For a brand sourcing paper packaging from China for the EU market, the most useful PPWR request is a set of documents tied to the packaging being ordered: its approved specification, component information, relevant supplier declarations and test reports, and the technical documentation supporting the EU declaration of conformity. Together, these should make it possible to understand what was assessed, which requirements it meets and whether the evidence covers the current order.

The EU Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, has generally applied since 12 August 2026. It covers packaging regardless of material or origin, including rigid gift boxes, folding cartons and small corrugated mailers. Some requirements have later application dates, so a useful evidence file distinguishes what applies now from the design requirements being phased in.

The five records to build your request around

Each record has a different job. The specification identifies the packaging; supplier information and testing provide evidence; the technical file explains the conformity assessment; and the declaration records the responsible manufacturer’s conclusion. Some documents come from the packaging supplier, while others must be prepared or held by the business with the relevant legal responsibility.

Establish who prepares the file and issues the declaration

Under PPWR, manufacturer is a legal role. For sales and grouped packaging, this will normally be the filler, often also the product brand owner, even when a separate business physically makes the box. An importer or distributor can also take on manufacturer obligations by placing packaging on the market under its own name or trademark, or by modifying it in a way that could affect compliance. The specific micro-enterprise exception depends on an EU-based supplier; it is not a general exemption for small brands buying directly from China.

The manufacturer must carry out, or arrange, the applicable conformity assessment before placing the packaging on the market. PPWR uses the internal production control procedure in Annex VII: the manufacturer assembles the technical documentation, ensures production remains consistent with it and draws up the EU declaration of conformity. A laboratory provides evidence within its testing scope; the manufacturer retains responsibility for the conformity decision.

The technical file needs enough explanation to make that decision understandable. Annex VII includes, where applicable, the packaging description and intended use, drawings, component materials, standards or technical specifications used, assessment information and test reports. It also requires an adequate analysis and assessment of non-conformity risks. For example, if one material report supports several box sizes, the file should explain which relevant characteristics are shared and why the evidence applies.

The EU declaration then identifies the packaging and responsible manufacturer, references the relevant legislation and standards or other technical specifications, and includes the place, date and authorised signatory’s details. If your brand is the legal manufacturer, request the supplier’s contributions so you can complete your assessment and declaration. Article 16 requires suppliers to provide the information and documentation needed to demonstrate conformity.

An EU importer has its own verification duties, including checking that the manufacturer has completed the required assessment and documentation and that the necessary documents and identification are available. Agree early who will compile the file, who will issue the declaration and how the importer can obtain the evidence. This avoids discovering at shipment time that each party expected another to prepare it.

Make the actual packaging specification the reference for every report

A description such as “paper box” leaves much of the construction unexplained. A rigid box may combine greyboard, printed wrapping paper, adhesive, a surface finish, magnets, ribbon and a fitted insert. A folding carton may add varnish, lamination or a plastic window to its paperboard. A small mailer has liners, fluting, printing and joining or closing materials, with labels or protective inserts added during packing. These differences determine which supplier information and tests are useful.

Ask for a component list linked to a drawing or photograph, with material grades, supplier references and the current revision. Include component weights where available: they help describe the construction and support later design assessments. The specification should also state the intended use, including food-contact status where relevant, and distinguish the sales box from a separate shipping mailer or other packaging layer.

Consider a skincare gift set in a rigid box with a green printed wrap and a black foam insert. An existing supplier report covers greyboard and blue printed paper submitted for a different box. The greyboard result may be useful if its grade and source match the new specification. The green print needs a reasoned assessment of whether the earlier evidence applies, because a colour change can introduce different pigments. The adhesive and foam insert need their own relevant evidence or assessment. The sample schedule reveals these questions much more clearly than the report’s cover-page description.

At CMIC, we can help turn a reference image, product information or an approved sample into this component breakdown. We can then gather the corresponding material references and supplier information, so the laboratory and your team are discussing the same construction. That work also makes it easier to reuse suitable evidence instead of commissioning tests simply because the packaging has a new product name.

