# Supplier Packaging Data Request

Request the facts needed to identify the packaging configuration, its components, constituent materials, weights and controlled technical specifications. If you are the PPWR Manufacturer and the counterparty is a supplier of packaging or packaging materials, Article 16 also requires that supplier to provide the information and documentation necessary for you to demonstrate conformity, including relevant Annex VII technical documentation and information required under Articles 5 to 11.

> A supplier response is source evidence. It is not an EU Declaration of Conformity, test certificate, authority approval or automatic proof of PPWR compliance.

Canonical: https://beyogluprofessional.com/templates/supplier-packaging-data

## Legal role gate

Regulation (EU) 2025/40 Article 16 concerns a supplier of packaging or packaging materials providing the PPWR Manufacturer with conformity-supporting information and documentation.

Article 16 does not set a universal 10-day supplier-response deadline. The 10-day rule in Article 15(10) concerns the Manufacturer responding to a reasoned request from a national authority. A return date in this engine is therefore a commercial workflow date unless another binding rule or contract applies.

Manufacturer and EPR Producer are separate PPWR roles. The engine asks which role you hold before it selects legal language.

Official EU source: https://eur-lex.europa.eu/eli/reg/2025/40/oj
Commission guidance: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52026XC03084

## Request modes

- PPWR Article 16 Request: Use only when you are the PPWR Manufacturer and the counterparty supplies packaging or packaging materials to you.
- EPR Operational Data Request: Use when packaging facts are needed for EPR operations but Article 16 is not asserted as the legal basis.
- Combined PPWR + EPR Request: Use when the same requester is both PPWR Manufacturer and EPR Producer and the Article 16 supplier relationship is present.

## Evidence request matrix

- **Packaging specification / revision** — PPWR Annex VII / factual source. Identify the packaging configuration and controlled revision.
- **Packaging component / bill of materials** — PPWR Annex VII. Identify components and constituent materials.
- **Material composition** — PPWR Articles 5-11 / Annex VII. Support material classification and conformity assessment.
- **Component weight and tolerance** — PPWR Annex VII / EPR operations. Support packaging mass calculations and EPR reporting facts.
- **Supplier technical declaration** — PPWR Article 16 where applicable. Document the supplier's stated facts and document references.
- **Substances in packaging information** — PPWR Article 5. Support the manufacturer's Article 5 assessment.
- **Lead/cadmium/mercury/Cr(VI) evidence** — PPWR Article 5(4). Support the 100 mg/kg aggregate heavy-metals requirement.
- **Recyclability / design evidence** — PPWR Article 6. Support the applicable recyclability assessment.
- **Packaging minimisation inputs** — PPWR Article 10 / Annex IV. Support weight/volume minimisation assessment.
- **Supporting specification / technical record** — PPWR Annex VII. Retain drawings, standards and controlled technical references.
- **Contact-sensitive Union-law documentation** — PPWR Article 16(2). Article 16 incorporates applicable Union documentation for contact-sensitive packaging.
- **Food-contact declaration / applicable compliance documentation** — Applicable Union food-contact law. Support intended food-contact use.
- **PFAS / total fluorine evidence** — PPWR Article 5(5). Food-contact packaging PFAS restrictions apply from 12 August 2026.
- **Migration / intended-use evidence** — Applicable Union food-contact law. Support intended conditions of use where relevant.
- **Recycled-content evidence** — PPWR Article 7. Support recycled-content facts and applicable technical documentation.
- **Recycled-plastic food-contact evidence** — Applicable Union law where food-contact. Required where recycled plastic is intended for food contact.
- **Reusability / rotations / system evidence** — PPWR Article 11. Support the reusable-packaging assessment and intended rotations.
- **Compostability evidence** — PPWR Article 9. Support applicable compostability requirements.
- **Composite / multi-material constituent breakdown** — PPWR Annex VII / EPR data. Separate constituent materials and weights rather than treating a composite as a single unknown material.

## How it works

1. **Choose the legal basis** — Separate Article 16 from ordinary EPR data collection before writing the request.
2. **Describe the packaging scope** — Identify products, configurations and packaging components the supplier must address.
3. **Apply conditional evidence** — Food-contact, reusable, compostable and other profiles add the relevant evidence requests.
4. **Generate the request package** — Create the corporate PDF and structured supplier-response workbook.
5. **Record real issue and response evidence** — Generated does not mean sent; sent does not mean answered. Lifecycle states require actual evidence.
6. **Review and hand off facts** — Accept only reviewed source facts, then export supplier-owned packaging fields to the Packaging Data Engine.

## Natural questions

### Can I demand packaging data from my supplier under PPWR Article 16?
Article 16 applies where the counterparty is a supplier of packaging or packaging materials and you are the PPWR Manufacturer. If you only need data as an EPR Producer, use the operational request mode unless the Article 16 relationship also exists.

### Does my supplier have 10 days to reply?
Article 16 itself does not create a universal ten-day supplier-response deadline. Article 15(10) gives the Manufacturer ten days to provide documents following a reasoned request from a national authority.

### What should I request for food-contact packaging?
In addition to composition and weight facts, the request should include applicable contact-sensitive Union-law documentation. PPWR Article 5 also applies PFAS limits to food-contact packaging from 12 August 2026.

### Does a supplier declaration prove PPWR compliance?
No. It is source evidence used in the Manufacturer's conformity assessment and technical documentation. The Manufacturer remains responsible for the applicable conformity duties.

### Can supplier data be reused for EPR reporting?
Measured component, material and weight facts can feed the Packaging Data & EPR Declaration Engine. Seller-owned facts such as units placed on market, reporting period, PRO and national classification stay outside the supplier workbook handoff.

### What should I ask for composite packaging?
Request the constituent-material breakdown and, where available, the weight or proportion of each material instead of recording the package as one unknown composite.
