Model letter to your suppliers: How to request packaging data for PPWR conformity in a structured way

The declaration of conformity is one page, the technical documentation a folder, and both fail at the same point: the data that only the supplier has. Which heavy metals are in the printing ink, which polymer in the inner bag, how much fluorine in the coating? Since 12 August 2026, Article 16 of Regulation (EU) 2025/40 has obliged your suppliers to provide this information. What the Article does not govern is how you ask, what you ask and what you do when no answer comes.

This article answers that. It shows which details you need per component, what a letter that gets answered looks like, what the supplier confirms in its declaration and how the answers flow into your technical documentation. At the end there is a package to download: the model letter and supplier declaration in German and English, as well as a query table (Excel).

What Article 16 requires of your suppliers

Article 16(1) is short: suppliers "shall provide the manufacturer with all the information and documentation necessary for the manufacturer to demonstrate the conformity of the packaging and the packaging materials with this Regulation, including the technical documentation referred to in Annex VII and required under or pursuant to Articles 5 to 11, in one or more languages which can be easily understood by the manufacturer." On paper or electronically. Paragraph 2 adds that for contact-sensitive packaging, the documentation required under the relevant Union legal acts also forms part of this, for example the declaration of compliance under Regulation (EU) No 10/2011 for plastics in contact with food.

Under Article 3(1)(16), a supplier is anyone who supplies packaging or packaging material to a manufacturer. That covers the carton manufacturer just as much as the film supplier, the printing ink manufacturer and the adhesive supplier, because the heavy metal limit in Article 5 applies to the packaging unit including printing inks, varnishes and adhesives (Commission FAQ, section III). For PFAS, the Regulation goes a step further: where the total fluorine content exceeds 50 mg/kg, manufacturers, importers and downstream users within the meaning of the REACH Regulation must, on request, provide the manufacturer with proof of what share of the fluorine is attributable to PFAS (Article 5(5)(c)).

The Commission has made clear in its FAQ that suppliers cannot refuse to cooperate and that responsibility for the declaration of conformity and the documentation nevertheless remains with the manufacturer (section X, question 4). There is one limitation you should know: the German Packaging Implementation Act contains no fine provision for Article 16. The duty to cooperate is a statutory obligation, but its enforcement runs through the contract and through market surveillance, which demands the evidence from you, not from your supplier. The letter is therefore not a formality but your most important tool.

Which information you really need

The most common mishap is an unspecific request: "Please confirm the PPWR conformity of your products." What comes back is a sentence that cannot be used in any technical documentation. Instead, ask per component for the information that Annex VII and Articles 5 to 11 actually require, separated into what applies today and what you should already be collecting for 2028 and 2030.

Two clarifications from the FAQ prevent misdirected requests. Adhesives, paints and printing inks do not count as plastic for the recycled content (section V), but they very much do count towards the heavy metal limit. And a test report is not mandatory: under Article 16, supplier declarations are also valid documents. Whether you settle for that is a matter for your risk analysis; for printing inks, recycled material and food contact you should insist on a test report, for an unprinted corrugated board box the declaration is enough.

Who owes what

Before you write, clarify your supplier's role for each packaging, because that determines whether you request data or a declaration of conformity.

If your supplier provides packaging or material that you fill or place on the market under your own name, it is a supplier under Article 16. You are the manufacturer, you issue the declaration, it supplies the data.

If it supplies dimensionally stable transport packaging without your brand, such as pallets or crates, it is itself the manufacturer of that packaging. In that case you request its EU declaration of conformity, not its raw data. For stretch film and strapping band, the Commission and the Central Agency Packaging Register (Zentrale Stelle Verpackungsregister, ZSVR) determine the manufacturer differently; request both, declaration and substance data, and you are covered on either reading. The details are set out in Does the PPWR apply to B2B? Transport packaging, pallets, stretch film, strapping and used cartons.

If you are a microenterprise with fewer than ten employees and no more than two million euros in turnover, and your supplier is established in the same Member State, the supplier is the manufacturer of your own-brand packaging and owes you the declaration of conformity (Article 3(1)(13), Article 15(12)). More on this in Microenterprises, small businesses and online retail. The full role logic: Manufacturer or producer? Which role your company has under the PPWR.