What a heavy-metal report needs to establish

For the paper packaging discussed here, Article 5 sets a combined concentration limit in packaging or packaging components: lead + cadmium + mercury + hexavalent chromium must not exceed 100 mg/kg. The limit applies to the sum. In an illustrative result, 60 mg/kg of lead and 50 mg/kg of cadmium would already exceed it, even though each individual result is below 100 mg/kg.

1. Identify the report. Obtain the complete document, including its report number, laboratory, applicant, sample receipt and testing dates, photographs and any appendices.
2. Match the submitted samples. Look for material descriptions and sample codes that can be linked to your component list. A supplier’s written mapping can explain the relationship when laboratory and production references differ.
3. Check what was measured. The evidence should address all four restricted metals. If a report lists total chromium, ask the laboratory how the method and interpretation address the hexavalent chromium requirement.
4. Read the result basis. Check units, detection or reporting limits, the combined result and the criterion used for the conclusion. A test method reference alone does not explain whether the result meets the applicable limit.

“Not detected” means the substance was below the method’s stated detection limit for that sample. It does not mean an absolute concentration of zero. Ask the laboratory to explain how non-detects are treated when assessing the combined limit and, where results are close to the threshold, how measurement uncertainty affects its conclusion. Equally, a detected amount can still fall within the permitted total; detection alone is not a failure.

Sample preparation matters because the limit addresses packaging or packaging components. Mixing a small, highly contaminated component into a much heavier clean board sample can conceal its concentration in the combined result. Where materials have been pooled, ask the laboratory how that sampling approach demonstrates compliance for the relevant components. Separate analysis is useful when a combined result cannot resolve the question.

Use new testing to close specific evidence gaps

PPWR does not prescribe automatic laboratory testing of every component in every case. Reliable supplier information, relevant existing reports and a documented assessment can support the evidence file. Their usefulness depends on traceability: the material, formulation, supplier and intended use must be sufficiently understood to establish that the evidence applies.

New testing becomes valuable when the composition is uncertain, a report cannot be matched to the material, supplier evidence is incomplete, or a change introduces a relevant risk. A new coating formulation may need closer assessment even if the box looks unchanged. Conversely, a revised logo position using the same ink system and construction may be supported by existing evidence, provided its continued applicability is documented.

Article 5 also contains a broader duty to minimise substances of concern. Supplier information about formulations, treatments and relevant chemical hazards helps support that assessment beyond the four-metal result. A useful supplier declaration identifies the material, intended use, requirement addressed and supporting basis, together with a commitment to notify relevant changes.

We can coordinate the supplier information and sample list with a suitable laboratory, ask which uncertainties need analytical work and arrange project-specific testing. Before samples are submitted, the proposed scope should explain what each test will establish and how the results will connect to the approved packaging. Relevant ISO/IEC 17025 accreditation is a useful laboratory competence check; ask which proposed tests fall within its accredited scope.

Add PFAS and food-contact evidence where the use calls for it

The PPWR PFAS limits specifically concern food-contact packaging. A carton around sealed skincare bottles and a paper tray holding unwrapped chocolates therefore need different evidence. For food packaging, establish the intended and reasonably foreseeable contact conditions, including the food type, contact time, temperature and barriers between layers. That gives the supplier and laboratory a basis for selecting the assessment.

Since 12 August 2026, food-contact packaging may not be placed on the EU market with PFAS at or above the Article 5(5) thresholds below. The evidence needs to address the packaging unit as a whole, including associated inks, coatings, varnishes and adhesives.

Current guidance describes a staged analytical approach beginning with total fluorine, with further analysis where needed. Total fluorine screening and targeted PFAS analysis answer different questions, so ask the laboratory to document how its approach supports the Article 5(5) conclusion for your material. Where total fluorine exceeds 50 mg/kg, obtain the required supporting evidence showing the amounts attributable to PFAS and non-PFAS sources. A report should make its analytical coverage understandable, including the limits of any targeted substance list.

Food-contact packaging must also meet Regulation (EC) No 1935/2004 and other applicable food-contact requirements. Keep the relevant supplier documentation and any migration or other safety assessments alongside the PPWR evidence. A content test measures substances in the packaging; a migration test examines transfer under defined contact conditions. A test designed for brief contact with dry food may not support prolonged contact with a fatty food at an elevated temperature.

