PPWR Compliance Checklist for Exporters: Inventory, PFAS, Evidence

Why start with the packaging inventory?

Because the PPWR reasons by packaging item, not by product or by company. A single bottle of olive oil carries a cap, a seal, a label and an adhesive, and travels in a carton on a stretch-wrapped pallet: so many items with different roles and different obligations. Without an inventory, no answer to a customer questionnaire is reliable.

Step 1: list every packaging reference shipped to the EU, with the fields below. A spreadsheet is enough to start; what matters is that one row matches one reference and that each row has an owner.

For a plastics converter or a printer, add the filling customer and the end use of the packaged product: that is what tells you whether your packaging is in contact with food.

How do you qualify the roles and agree them with the customer?

By applying, reference by reference, the criteria set out by the Commission, then having the result confirmed in writing. There is only one manufacturer per packaging item: normally the brand owner or the filler for sales or grouped packaging, the maker for transport packaging without customer branding, and, where no brand is shown, whoever places the order and sets the specifications.

Step 2: for each row of the inventory, answer five questions.

1. Who fills the packaging, and under which brand?
2. Who set the design specifications?
3. Who places the product on the EU market, in other words who is the importer established in the EU?
4. Does anyone in the EU modify the packaging in a way that could affect its compliance (Article 21)?
5. Is the product sold directly to end users in a Member State, online for example?

Write the answers into a role matrix and send it to your customer for approval. Two traps come up often: believing that a branch in the EU can act as importer, whereas the Commission requires an established entity with a registered address; and forgetting that a logistics company repacking goods in the EU becomes the producer of the transport packaging.

What should you ask your suppliers for?

Verifiable facts about each material, not a general certificate of “PPWR compliance”. According to the Commission, the manufacturer draws up its EU declaration of conformity based on the information and documentation its suppliers provide (Article 16(1)). What you do not ask for, you will not be able to pass on.

Step 3: send each supplier of paper, board, film, varnish, ink, adhesive, closure or cap a written request covering:

• the composition of the material supplied, at the level of detail needed for recyclability (materials, layers, coatings);
• the absence of intentionally added PFAS, and the result of a total fluorine test for materials intended for food contact;
• if total fluorine exceeds 50 mg/kg, proof of the quantity of fluorine measured as PFAS or non-PFAS: Article 5 makes this an obligation, on request, for the manufacturer, importer or downstream user under REACH;
• the food contact declaration of compliance required by EU legislation, for example under Regulation (EU) No 10/2011 for plastics;
• for recycled plastics in contact with food, the origin and the recycling process in light of Regulation (EU) 2022/1616;
• the recycled content and its batch traceability;
• a commitment to report any change of formulation, site or upstream supplier.

In our reading, the operators covered by REACH are established in the EU: if your ink or paper supplier is outside the EU, provide for the same transmission in your purchase contract.

How do you build the PFAS evidence plan?

By following the enforcement logic recommended by the Commission, and starting with the most exposed materials. Since 12 August 2026, food-contact packaging may not be placed on the market if it reaches 25 ppb for any PFAS measured by targeted analysis, 250 ppb for their sum, or 50 ppm for PFAS including polymeric PFAS.

Step 4: prioritise, then test.

The Commission adds that, on the evidence currently available to it, all samples compliant with step 1 are also compliant with steps 2 and 3. Official controls under Regulation (EU) 2017/625 on food contact materials also apply to this limit.

In practice: one test per material and per supplier, repeated at each change; the laboratory’s report, method and limit of quantification kept with the reference; particular attention to grease-resistant papers and boards, coatings and varnishes.

Which recyclability and recycled-content evidence should you gather now?

The evidence already required, and the composition data that will be needed tomorrow. The Commission considers that the general recyclability obligation has applied since 12 August 2026, but that until the harmonised criteria apply, the manufacturer only has to meet the requirements of the former Directive and its standards, such as EN 13430:2004. The conformity assessment under Article 38 and Annex VII is not required for recyclability until the delegated acts under Article 6(4) enter into force.

Step 5: build three files.

