PPWR Technical Documentation and Declaration of Conformity (Part 2): How to Build a Complete Packaging Compliance Evidence Chain?

In Part 1, we examined the PPWR requirements for technical documentation, the EU Declaration of Conformity, and the respective responsibilities of manufacturers, suppliers and importers.

However, an important practical question remains for packaging procurement: how should material certificates, laboratory test reports, supplier declarations and manufacturing records be organised to support a packaging product's conformity assessment?

For example, a garment packaging bag made from GRS-certified recycled PE may involve raw material specifications, recycled content evidence, supply chain traceability, product structure information and recyclability assessment. Although these documents all relate to the product, they do not demonstrate the same things.

The PPWR requires businesses to establish technical documentation based on the applicable regulatory requirements for the packaging concerned. The objective is not simply to collect as many certificates as possible, but to ensure that each document supports a relevant claim or assessment.

This article examines the roles of certifications, laboratory test reports, packaging changes and supply chain documentation, explaining how businesses can build a more complete PPWR compliance evidence chain.

1. What Roles Do GRS, FSC and EN 13432 Play in PPWR Compliance?

Different certifications and standards address different material characteristics, supply chain requirements or product properties. They may support specific parts of a packaging product's technical documentation, but they do not automatically demonstrate full compliance with the PPWR.

1.1 GRS and EN 15343: Supporting Recycled Material Claims and Traceability

For packaging made from recycled PE, PP, CPE or other plastics, buyers often need to understand the origin, recycled content and traceability of the materials used.

The Global Recycled Standard (GRS) is a voluntary certification standard covering recycled material content, chain of custody and certain environmental and social requirements.

EN 15343 is a technical standard concerning the traceability and assessment of recycled content in recycled plastics. It should not automatically be described as a separate mandatory PPWR certificate.

In practical procurement, relevant certification and transaction documents may help businesses verify:

• The origin and supply chain information of recycled materials.
• Recycled content declarations within the applicable certification scope.
• Raw material purchasing and transaction records.
• Traceability throughout the relevant supply chain.

However, PPWR Article 7 establishes specific minimum recycled content requirements for applicable plastic packaging. These requirements concern recycled content recovered from post-consumer plastic waste and are subject to prescribed calculation and verification rules.

Plastic Packaging Category	By 1 January 2030*	By 1 January 2040
Contact-sensitive packaging made from PET as the major component, excluding single-use plastic beverage bottles	30%	50%
Contact-sensitive packaging made from plastics other than PET, excluding single-use plastic beverage bottles	10%	25%
Single-use plastic beverage bottles	30%	65%
Other plastic packaging	35%	65%

*The 2030 targets apply from 1 January 2030 or three years after the entry into force of the implementing act referred to in Article 7(8), whichever is later. Certain packaging categories are exempt under Article 7(4).

The calculation is based on the average recycled content per manufacturing plant, per year, and by the relevant packaging type and format.

Article 7 also specifies the conditions for qualifying post-consumer recycled plastic, including requirements concerning collection and recycling.

Therefore, a GRS certificate or Transaction Certificate (TC) may support recycled material claims and supply chain traceability, but it cannot independently replace the recycled content calculation and verification required under the PPWR.

1.2 FSC: Supporting Paper-Based Material Sourcing and Chain of Custody

For paper-based packaging, such as glassine paper bags, FSC certification can support claims concerning forest-based material sourcing and chain of custody within the applicable certification scope.

Relevant FSC documentation may help buyers understand:

• The sourcing information of paper materials.
• Certification management throughout the supply chain.
• Whether the paper material falls within the relevant certification scope.

However, FSC certification does not independently demonstrate that packaging meets the PPWR requirements for recyclability, minimisation or other technical performance.

For paper-based packaging, businesses still need to consider the paper composition, coatings, laminated structures, printing inks and other components when identifying applicable regulatory requirements and supporting evidence.

1.3 EN 13432 and OK compost: Supporting Compostability Claims

For compostable materials such as PLA+PBAT, EN 13432 and relevant OK compost certification can support claims concerning compostability under the conditions and scope covered by the applicable standard or certification.

Two concepts should be distinguished:

• Compostable: A material meets specified requirements for biodegradation and other composting properties under defined composting conditions.
• Recyclable: Packaging is designed to enable material recovery in accordance with applicable recyclability requirements.

These concepts are not interchangeable.

Under Article 9, the PPWR does not require all plastic packaging to be compostable.

Article 9(1) specifically addresses packaging referred to in Article 3(1)(1)(f) and sticky labels affixed to fruit and vegetables. These must meet the applicable industrial composting requirements. Home-composting compatibility is also required where Member States impose such requirements.

Under Article 9(2), Member States may require additional specified packaging categories to be compostable, provided that the relevant waste collection and treatment infrastructure conditions are met.

Importantly, Article 9(3) states that other packaging, including packaging made from biodegradable plastic polymers and other biodegradable materials, must be designed for material recycling in accordance with Article 6, without affecting the recyclability of other waste streams.

Therefore, using PLA+PBAT or obtaining EN 13432 certification does not automatically demonstrate compliance with all PPWR requirements.

