importer, the Regulation provides a 10-day response period for the relevant reasoned request. In practice, this means that the compliance file must be capable of being reconstructed quickly.

Confidentiality – how much must the supplier or customer disclose?

A supplier says:
“I cannot give you the formulation. It is confidential.”
The customer replies:
“I need evidence for PPWR.”

Both positions may be legitimate. PPWR does not give customers a universal right to access the supplier's complete formulation. But the supplier cannot refuse information needed to demonstrate compliance simply by invoking confidentiality. The practical solution is to provide enough information to demonstrate the relevant requirement without unnecessarily disclosing protected know-how.

An NDA does not cancel PPWR – but PPWR does not cancel know-how either

Confidentiality agreements can protect:

• formulations;
• recipes;
• sources;
• processes;
• commercially sensitive information.

But they cannot eliminate a legal information obligation. In practice, companies may use:

• controlled declarations;
• specification limits;
• test reports;
• relevant certifications;
• NDAs;
• controlled disclosure mechanisms to authorities or other authorised parties.

These are industrial risk-management tools, not a mandatory PPWR model.

Change control

A supplier changes:

• the polymer grade;
• the recycled-material source;
• the masterbatch;
• the pigment;
• the adhesive;
• the barrier layer;
• the cap material.

The commercial code remains unchanged. Is the old documentation automatically still valid? Not necessarily.

If the change may affect conformity, reassessment is required. The manufacturer must take account of changes in design, characteristics and specifications that may affect conformity. From a contractual perspective, it is prudent for supplier and customer to define which changes must be notified before implementation.

Version control

Compliance evidence must be linked to the correct product. Ideally, the company should be able to identify:

• material grade;
• supplier;
• packaging code;
• drawing revision;
• specification revision;
• production period;
• test-report version;
• methodology used.

This is a recommendation for industrial discipline. Without this control, there is a very real risk of holding a perfectly valid report for the wrong packaging version.

One document is not enough

Compliance may depend on a chain of evidence:
recycled-material supplier evidence → material specification → converter calculations and tests → packaging technical documentation → EU Declaration of Conformity → importer/distributor verification → EPR data, where relevant.
Not every document must physically travel through every stage. But there must be a controlled and logical connection between them.

Data versus documents

Data may include:

• weight;
• material;
• composition;
• recycled-content percentage;
• packaging category;
• components;
• dimensions.

Documents may include:

• supplier declarations;
• test reports;
• specifications;
• technical documentation;
• the EU Declaration of Conformity.

A PDF does not fix incorrect data. And correct data without controlled evidence may still be insufficient to demonstrate compliance.

EPR data

PPWR 11 showed that the EPR producer needs other categories of data:

• material;
• weight;
• quantity placed on the market;
• Member State;
• reuse status;
• DRS status;
• other relevant reporting data.

Some of this data may originate in engineering. Other data may come from sales, logistics, ERP or the PRO. PPWR is therefore also a master-data issue, not only a technical one.

ERP and PLM – where order begins

PPWR does not require companies to use a particular software system. But it is prudent to maintain controlled fields for:

• packaging code;
• material;
• weight;
• components;
• supplier;
• recycled content;
• market;
• DRS status;
• reuse status;
• technical-documentation reference;
• EU Declaration of Conformity reference.

Without this structure, compliance risks being fragmented across spreadsheets, emails and unrelated PDFs.

Digital Product Passport – do not confuse the concepts

The information flow described in PPWR 13 does not mean that all this data must automatically be entered into a Digital Product Passport. PPWR does not create a general packaging DPP equivalent to the ESPR mechanism. Digital data carriers may have specific roles under certain obligations, but they should not be treated as a universal solution for all PPWR documentation.

What should a supplier declaration contain?

There is no universal mandatory EU template. As Plastinfo good practice, a useful declaration could include:

• supplier identification;
• product or material identification;
• grade, code and revision;
• the specific PPWR requirement supported;
• relevant composition or recycled-content information;
• the relevant method, standard or test-report reference;
• date;
• responsible person;
• validity and change conditions.

Important:
this is an industrial recommendation, not a mandatory PPWR form.

PPWR supplier questionnaires

The question:
“Are you PPWR compliant? YES / NO”
is convenient, but weak.

Better questions include:

• Which specific PPWR requirement does this material support?
• What evidence exists for recycled content?
• Which test supports the recyclability claim?
• Has the formulation changed since the last report?
• For which packaging application was the material assessed?

The rule is:
Ask for the evidence behind the claim, not only the claim.

What should a converter request from suppliers?

• Material identification and technical specification.
• Composition information necessary for the applicable PPWR requirements.
• Evidence of recycled content, where relevant.
• Information on relevant substances.
• Test reports, where necessary.
• Document revision.
• A responsible regulatory-information contact.
• A contractual mechanism for notification of relevant changes.

The final point is a contractual recommendation, not a general PPWR obligation imposed on every supplier.

What should the customer receive from the converter?

Depending on the legal roles of the parties and the applicable requirement:

• packaging identification;
• material and component structure;
• weight;
• relevant technical specification;
• evidence supporting applicable PPWR requirements;
• the EU Declaration of Conformity, where the legal role and obligation justify it;
• information necessary for correct use;
• data needed for EPR where the contractual relationship assigns this to the converter.

