PPWR Supplier Documents: What to Request and the Exact Email

Your Conformity Case Lives in Someone Else's Filing Cabinet

Five documents. That is the entire paper trail a PPWR technical file needs from your packaging supplier, and most sellers currently hold none of them.

Here is the structural problem. Regulation (EU) 2025/40 applies from 12 August 2026. From that date, whoever places packaging on the EU market must hold a Declaration of Conformity backed by technical documentation. But the facts that documentation must prove, heavy-metal totals, PFAS content, material composition, sit in a lab folder at your supplier's plant. You sell candles. They made the box. The regulation expects you to vouch for chemistry you never touched.

The fix is administrative, not chemical. You ask your supplier for five specific documents, in writing, with a deadline. This post gives you the list, the exact email, a Chinese version for factories in Guangdong, the escalation path when answers stall, and the folder structure for whatever arrives. If you have not yet mapped your obligations end to end, start with the PPWR compliance checklist and come back.

The 5 Documents to Request

#	Document	What it proves	PPWR basis
1	Supplier Declaration of Conformity	Conformity with Articles 5 to 12	Article 39, Annex VIII
2	Heavy-metals test report or declaration	Pb + Cd + Hg + Cr(VI) at or below 100 mg/kg	Article 5
3	PFAS test report (food-contact only)	Below 25 ppb single, 250 ppb sum, 50 ppm total	Article 5
4	Material composition and recyclability data	What the packaging is made of, how it recycles	Articles 6 and 7
5	Minimisation data	Weight, volume, why the dimensions are what they are	Article 10

1. The supplier's Declaration of Conformity. One page, following the Annex VIII model, signed by a named person, listing the packaging it covers. This is the anchor document. Everything else supports it.

2. Heavy-metals evidence. The sum of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg. This limit carried over from the old Packaging Directive, so any competent supplier has data on file already. A test report from an accredited lab is best. A signed declaration that references test data is acceptable.

3. PFAS test report, food-contact packaging only. From 12 August 2026 food-contact packaging must stay below 25 ppb for any single targeted PFAS, 250 ppb for the sum of targeted PFAS, and 50 ppm for PFAS including polymeric ones. If your packaging never touches food, skip this row and save the lab fee.

4. Material composition and recyclability information. Materials, percentages, coatings, inks, adhesives. You need this for design-for-recycling conformity and, separately, for EPR fee declarations. One spreadsheet from the supplier covers both.

5. Minimisation data. Article 10 requires packaging reduced to the minimum necessary. Ask for weight, volume, and the design rationale behind the current dimensions. If the supplier right-sized the box, they can say why in three sentences.

How to Ask

Three rules. Name the exact products or SKUs, because "all our packaging" produces nothing. Set a deadline three to four weeks out. Send it to your sales contact and copy the quality department if you know it. Suppliers answer specific requests. Vague ones get vague warmth back.

The copy-paste version:

Subject: PPWR compliance documents needed by [date]

Dear [name],

We purchase [product references / SKU list] from you. From 12 August 2026, Regulation (EU) 2025/40 (the EU Packaging and Packaging Waste Regulation) requires us to hold conformity documentation for every piece of packaging we place on the EU market. To complete our technical file, please send us the following by [date]:

1. Your Declaration of Conformity for the packaging listed above, confirming conformity with Articles 5 to 12 of Regulation (EU) 2025/40.
2. A heavy-metals test report or written declaration confirming that the sum of lead, cadmium, mercury and hexavalent chromium does not exceed 100 mg/kg.
3. For food-contact packaging: a PFAS test report against the limits of 25 ppb (any single PFAS), 250 ppb (sum of PFAS) and 50 ppm (PFAS including polymeric).
4. Material composition and recyclability information: materials, percentages, coatings, inks and adhesives.
5. Packaging minimisation data: weight, volume and the design rationale for the current dimensions.

If any of these documents do not yet exist, please tell us which ones and when you expect to provide them.

Kind regards, [Name] [Company, role]

If Your Supplier Is in China, Send This Version

A large share of Europe's e-commerce packaging is converted in China. Send the Chinese version below together with the English letter in the same email: the sales manager reads one, the quality engineer reads the other, and your request no longer depends on whoever at the factory sits closest to a translation app. Your account manager's English is probably fine. The person who actually holds the test reports may never see your English email.