• Current recyclability: evidence that the former Directive’s requirements are met, with the harmonised standard used.
• Composition for design for recycling: layers, coatings, adhesives, inks, separable elements. Multilayer structures and material combinations are the first to review before the criteria expected to apply from 1 January 2030 at the earliest.
• Recycled content in plastics: two exemptions apply directly, with no authorisation needed. One covers plastic parts representing less than 5% of the total weight of the packaging unit; the other, food-contact plastics where the quantity of recycled content poses a threat to human health and results in non-compliance with Regulation (EC) No 1935/2004. The manufacturer substantiates them in the technical documentation; for the second, it states the polymer of each plastic part representing 5% or more of the weight and confirms that Annex I to Regulation (EU) 2022/1616 lists no suitable recycling technology and that none is available at industrial scale.

The rates to prepare for are in Article 7. From 1 January 2030, or three years after the entry into force of the implementing act on the calculation method if that is later, every plastic part must contain a minimum share of post-consumer recycled plastic, calculated as an average per manufacturing plant and year: 30% for contact-sensitive packaging with PET as the major component, 10% for contact-sensitive packaging in other plastics, 30% for single-use plastic beverage bottles and 35% for other plastic packaging. From 1 January 2040, these rates rise to 50%, 25%, 65% and 65%. The Article also excludes some packaging, including compostable plastic packaging, the immediate packaging of medicinal products, packaging of medical devices, packaging for the transport of dangerous goods and packaging of food intended for infants and young children. The evidence belongs in the Annex VII technical documentation.

How do you assemble the information sheet for the EU declaration?

By bringing together, in one document per reference, everything the manufacturer must include in its technical documentation. The manufacturer remains solely responsible for the declaration, even if it did not draft it itself; your sheet is what allows it to sign.

Step 6: structure the sheet as follows, with a version number and a date:

1. Identification of the reference, the customer and the manufacturing site or sites.
2. Packaging type, materials, components and weight of each part.
3. Food contact status and the corresponding declaration of compliance.
4. PFAS results, with report, method and batch tested.
5. Recycled content, traceability evidence, and the exemption invoked where relevant.
6. Recyclability data and the harmonised standard applied.
7. Minimisation data: weight, volume, functional justification.
8. Owner of the sheet and the events that trigger its revision.

This sheet feeds the technical documentation that Annex VII requires from the manufacturer. Where applicable, it contains a general description of the packaging and its intended use, the design and manufacturing drawings and the materials of components, the list of harmonised standards, common specifications or other technical specifications applied, a qualitative description of how the assessments of recyclability (Article 6), minimisation (Article 10) and reusability (Article 11) were carried out, and the test reports, together with an analysis of the risks of non-conformity. So attach the packaging drawings and the list of standards applied to the sheet. The EU declaration of conformity (Article 39) follows the model in Annex VIII: number, unique identification of the packaging, name and address of the manufacturer, object of the declaration allowing traceability, other Union acts complied with, standards or specifications used, additional information and signature. It is drawn up for each packaging type, kept up to date, drawn up in or translated into a language required by the Member State where the packaging is placed on the market, and kept with the technical documentation for five years after single-use packaging is placed on the market, ten years for reusable packaging.

For a manufacturer certified to BRCGS Packaging Materials Issue 7, the statement of compliance required for each food-contact product is the right starting point: see our BRCGS Packaging Materials Issue 7 page.

Which mistakes should you avoid, and how do you check you are ready?

The mistakes we see most often come from too much trust in certificates:

• signing a PPWR questionnaire “as manufacturer” when the customer is the brand owner;
• passing on a supplier’s general certificate, with no test result and no link to the reference supplied;
• testing once and forgetting to retest after a change of paper, varnish or supplier;
• ignoring small plastic parts, when the 5% weight threshold decides an exemption;
• believing that stock produced before 12 August 2026 escapes the PFAS limits, when for an imported product only its release for free circulation in the EU counts.

Before answering the next questionnaire, check:

• The inventory covers every reference shipped to the EU, one row per reference.
  
• The role matrix has been approved in writing by each customer.
  
• Each supplier has answered the written request, with evidence attached.
  
• Each food-contact material has a total fluorine test on file.
  
• The recycled-content exemptions invoked are justified in writing.
  
• The composition of multilayer structures is documented.
  
• A versioned information sheet exists for each reference.
  
• Someone tracks Commission acts and triggers the updates.
  

The full context is in our PPWR guide for non-EU exporters, the deadlines in our article PPWR since 12 August 2026, and the budget items in PPWR compliance cost.