The letter: structure and tone

A letter that gets answered has six elements.

The occasion in two sentences: you are a manufacturer within the meaning of Regulation (EU) 2025/40, since 12 August 2026 you have had to demonstrate the conformity of your packaging, and for this you need information on the components you source from the supplier.

The legal basis in one sentence, with Article 16(1) and the note that the information can be provided in a language easily understood by you and in electronic form.

The specific request: which of the supplier's articles are affected, which information you need for each component, and in what format. Refer to the attached table or your portal so that the answer comes back in structured form.

The deadline, set realistically. Four weeks are reasonable if the supplier has the data; for test reports that first have to be commissioned, six to eight weeks. Give the date, not "promptly".

The assurance of confidentiality. Formulations and test reports are sensitive for many suppliers. Undertake to use the documents solely for the conformity documentation and to disclose them only to the authorities.

The contact person and the request to let you know if the supplier cannot provide individual items, so that you are not left waiting for the rest.

What does not belong in it: threats of fines that do not apply to the supplier under German law, and catch-all wording such as "all relevant evidence under the PPWR". The more precise the question, the more usable the answer.

An excerpt from the model letter in the download package:

The supplier declaration: what the supplier confirms

The declaration is the document you will later file in the technical documentation as the basis of evidence. It must therefore be as precise as the declaration of conformity itself. In the download package it has seven parts: the identity of the supplier, the affected articles with their components, the confirmation of the heavy metal limit for each component stating the basis of evidence, the PFAS information for food contact, the statement on substances of concern, the information on recycled content and material composition, and the commitment to report changes without being asked, with signature, function and date.

There are three formulations you should not accept. "Compliant to the best of our knowledge" without stating what that knowledge rests on. "Complies with the PPWR" without naming the Articles and limit values. And a declaration that applies to "all products supplied" without naming articles or components, because such a declaration cannot later be assigned to any packaging type.

The declaration does not replace a test report where your risk analysis calls for one, but it turns a data sheet into an assurance with a name and a date. That is precisely what Annex VII needs.

The query table

The Excel table in the download package is structured so that the answers fit directly into the structure of the technical documentation: one row per component, columns for master data, substance data with the basis of evidence, PFAS for food contact, recycled content and recycling characteristics, change commitment and sign-off. Drop-downs keep the answers consistent, an example row shows the expected format, and an evaluation counts which rows are complete and which are above the limit.

More important than the tool is the logic behind it: ask per component, not per article, because what is assessed is the unit made up of its parts, and the declaration must list the components (Commission FAQ, section XV, question 5). Ask for figures with units, not for yes or no. And ask for the basis of evidence, because "below 100 mg/kg" is worthless for the risk analysis without knowing whether that is a test report or an estimate.

When the supplier does not respond

It happens, and the Regulation recognises the situation. For packaging whose supplier no longer exists or does not react, the Commission requires the manufacturer to make demonstrable efforts to obtain the information, to carry out its own assessments if need be, and to document those efforts (FAQ, section X, question 6). The result is an escalation ladder.

First reminder after the deadline expires, with a new deadline of two weeks. Second reminder to the supplier's management, referring to Article 16 and to the fact that without the information you can no longer place the packaging on the market, which for the supplier means the order is at stake. In parallel: your own assessment on the basis of the available data sheets and, where the risk justifies it, your own test reports at your expense, which you can later invoice to the supplier if the contract allows for it. Record every step with its date in the technical documentation, because precisely this documentation is your argument in dealings with market surveillance.

Where a supplier permanently fails to deliver, that is a procurement risk, not a compliance problem, and should be treated as such in purchasing.

Contractual safeguards

Article 16 gives you the claim, a contract gives you the enforcement. Since 2026, purchasing conditions and supply contracts should contain five points: the supplier's obligation to provide the information under Article 16 for each component before the first delivery and upon every change; the format, that is your table or your portal; the basis of evidence, that is when a test report is required; the duty to notify changes to the material, formulation, sub-supplier or production site; and who bears the costs of testing that becomes necessary because information is missing. How you frame this legally is a matter for your legal department; this article does not replace legal advice.

