For custom paper packaging going to the EU, ask your supplier for an approved packaging specification, component and material information, relevant assessments and test reports, and the documentation needed to support the manufacturer’s EU declaration of conformity. Production identifiers and change records should connect that evidence to the boxes delivered. The exact handover depends on the supplier’s legal role: a brand owner can have manufacturer responsibilities under the Packaging and Packaging Waste Regulation (PPWR), even when a factory in China makes the packaging.

The European Commission’s packaging overview confirms the PPWR’s general application date of 12 August 2026. Individual requirements have their own timetables. Your documentation should therefore address the requirements applicable when the packaging is first made available on the EU market, with later obligations identified separately.

The documents to request

Establish who prepares and signs the documents

Under Article 3(13) of Regulation (EU) 2025/40, an organisation that has packaging or a packaged product designed or manufactured under its own name or trademark is generally the PPWR manufacturer. The definition includes a specific exception for qualifying micro-enterprises using a supplier in the same EU Member State. That exception does not fit an order supplied from China.

For example, a French brand commissioning its own-brand gift boxes from CMIC in China would hold the manufacturer role under that rule. We would contribute the relevant packaging design, material and manufacturing information as its supplier. The brand’s responsibilities include ensuring the conformity assessment is completed, establishing the technical documentation and drawing up the declaration. Specialist preparation can be arranged on its behalf; responsibility remains with the manufacturer.

Article 16 requires suppliers to provide manufacturers with all information and documentation necessary to demonstrate conformity, including the relevant Annex VII documentation required under Articles 5–11. It must be supplied in paper or electronic form, in a language the manufacturer can easily understand. A business acting as an EU importer also has pre-market checks: it must ensure the manufacturer has completed the assessment and prepared the technical documentation, alongside the applicable identification, labelling and accompanying-document requirements.

Make the specification identify the actual packaging

The specification gives the evidence something definite to describe. For a rigid box, useful information includes the structure, intended use, dimensions, greyboard, wrapping paper, insert, printing, coatings, adhesives and added components such as ribbons or magnets. A bill of materials—a component and material schedule—can connect those parts to material references and supporting documents. It should also identify which items the handover covers, including any separate protective bag or transit packaging.

Small differences matter here. A black surface made from dyed paper can have a different material composition from one made by printing and coating white paper. Both may satisfy the same visual brief, while requiring different supporting information. An approved sample reference, drawing revision and material schedule make that distinction visible.

At CMIC, we can turn the selected structure and finish into these technical inputs and coordinate information from the relevant material or component suppliers. This helps the customer approve the appearance while the underlying specification records how that appearance will be produced.

Check what each test report covers

Supporting evidence can include material declarations, technical assessments and laboratory reports. Each has a distinct function. A material declaration identifies a material and the claim its supplier makes about it. A laboratory report records the results of specified tests on identified samples. The manufacturer must assess whether that evidence is sufficient for the applicable requirement and the packaging concerned.

• Sample identity: Can the tested sample be connected to a component, material grade, colour or finish in the approved specification?
• Assessment scope: Which substances, properties or performance characteristics were examined, using which methods and criteria?
• Results and conditions: Are the units, detection limits, conclusions and relevant limitations available in the complete report?
• Continuing relevance: Have the material, source or manufacturing conditions changed since sampling, and how does the evidence relate to the current order?

A report covering lead, cadmium, mercury and hexavalent chromium supports the stated chemical findings for its identified samples. Recyclability, packaging minimisation and any other applicable requirements need their own assessment and supporting information. Carry each result into the technical file at the scope it establishes. The date of a report is useful, but the connection between its samples and the ordered materials is what makes it relevant.

A rigid-box example. Consider a fragrance gift box with greyboard, a printed paper wrap and a paperboard insert. A chemical report identifies samples of those paper components. During final sampling, the insert changes to fabric-covered foam. The closed box may look almost identical, but its composition, weight and combination of materials have changed. The useful response is to retain relevant evidence for unchanged components, obtain information for the new insert and review how the revised construction affects the packaging assessment.

Article 15(4) requires manufacturers to take account of design and characteristic changes and to reassess where conformity could be affected. This gives change review a practical purpose: identify what changed, which conclusions it touches and what further evidence is needed. It does not turn every revision into an automatic requirement to repeat every previous test.

