PPWR Packaging Specification Sheet and Supplier Document Requests — The Order for Filling the Cells a Quotation Cannot

Key takeaway — The specification sheet is a table that reveals ‘what we do not know’. Identify the packaging unit, record the separable components and the joining structure, and distinguish confirmed values from estimates, and the questions for suppliers arise by themselves. Those questions become a request that specifies the information and documents a supplier must provide to the manufacturer under Article 16, and the replies feed into the items of the Annex VII technical documentation.

This article is based on Regulation (EU) 2025/40 (PPWR) and Commission Notice C/2026/3084 (implementation guidance), as checked on 6 October 2026. Confirm who the manufacturer is in PPWR responsible operators and internal role allocation, and the overall scope in the PPWR preparation guide first.

The unit of the specification sheet is the packaging, not the finished product

Article 3 distinguishes sales packaging (point 5), grouped packaging (point 6), transport packaging (point 7) and e-commerce packaging (point 8). The packaging for selling a single unit differs from the packaging for shipping a bundle of the same product, so do not merge them into one specification just because the product name is the same. Assign a management number to each packaging and link the applicable product, packaging type and shipping configuration.

Article 6(9) provides that in the recyclability assessment, all integrated components of a packaging unit are included in the assessment, integrated components that may become separated by mechanical stress during transport or sorting are assessed separately, and separate components are assessed individually. This is why the specification sheet must record how components are joined and whether they can be separated.

Specification sheet template

The columns below are our own proposal. They are not a statutory form; shorten or extend them to suit your ERP or drawing management system.

Inserting an arbitrary material name or an average weight to fill a blank undermines the judgements that follow. Record the reason for each gap. The absence of a document and the failure of the packaging to meet a requirement are different problems, and the absence of a document that is itself required is yet another.

From the specification sheet to the Annex VII technical documentation

Article 15(2) requires the manufacturer, before placing packaging on the market, to carry out or have carried out the conformity assessment procedure under Article 38 and to draw up the technical documentation under Annex VII. Point 2 of Annex VII provides that the technical documentation is to contain, where applicable, at least the following.

This does not mean that every cell of the specification sheet needs the same certificate. Organise it within the scope needed for the requirements and assessments applicable to that packaging. Section 6 of the Commission guidance explains that until the delegated act under Article 6(4) enters into force, there is no need to carry out the conformity assessment under Article 38 and Annex VII for recyclability, so not every cell has to be complete right now.

Supplier request: ask for what needs confirming, not for document names

Article 16(1) requires the supplier to provide the manufacturer, in writing or electronically and in a language easily understood by the manufacturer, with all information and documentation necessary to demonstrate the compliance of the packaging and packaging materials, including the Annex VII technical documentation. Paragraph (2) requires documents and information under EU legislation applicable to contact-sensitive packaging to be included as well.

The request can be built from the following items.

Instead of ‘please send the certificate for the pouch for EU export’, write ‘layer-by-layer material and weight data for the part number currently supplied against the attached drawing’. Do not demand the same test items from every supplier across the board, and do not assume that any single certificate demonstrates compliance with the whole of PPWR.

Manage replies in four statuses

These four statuses track the progress of the document request; they are not a grade judging whether the packaging is compliant. Even an item whose data has been obtained can only be moved to complete after its content has been checked against the applicable requirements.

Fictional example: one pump and one label

This is a fictional example for illustration. Suppose a pump on a household product container was recorded on the specification sheet simply as ‘PP, 12 g’, and it was later confirmed that it contains an internal spring and parts of a different resin. The initial value must not be used as a complete description of the finished pump, so send the items needing configuration confirmation to the supplier as questions and, when the reply arrives, update the pump's component structure and applicable part number.

If the label supplier for the same product replies only with ‘recyclable material’, ask further about the face stock resin and adhesive specification, the conditions under which the label separates from the bottle, and whether the assessed item is the same as this delivery. A description of the label material does not replace an assessment of the finished container-and-label combination. Neither example is a compliance judgement on a specific component.

For trade-secret data, settle the scope of delivery first

Where detailed formulations or process information are confidential, agree with the supplier on the scope of information needed, the method of delivery and who may view it. Whether the figures themselves are needed or a document confirming a specific requirement suffices depends on the purpose of the assessment. Record why provision is difficult and the scope that any substitute document demonstrates, and review the effect of the remaining gap on the judgement. Confidentiality is not a basis for treating packaging as compliant without evidence.

Review the first specification sheet against one shipping configuration

Before entering many products at once, pick one actual shipping configuration of a representative product and compare its photographs, specification sheet and specifications. Correct missing components and number confusion before extending to other products, and the amount of rework falls. After a reply, do not stop at filing the attachment: link it to the part number and specification revision, and mark its scope of application so that old data is not reused after a change.

Documents that speed up the review if prepared before enquiring

• Product list and photographs of the actual shipping packaging
• List of quotations, specifications and drawings held, with revision dates
• List of documents already received from each supplier and the questions still unanswered

Please mention PPWR packaging in your message when you use the PPWR packaging document review enquiry. We will distinguish the items that can be confirmed from current documents from the documents still to be obtained. The scope and cost of the review are advised individually after we have confirmed the product and packaging configuration.

Prepared and sources checked: 2026-10-06. Sources: Regulation (EU) 2025/40 Article 3(1)(5) to (8), Article 6(9), Article 15(2), Article 16, Article 38, Annex VII point 2 · Commission Notice C/2026/3084 Section 2 (declaration based on supplier information), Section 6 (timing of recyclability assessment). The specification sheet, request form, reply status table and fictional example are our own practical tools and do not replace a statutory form or a compliance judgement on individual packaging.