Documenting Packaging Materials: Material Register and Supplier Declarations for EU Customers

Anyone supplying customers in the EU needs a complete register of all packaging components, current supplier declarations and technical data that match the packaging actually used. Since 12 August 2026, packaging placed on the market needs technical documentation and an EU declaration of conformity, and EU customers request the necessary information from their suppliers. What matters is that the individual details can be brought together for every composite packaging.

Why documentation matters now

The Packaging Regulation (PPWR), Regulation (EU) 2025/40, has required a conformity assessment with technical documentation and an EU declaration of conformity since it became applicable. The substance restrictions under Art. 5 come on top. Who issues the declaration depends on the role in the supply chain, that is, on who places the packaging on the market in the EU. For manufacturers from Bosnia and Herzegovina and Serbia this is often the EU customer; in Croatia the regulation applies directly. More on the roles is explained in the guide PPWR for suppliers outside the EU.

The amount of data grows with the later obligations: recycled content in plastic parts (Art. 7), recyclability (Art. 6), empty space (Art. 24) and reuse for transport packaging (Art. 29). Anyone who sets up a clean register today can add this information later instead of searching for it all over again.

Step 1: the material register

The basis is a list of all packaging components, not just the main packaging. This includes cartons, inserts, stretch film, adhesive tape, strapping, edge protection, pallets and filling material. Small parts such as adhesive tape, labels or interlayers are especially often forgotten.

A register can be structured like this:

Field	Content
Component	e.g. shipping carton, insert, stretch film, strapping, pallet
Material	e.g. corrugated board, PE film, PP strap, wood
Supplier and article number	clear assignment to the purchased material
Dimensions and weight	per unit, as a basis for weight figures per packaging
Plastic parts and recycled content	post-consumer share with proof, relevant for Art. 7
Supplier declaration	document, date, version, affected articles
Used in	which packaging configurations use this component

The last column is the most important: it links individual materials to the packaging your customers actually receive.

Step 2: supplier declarations and technical data

For every component you should obtain from the supplier at least the following:

• a declaration on the substance restrictions under Art. 5
• technical data sheets with material, dimensions, weight or thickness
• for plastic parts, the post-consumer recycled content, calculated per production plant and year
• the date, scope and the article numbers the declaration refers to

Make sure the declaration covers exactly the material you buy. A general declaration on a supplier’s product range is of little help if it remains unclear which article is meant.

A material declaration is not a declaration for the whole packaging

A supplier declaration on a single material is not automatically a declaration of conformity for every packaging assembled from it. An example: the same carton is used in three configurations, once with a matching insert, once with air cushions, once as part of a load unit with pallet, film and strapping. Weight, empty space and material combination differ each time. Whoever is responsible for the packaging must bring together and assess the individual details for each configuration.

Step 3: standardize materials

Documentation becomes especially laborious when packaging is put together for each order. Every new combination of carton size, filling material and load securing is another packaging that has to be described. Standardization keeps this manageable:

• a fixed range of carton sizes instead of many individual formats
• few film types and strapping types
• a defined filling or cushioning material
• fixed pallet types
• standard configurations with a bill of materials and packing scheme

This way you document a manageable number of configurations instead of every single order. It is also a matter of process and logistics optimization, because packing instructions and warehousing must match the standardization.

Step 4: keep the documents up to date

Documentation is only as good as its latest version. Define when information is reviewed:

• when changing supplier or material
• for new formats or configurations
• for new customer requirements
• when the Commission adopts legal acts, for example on recyclability or on the calculation of empty space
• in addition, at regular intervals

A version number for each document, a review date and a responsible person help. And a simple rule for purchasing: use replacement materials only once the documents for them are available. How this looks in practice for stretch film is shown in the guide Stretch film and the PPWR.

What EU customers typically ask for

With a well-kept register, the usual requests can be answered quickly:

• list of packaging components with material and weight per product or load unit
• information on substances under Art. 5
• supplier declarations and technical data sheets
• dimensions, packing schemes and drawings
• information with a view to 2030: recycled content, recyclability, empty space and reusability

Also clarify format and language with the customer. Many documents are expected in German or English, while supplier declarations from the region are available in the local language.

Build your documentation in a structured way

A material register is not a one-off task but a tool that grows with your packaging. Our material review and documentation service helps with the setup, and the PPWR and EU compliance service classifies your customers’ requirements. If you want to know where your documents stand today, request an initial assessment.