主题：欧盟法规 (EU) 2025/40 (PPWR) 合规文件请求，请于 [日期] 前回复

尊敬的 [联系人姓名]：

您好。我们是贵司包装产品的采购客户 [公司名称]，采购型号为 [产品/SKU 清单]。根据欧盟《包装与包装废弃物法规》(EU) 2025/40（PPWR），自 2026 年 8 月 12 日起，投放欧盟市场的所有包装必须符合该法规要求，我方需为每种包装建立合规技术文件。为此，请贵司于 [日期] 前提供以下文件：

1. 符合性声明（Declaration of Conformity），确认所供包装符合法规 (EU) 2025/40 第 5 至 12 条的要求；
2. 重金属检测报告或书面声明：铅、镉、汞、六价铬四项总和不超过 100 mg/kg；
3. 如为食品接触包装：PFAS（全氟及多氟烷基物质）检测报告，限值为单项 25 ppb、总和 250 ppb、含聚合物在内总量 50 ppm；
4. 材料成分说明及可回收性信息：材料种类、比例、涂层、油墨、粘合剂；
5. 包装减量化数据：重量、体积及现有尺寸的设计依据。

如部分文件暂不齐备，请告知目前可提供的检测报告或第三方认证，以及补齐所缺文件的预计时间。

感谢贵司的配合，期待您的回复。

此致 敬礼

[姓名] [公司名称]，[职位] [电子邮箱] / [电话]

When the Supplier Stalls, or Sits Outside the EU

Silence usually means one of two things: the documents do not exist yet, or your contact does not know where they are. Chase once at the deadline, in writing. Then adjust by supplier type.

Your supplier is a converter. Most packaging suppliers buy board, film or resin upstream and convert it. Your request for a heavy-metals report travels up their supply chain before it travels back down to you. That adds weeks. It is a reason for delay, not a reason for absence, so keep the deadline and ask for a status date.

Your supplier is outside the EU and you import. Then the PPWR's manufacturer-level obligations effectively land on you, and a shrug from the factory does not transfer them back. The guide for non-EU sellers covers the role logic in detail. Practically: if the factory cannot produce test reports, you commission your own. A heavy-metals screen on one material is a routine lab job. A targeted PFAS panel takes longer and costs more. Budget for both if you sell food-contact packaging from a supplier that answers compliance questions with product photos.

The supplier offers a discount instead of documents. Take the discount. Also keep asking for the documents.

Red Flags in Supplier Answers

• "Our packaging is eco-friendly." That is a sentence, not a document. Same for "green", "sustainable" and "100% recyclable" when unaccompanied by data.
• A certificate for a different product. Check that the material, colour and coating on the report match what you actually buy. Suppliers recycle paperwork more reliably than packaging.
• Undated or ancient test reports. A report predating the current material spec proves the old spec.
• "REACH compliant" or "FDA approved" as PPWR proof. Different laws, different substances, different limits. Related, not equivalent.
• No lab name, no method, no standard. A result you cannot trace is a number in a PDF.
• A Declaration of Conformity signed by nobody. Annex VIII expects a name and function. An unsigned DoC is a draft.

Any of these answers means you send one more email: name the gap, restate the deadline, ask whether they can meet it. If the second answer is also a brochure, start pricing your own tests.

Filing What Arrives: The Annex VII Technical File

The PPWR expects the Declaration of Conformity to sit on top of technical documentation as described in Annex VII. Keep it boring and consistent: one folder per packaging type, containing a description of the packaging, the supplier DoC, the test reports, the material composition data and the minimisation rationale. Keep the documentation for five years after the packaging is placed on the market, ten for reusable packaging. When a market surveillance authority asks, you want retrieval to take minutes, because the alternative reads like non-compliance even when it is only disorganisation.

Get Your Version of the Letter

The complydex wizard generates a personalized version of this request letter for free, filled in with your packaging types and supplier situation: start with the wizard. Send it this week. Three to four weeks of supplier lead time is only cheap while August is still far away.