Not every customer is automatically entitled to every document. Access depends on the legal role and the obligation the customer must fulfil.

Some practical cases

Virgin PE producer → bottle converter
The supplier must provide the necessary information on the material and relevant requirements. The manufacturer of the final packaging remains responsible for the conformity conclusion.

Recycled HDPE supplier → converter
Evidence on origin, traceability and recycled content becomes relevant to the downstream file.

Masterbatch supplier → converter
Even at low addition rates, colour and additives may affect recyclability or other requirements.

Converter → Romanian detergent filler
First determine who is the PPWR manufacturer. Documentation and the Declaration then follow that role.

Romanian converter → German brand owner
The cross-border flow does not change the principle: the legal role must be identified before documentation obligations are allocated.

Chinese manufacturer → Romanian importer
The importer must verify the existence of the conformity assessment and required documentation. An invoice is not enough.

EU distributor → Romanian customer
The distributor performs the checks required by its own role, not a full technical reassessment from scratch.

Converter → private-label retailer
The manufacturer role follows the PPWR legal test, not merely who physically made the packaging.

Supplier changes recycled-material source without changing the product code
Existing evidence may become outdated if the change affects conformity.

Brand owner changes the sleeve after receiving the packaging
The change may affect sortability, recyclability or labelling and may require reassessment.

Common misunderstandings

• “If the supplier says PPWR compliant, I am covered.” False. The claim must be supported by evidence.
• “The supplier's technical data sheet is the technical documentation.” False. It may feed the file, but does not replace it.
• “The converter must always give the customer the complete formulation.” False.
• “The EU Declaration of Conformity is the same as a material certificate.” False.
• “The importer can rely only on the Asian supplier's invoice.” False.
• “The distributor has no PPWR obligations.” False.
• “If the material keeps the same code, no reassessment is needed.” False as a general rule. What matters is the actual change and its effect on conformity.
• “All PPWR data must be in a Digital Product Passport.” False.
• “If I pay EPR, I already have the technical documentation.” False. These are separate systems.
• “One certificate can prove all PPWR requirements.” False.

Who pays when the data is wrong?

A supplier provides incorrect recycled-content data.
The converter uses it.
The brand owner reports it.
The problem appears later.

PPWR allocates regulatory responsibility according to the legal roles. But who commercially bears the cost may depend on the contract. Two things must therefore be separated:
regulatory responsibility
from
contractual liability.

What is worth including in contracts?

As industrial recommendations:

• the PPWR roles of the parties;
• the information that must be supplied;
• document format;
• responsible contact person;
• change notification;
• notification period;
• document retention;
• access to relevant evidence;
• confidentiality;
• liability for incorrect data;
• who bears the cost of re-testing after changes.

These are not contract clauses mandated by PPWR. They are tools companies can use to reduce the risk created by an unclear information flow.

What can companies do now?

WHAT I CAN DO NOW

• Map who needs what information across the supply chain.
• Establish the real legal roles of the parties.
• Identify missing documents and data.

WHAT I ASK SUPPLIERS

• Data linked to the applicable PPWR requirements.
• Evidence, not only commercial statements.
• Document revision and validity.

WHAT I PROVIDE TO CUSTOMERS

• The information they need for their legal role.
• The relevant evidence for the correct product and version.

WHAT I PUT INTO CONTRACTS

• Change notification.
• Document format.
• Responsibility for data.
• Confidentiality.
• Access to relevant evidence.

WHAT I PUT INTO ERP / PLM

• Packaging code.
• Material and components.
• Weight.
• Supplier.
• Revision.
• Technical-documentation reference.
• EU Declaration of Conformity reference.

WHAT I ARCHIVE

• Technical documentation, according to the applicable retention periods.
• The EU Declaration of Conformity.
• Economic-operator identification records.
• The versions of the documents and evidence used.

WHAT I MONITOR

• Delegated and implementing acts that will detail methodologies still under development.
• Future requirements concerning digital data carriers.
• Any relevant change to the conformity criteria applicable to the company's own portfolio.

WHAT I WOULD NOT DO YET

• I would not invent a universal PPWR certificate.
• I would not ask suppliers only “are you PPWR compliant?”.
• I would not collect hundreds of PDFs without linking them to a specific product and version.
• I would not disclose unnecessary know-how just to answer a generic questionnaire.
• I would not assume that old documentation remains valid after a relevant material or design change.

Conclusion

PPWR compliance is not built by collecting certificates.

It is built by connecting:
the right data
to
the right product
in
the right version
to
the right legal requirement
and to
the economic operator that carries the obligation.

The practical rule remains:
No data, no evidence. No evidence, no compliance.
And when someone says:
“It is PPWR compliant.”
the next question should be:
“What evidence supports that claim?”

Official Sources

• Regulation (EU) 2025/40 on packaging and packaging waste – in particular Articles 15, 16, 18, 19, 21 and 22.
• Annex VII – technical documentation and conformity-assessment procedure.
• Annex VIII – model EU Declaration of Conformity.
• European Commission Communication C(2026) 3702 – guidance document for Regulation (EU) 2025/40.

Context Sources

• Official information on the Romanian deposit-return system, used solely for the practical SGR example.