Intended use also changes the evidence needed. Packaging intended to contact food must meet the applicable food-contact rules as well as PPWR requirements. Article 16(2) brings relevant documentation under Union rules for contact-sensitive packaging into the supplier’s information obligations where appropriate. A heavy-metals report alone cannot answer the separate food-contact questions.

The technical documentation should explain the conclusion

Annex VII requires the manufacturer’s technical documentation to make conformity assessable and include an adequate analysis and assessment of non-conformity risks. It must identify the applicable requirements and cover the relevant design, manufacture and operation of the packaging. In practical terms, it connects the specification and evidence to the conclusion that the packaging meets those requirements.

• A description of the packaging and its intended use.
• Design and manufacturing drawings, component materials and explanations needed to understand them.
• The harmonised standards, common specifications or other relevant technical specifications used, including which parts were applied.
• The solutions adopted to meet requirements where harmonised standards or common specifications were not applied.
• Descriptions of the recyclability, minimisation and reusability assessments under Articles 6, 10 and 11, wherever applicable.
• Relevant test reports.

A useful file lets someone follow the reasoning. If a report covers one insert material, the component schedule should show where that material is used. If a conclusion depends on a particular construction or intended use, that condition should remain visible. A simple index linking requirements, packaging revisions and evidence can make the file easier to maintain; it is a practical format rather than a separately prescribed PPWR form.

Check the EU declaration of conformity

The manufacturer draws up the EU declaration of conformity once conformity with the applicable requirements has been demonstrated. Annex VII calls for a written declaration for each packaging type. Its description and identifiers should allow the declaration to be connected to the approved packaging specification.

• Packaging identification: a unique identification and description that allow traceability.
• Responsible business: the manufacturer’s name and address, and its authorised representative where applicable.
• Responsibility statement: confirmation that the declaration is issued under the manufacturer’s sole responsibility.
• Basis of conformity: the relevant Union legislation and references to the standards or technical specifications used.
• Authorisation: the place and date of issue, the signatory’s name and function, and signature.

These checks come from the Annex VIII model. PPWR uses Module A, internal production control, rather than imposing a general requirement for third-party PPWR certification. A laboratory can supply evidence and specialists can support the assessment, while the declaration remains the manufacturer’s responsibility. CE marking does not demonstrate packaging conformity with PPWR; a CE mark appearing on packaging may concern the product inside.

Connect the final handover to production

Agree the document requirements while the design and commercial terms are being settled. A handover before shipment gives the parties time to resolve missing information; the manufacturer’s legal assessment and declaration duties must be completed before placing the packaging on the EU market. The final records should refer to the approved production version, including agreed substitutions or changes.

Article 15 requires a type, batch or serial number, or another identifying element, subject to its provisions for packaging whose size or nature prevents that information appearing on it. Commercially, an agreed reference connecting the specification, order and production records makes investigations easier. Selected QC records can help show that the specified materials and construction were used. On a reorder, confirmation of the current revision and any material changes helps keep earlier evidence usable.

The manufacturer must retain the technical documentation and declaration for five years after single-use packaging is placed on the market, or ten years for reusable packaging. Importers must retain a copy of the declaration and ensure the technical documentation can be made available to authorities for the same periods. Both manufacturers and importers must provide the relevant documents within ten days of a reasoned national-authority request. Agree upstream document access, contacts and language arrangements that make those duties workable.

Keep later obligations identifiable. For example, Article 24 sets the 50% maximum empty-space deadline for specified grouped, transport and e-commerce packaging at 1 January 2030 or three years after the relevant implementing acts enter into force, whichever is later. That duty concerns operators filling the packaging. Supplier dimensions can support planning, but the handover should distinguish this later operational obligation from the manufacturer’s current conformity documentation.

Obtain reporting data alongside the conformity records

Extended producer responsibility (EPR) involves another role: the legally defined producer, determined by how packaging or packaged products are supplied in the relevant market. Ask the supplier for usable packaging weights by material and an explanation of what each figure includes. The responsible producer can then connect those unit weights to the quantities first made available in each market. Registration and producer-responsibility-organisation records belong to that producer’s arrangements; they serve a different purpose from the packaging’s declaration of conformity.

A sufficient handover lets you identify the packaging, understand the basis of its assessment and reach the right records when a question or change arises. For a CMIC project, we can coordinate specifications, material information and appropriate testing around the approved design, then help connect those inputs to production. If you have a design and EU destination markets in mind, talk with us about the packaging and documentation your project needs.

For the wider sourcing process, see our buyer’s checklist for sourcing PPWR-ready custom paper packaging.