PPWR (EU) 2025/40: what your closure supplier must document per item code

The Packaging and Packaging Waste Regulation (EU) 2025/40 applies since 12 August 2026 and replaces Directive 94/62/EC. For a brand or filler this means one practical thing: your compliance file must hold data per packaging component and per article number. A generic supplier letter is no longer accepted by auditors. This is what a closure supplier should give you, and what we give.

01 · Who is responsible for what

The regulation places obligations on the manufacturer who places packaging on the EU market, on importers and on distributors. When we import a trigger sprayer from China and sell it under our name in the EU, we hold the manufacturer's and importer's duties for that component: technical documentation and a declaration of conformity for the packaging component, retained for five years. You, as the filler, hold the duties for the finished packaging unit (bottle plus closure). Our declaration supports your file; it does not replace your own Declaration of Conformity where you are the producer of the filled packaging.

02 · The six sections of a supplier declaration

1. Bill of materials: every part with material and weight. For a VM-01E: shroud, trigger, closure and nozzle in PP; piston and valve body in PP/PE; SUS304 spring; glass ball; LDPE dip tube. Plastic share by weight 89 to 96 % depending on model.
2. Material breakdown: predominant material PP (resin code 05), PE/LDPE (04), steel, glass, aluminium where used. Recycled content, declared as 0 % today.
3. Substances of concern: sum of lead, cadmium, mercury and hexavalent chromium not above 100 ppm; no REACH SVHC above 0.1 %; no phthalates, PFAS or BPA added.
4. Recyclability: design facts today (mono-material or not, colours, no carbon black, no metallised layers). Grades A, B, C become binding from 1 January 2030; no grade can be issued before the criteria are adopted, and a serious declaration says so.
5. Suitability: intended use and contact with the filled product; food-contact test reports for the resins where relevant.
6. Basis: the factory's supplier declaration, resin technical and safety data sheets, test reports, date and signature.

03 · The timetable

• 12 August 2026: PPWR applies. Substance restrictions, technical documentation, supplier declarations per item code.
• 1 January 2028: design-for-recycling criteria due in delegated acts; harmonised labelling obligation from 12 August 2028.
• 1 January 2030: recyclability grades A, B, C binding; packaging below grade C cannot be placed on the market. Minimum recycled-content targets for plastic packaging start.

REACH runs in parallel: the Article 33 duty to communicate SVHC content is independent of PPWR, and a SCIP notification is owed if any SVHC exceeds 0.1 %.

04 · Wording auditors accept

Per item code, not per product family. Dated and signed, on the supplier's letterhead. Numbers with units and thresholds, not "compliant". A named basis (which factory declaration, which resin documents). A clear statement of what is not claimed: no recyclability grade yet, recycled content 0 %. If your buyer sends a template, the same data fills it.

05 · How to get yours

Send us your article numbers or ours (for example VM-01E-S316) and whether a buyer template must be filled. Declarations are in English and sent on request. See the Compliance page for the request form.

This article describes our understanding of the regulation as of September 2026 and is not legal advice. Check your own obligations with a compliance advisor.