The most common mistakes

1. Asking blanket questions. "Please confirm PPWR conformity" delivers a sentence, not data.
2. Querying only the main component. Printing inks, varnishes and adhesives belong in the heavy metal balance and are regularly forgotten.
3. Demanding the declaration of conformity from the supplier although you are the manufacturer. The supplier owes data; you issue the declaration.
4. Demanding only data from the pallet maker although it is the manufacturer. Here you need its declaration.
5. Not asking for the basis of evidence. A value that does not state whether it rests on a test report or an estimate does not support the risk analysis.
6. Accepting only English when the authority demands German. Article 16 requires a language you understand; for the authority, Article 15(10) applies.
7. Asking once and never again. Without change notifications you do not know when your documentation is out of date.

How Polygon One helps

In the Polygon One supplier portal, you request the information per packaging unit and component with one click. The supplier receives a link with no registration required and chooses, for each item, whether to upload an existing document, enter the component data in a guided form or pass the request on to their own sub-supplier, whose answer flows back into the same request. Two rules safeguard quality: every substance statement under Article 5 must be backed by a test report or supplier declaration, otherwise the answer cannot be submitted, and before submitting, the supplier confirms the accuracy and completeness of their information, stored in audit-proof form.

You see the status of each request, handle queries in the message thread and transfer the data directly to the component from which the technical documentation and the declaration of conformity are later generated. Corrections run through a reopening that you approve. What the portal does not do: force the supplier to answer or assess test reports. It makes asking and collecting so easy that the response rate rises, and it documents every step in case it does not.

If you would like to see how a data request to your suppliers looks, book a demo or read more on the product page for the PPWR module.

Download the package

The package contains the model letter and the supplier declaration, each in German and English, as well as the query table as an Excel file with instructions, an example row, drop-downs and an evaluation. All documents reflect the position as of September 2026 and refer to the articles that apply today.

• Download: Model letter and supplier declaration, German and English (DOCX)
• Download: Query table for packaging components (XLSX)

Frequently asked questions

What information do I have to obtain from my packaging supplier?

For each component, material and mass, the heavy metal value with the basis of evidence, for food contact the PFAS information, a statement on substances of concern and a commitment to report changes. For 2028 and 2030, additionally material composition, recycled content and recycling-relevant characteristics.

Who in the supply chain is responsible for the declaration of conformity?

The manufacturer, which for sales and grouped packaging means as a rule the filler or the brand owner. The supplier supplies the data under Article 16 and does not itself issue a declaration, unless it is the manufacturer for the packaging concerned, for example for unbranded pallets.

What applies if my supplier is a microenterprise?

The microenterprise rule concerns not the supplier but the commissioning party: if the brand owner is a microenterprise and its supplier is established in the same Member State, the supplier is the manufacturer. A microenterprise acting as a supplier has the same duty to cooperate as any other.

Does the supplier have to provide a test report?

Not necessarily. Under Article 16, supplier declarations are also valid documents. Whether you require a test report is decided by your risk analysis under Annex VII.

In which language must the supplier provide the information?

In one or more languages that you can easily understand. For submission to the authority, Article 15(10) additionally applies, that is a language easily understood by the authority.

What do I do if the supplier is based in a third country and does not respond?

The same escalation as with any other supplier, plus your own assessment and test reports, with documentation of all attempts. Without robust data, you may not place the packaging on the market.

Sources and status: Regulation (EU) 2025/40 (OJ L, 22.1.2025), Articles 3, 5, 15, 16, 21 and Annex VII. Commission FAQ on the PPWR, 2nd edition (August 2026), sections II, III, V, X and XV. Commission guidance document C/2026/3702, section 5. Packaging Implementation Act, Federal Law Gazette 2026 I No 207, Section 66. This article describes the legal position as of September 2026 and does not replace legal advice.