The applicable requirements must be assessed according to the packaging category, intended application and relevant national provisions.

1.4 RoHS and REACH: Supporting Information on Regulated Substances

RoHS and REACH belong to regulatory frameworks separate from the PPWR.

Where applicable, relevant test reports and declarations can provide supporting information about certain regulated substances in packaging materials.

• Specific restricted substances in materials.
• Test results for relevant chemical substances.
• Material composition information supplied by manufacturers.

However, RoHS or REACH reports cannot replace PPWR technical documentation or independently demonstrate full compliance with the PPWR.

Businesses must still determine whether additional testing or assessment is necessary based on the packaging materials, intended use and applicable regulatory provisions.

The key principle is that each certificate and test report has a defined scope. PPWR conformity assessment must connect the available evidence with the actual packaging product and its applicable legal requirements.

2. Can Laboratory Test Reports Replace the PPWR Declaration of Conformity?

No.

A Laboratory Test Report is an important supporting document for conformity assessment, but it has a different legal purpose from an EU Declaration of Conformity.

A test report records the results obtained from a particular sample under specified test methods and conditions. An EU Declaration of Conformity is the formal declaration drawn up by the manufacturer after the applicable conformity assessment has demonstrated compliance.

Document Type	Main Purpose	Important Consideration
Heavy Metal Test Report	Tests applicable heavy metal parameters	Results must be assessed against relevant limits and scope.
PFAS Test Report	Supports PFAS assessment where applicable	The specific PPWR PFAS restrictions under Article 5 concern food-contact packaging.
Material Composition Report	Identifies material composition	Must correspond to the actual packaging structure.
Recycled Content Evidence	Supports recycled content claims	Must follow Article 7 calculation and verification rules.
Recyclability Assessment	Supports recyclability assessment	Must consider applicable design-for-recycling requirements and methods.
Packaging Minimisation Assessment	Supports packaging reduction assessment	Must consider functionality, weight, volume and relevant performance criteria.

First, not every packaging product requires all the tests listed above.

The applicable tests depend on material composition, intended use and the relevant regulatory requirements.

For example, the specific PFAS restrictions in Article 5 apply to food-contact packaging. They should not be presented as a universal PFAS testing obligation for all apparel packaging bags.

Second, test reports must be relevant to the actual packaging product.

If a report covers one raw material but the finished packaging uses different materials, inks, adhesives or laminated structures, the manufacturer must assess whether the original report remains relevant.

The sample identification, material specifications, testing methods and results should be traceable to the packaging under assessment.

References: PPWR Article 5 – Substances of Concern and Annex VII – Technical Documentation.

3. Do Changes in Packaging Materials, Dimensions or Structures Require Reassessment?

Packaging does not automatically remain compliant indefinitely after its initial conformity assessment.

Under Article 15(4), manufacturers must establish procedures to ensure that series production remains in conformity with the PPWR.

Manufacturers must take appropriate account of changes in packaging design, product characteristics and relevant technical specifications. Where they find that conformity could be affected, they must carry out a reassessment under Article 38 or have it carried out on their behalf.

Type of Change	Key Areas to Review
Raw material changes	Material composition, substance restrictions and recycling compatibility.
Recycled content changes	Recycled content calculation and supply chain traceability.
Film thickness changes	Material consumption, product protection and minimisation assessment.
Packaging dimension changes	Packaging volume and relevant functional performance.
Printing process changes	Ink composition and potential effects on material recycling.
Closure structure changes	Component materials and overall packaging structure.
Material supplier changes	Material specifications, sourcing and supporting documentation.

Not every change in dimensions, printing or suppliers automatically triggers a complete reassessment.

The key question is whether the change could affect compliance with the applicable regulatory requirements. The technical documentation and assessment records should be updated according to the actual impact.

Example: A Custom PE Self-Adhesive Bag

Suppose a garment packaging bag initially uses conventional PE film with a specified thickness and self-adhesive closure.

During subsequent production, the customer requests several changes:

• Replace the original material with PE containing recycled content.
• Reduce film thickness to lower material consumption.
• Change the adhesive strip supplier.
• Adjust bag dimensions and closure positioning.

These changes may affect the original material information, recycled content evidence, packaging minimisation assessment and product structure documentation.

The manufacturer should review whether the existing technical documentation remains applicable and identify any additional evidence or assessment required.

For example, reducing film thickness does not automatically demonstrate compliance with Article 10.

The manufacturer must assess whether the packaging weight and volume have been reduced to the minimum necessary to ensure its functionality, taking into account the relevant performance criteria in Annex IV.

Article 10(4) requires the relevant technical documentation to include information such as:

1. The technical specifications, standards and conditions used to assess packaging performance.
2. The design requirements that prevent further reduction of packaging weight or volume under the relevant performance criteria.
3. Test results, studies or other relevant sources used to assess the minimum necessary weight or volume, including modelling and simulations where appropriate.

Therefore, packaging minimisation is not simply a matter of reducing film thickness. It requires a technical assessment of the packaging's actual function and performance.

References: PPWR Article 15(4) and PPWR Article 10 – Packaging Minimisation.