Include design evidence, with the correct application dates

Chemical testing is one part of the packaging assessment. The general recyclability requirement applies from 12 August 2026, while the detailed design-for-recycling requirements apply from 1 January 2030 or 24 months after the relevant delegated acts enter into force, whichever is later. Keep those stages distinct when requesting evidence or discussing future recyclability grades.

For a paper box, useful design evidence describes the finished structure: fibre materials, coatings, plastic films, adhesives, attached components and how parts separate. Repulpability testing can show how a sample behaves in a defined paper-recycling test process. A broader recyclability assessment also considers the relevant sorting and recycling route. An uncoated board result may need further assessment before it can support a laminated box with a permanently attached insert.

By 1 January 2030, Article 10 requires packaging weight and volume to be reduced to the minimum necessary for its functionality. Its documentation provisions call for the assessment conditions, the design requirements preventing further reduction and relevant tests, studies or other supporting evidence. Structural drawings, component weights and protection testing can therefore contribute to this work.

For a gift set containing two glass fragrance bottles, the insert may need enough depth and separation to prevent the bottles striking each other. Comparing a compact design with a deeper alternative, and recording the relevant protection results, helps explain the space the package needs. That reasoning gives the brand a firmer basis for approving dimensions and materials than a statement that the box is “premium”.

Keep the evidence connected when packaging changes

A useful approval record links the specification revision, component references, reports and conformity assessment. Article 15 requires manufacturers to account for changes in packaging design or characteristics and in the specifications used to establish conformity. Where conformity could be affected, reassessment is required. Build supplier change notification into the purchasing arrangement so a substituted adhesive, board source, ink or coating reaches the responsible team before it becomes an unexplained difference in production.

Reassessment can be focused. Changing a foam insert to folded paper changes the component evidence and may also affect protection, assembly and recyclability. The unchanged outer-box materials may retain useful supporting reports. Record what changed, which conclusions it affects and whether supplier confirmation, further analysis or new testing resolves the difference.

A report’s date tells you when its sample was tested; continued applicability depends on the material, specification, supply controls and requirements. PPWR does not prescribe a fixed testing frequency. Its document-retention periods are a separate matter: manufacturers must retain the technical documentation and EU declaration for five years after single-use packaging is placed on the market, or ten years for reusable packaging. Importers must retain the declaration and ensure the technical documentation can be made available for the corresponding periods.

Where REACH and FSC documents fit

REACH documents address chemical obligations and substance information. For an SVHC screening report, check the substances or Candidate List version covered, the date and the tested components. That information can help with substance assessment, but its precise scope still matters: a screening result for specified substances does not establish every REACH obligation or every PPWR requirement.

FSC chain-of-custody documents address forest-based material sourcing and the control of FSC claims through the supply chain. For an order carrying an FSC claim, request the relevant valid certification information and order or sales documentation carrying the agreed claim. These records answer a sourcing question; heavy-metal content, food-contact suitability and finished-pack recyclability need their own appropriate evidence.

A document request you can send

Subject: PPWR evidence for [packaging reference and revision]

We intend to use this packaging for [product and intended use] on the EU market. Please provide the current specification and component list, identifying materials, relevant supplier references, finishes, inserts and food-contact status.

Please send the relevant supplier declarations and complete heavy-metal test reports, with a clear mapping between tested samples and our packaging components. Where food-contact requirements apply, please include the supporting PFAS and food-contact documentation and explain its coverage.

Please identify who will complete the conformity assessment, hold the technical documentation and issue the EU declaration of conformity for the packaging type. Include available design assessments and identify any further evidence needed for the applicable requirements.

Please also confirm the process for notifying material, formulation or supplier changes. Where additional assessment or testing is proposed, explain the gap it will resolve, the samples needed, and the expected cost and timing.

For a project with CMIC, you can begin with the product details, a packaging drawing or reference sample, intended EU destinations and the reports already available. Through our EU packaging solutions, we can help connect the construction, supplier evidence and appropriate testing, then carry the agreed material and version references into production coordination. Contact us about your packaging so we can identify the useful existing evidence and the specific work needed for your project.