4. How Can Businesses Establish a Complete PPWR Compliance Evidence Chain?

From a practical packaging procurement and manufacturing perspective, businesses should not wait until a customer requests compliance documents before collecting material information and test reports.

A more effective approach is to integrate documentation management into packaging development, purchasing and production.

Step 1: Identify the Packaging Product and Applicable Requirements

First, identify the packaging category, material composition, intended use and target market.

• PE self-adhesive bags.
• GRS recycled plastic grip seal bags.
• PLA+PBAT compostable zipper bags.
• FSC glassine paper bags.
• Cellulose film packaging bags.

Different materials and structures may involve different regulatory requirements. The same assessment approach should not automatically be applied to every packaging product.

Step 2: Collect Raw Material and Supply Chain Information

Collect relevant information from raw material and packaging component suppliers.

Depending on the product, this may include:

• Raw material specifications and composition information.
• Material supplier details.
• Relevant certificates and their scope.
• Recycled material sourcing and transaction traceability records.
• Applicable laboratory test reports.
• Information about adhesives, printing inks and other components.

Particular attention should be paid to whether the documents correspond to the materials actually purchased and used in production.

Step 3: Establish Product-Specific Technical Information

Organise the technical information according to the actual packaging structure.

• Product design drawings.
• Packaging dimensions and film thickness.
• Material composition and component information.
• Manufacturing process descriptions.
• Intended use.
• Applicable technical standards and specifications.

The documentation should accurately describe the finished packaging product rather than simply presenting the manufacturer's general production capabilities.

Step 4: Carry Out the Applicable Conformity Assessments

Complete the necessary tests, calculations and technical assessments according to the applicable PPWR provisions.

These may include:

• Recyclability assessment.
• Recycled content calculation and verification.
• Packaging minimisation assessment.
• Reusability assessment, where applicable.
• Assessment of substance restrictions.

Not every packaging product requires every assessment. The applicable scope must be determined according to the product and relevant legal provisions.

Step 5: Establish Technical Documentation and Draw Up the Declaration of Conformity

The economic operator legally responsible as the manufacturer must complete the relevant work in accordance with Articles 15, 38 and 39 and Annexes VII and VIII.

Technical documentation and the EU Declaration of Conformity cannot simply be generated from generic supplier certificates.

They must be based on the actual packaging product and the relevant conformity assessment.

Step 6: Maintain Documentation and Production Consistency

After the initial assessment, businesses must continue monitoring changes in materials, packaging structures and manufacturing processes.

Where a change could affect conformity, the manufacturer should carry out the necessary reassessment and update the relevant technical documentation and declaration.

This approach helps connect product information, supplier records, test results and the final declaration into a traceable evidence chain rather than keeping individual documents in isolation.

5. How Can Packaging Suppliers Support Customers with PPWR Documentation?

For European apparel brands and packaging buyers, selecting a supplier involves more than evaluating material options, prices and production capacity.

It is also important to consider whether the supplier can provide accurate, complete and product-specific technical information.

A packaging supplier may not necessarily be the Manufacturer under the legal definition of the PPWR. However, under Article 16, suppliers must provide the necessary information and documentation to manufacturers to support conformity assessment.

Suppliers with reliable manufacturing, material management and documentation capabilities can therefore help reduce information gaps during packaging development and compliance preparation.

Goolien's Packaging Manufacturing and Documentation Support

Dongguan Goolien Packing Technology Co., Ltd. has 23 years of industry experience and a production base of more than 5,000 square metres. Our integrated manufacturing processes cover film extrusion, precision printing, bag making and quality inspection.

Our product range includes recycled plastic packaging, compostable packaging, paper-based packaging and other customised packaging solutions.

Our main material options include:

• PE, PP, OPP and CPE plastic materials.
• PLA+PBAT compostable materials.
• FSC-certified paper materials within the applicable certification scope.
• Cellulose film.

We hold relevant certifications including GRS, FSC, OK compost and EN 13432, within their respective certification scopes. We can also provide relevant EN 15343-related technical information where applicable.

We support customised bag styles, dimensions, thicknesses, printing designs and closure structures.

Depending on the actual materials and products involved, we can assist customers by providing relevant material specifications, certification documents, supply chain information and supporting technical documentation.

From material selection and packaging structure development to finished bag production, we aim to provide customised packaging solutions that balance functionality, product presentation and manufacturing requirements.

It is important to clarify that supplier certificates and technical information support the customer's conformity assessment. They do not automatically transfer or replace the legal responsibilities of the manufacturer under the PPWR.

Conclusion

PPWR compliance is not simply about collecting environmental certificates or preparing a declaration after packaging production has been completed.

What matters is whether businesses can connect packaging materials, product structures, supply chain information, test results and conformity assessment evidence into a complete, accurate and traceable technical documentation system.

For packaging manufacturers and suppliers, providing reliable product and material information is an important part of supporting customers' conformity assessments.

For brand owners and importers, understanding their legal responsibilities, verifying supply chain documentation and managing packaging changes are essential steps in reducing market access risks.

A compliant packaging product needs more than a certificate. It needs traceable materials, reliable technical evidence and a properly documented conformity assessment.

//www.goolien.com/