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PPWR: Art. 16 docs for manufacturers

Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) places documentation duties on suppliers as well as manufacturers. Article 16(1) states that suppliers shall provide the manufacturer with all information and documentation necessary to demonstrate conformity, including the technical documentation referred to in Annex VII. The regulation text does not set a deadline for suppliers. This guide summarises that confirmed rule and points to Product Registry tools. Product Registry never emails suppliers or files anything with an authority.

Article 16(1): what suppliers must provide

Article 16(1) PPWR requires suppliers to provide the manufacturer with all the information and documentation necessary for the manufacturer to demonstrate the conformity of the packaging and packaging materials with the Regulation, including the technical documentation referred to in Annex VII.

Annex VII Module A point 2 lists the technical documentation elements manufacturers must keep, such as a general description, design drawings, standards applied or solutions adopted, qualitative assessments under Articles 6, 10 and 11, and test reports. Suppliers often hold test reports and material declarations your team needs to complete that file.

Confirm which supplier in your chain owes which documents for each packaging unit. Product Registry does not decide legal roles for you.

No supplier deadline in the regulation text

Unlike the 10-day hand-over rule for manufacturers and importers answering a national authority (Articles 15(10) and 18(8) PPWR), Article 16(1) does not state a number of days for suppliers. Plan your own due dates in contracts and in Product Registry when you open an evidence request.

Your due queue may already list reminder tasks for open supplier requests. The org-wide evidence requests board is the cross-supplier view of the same records.

Supplier evidence portal in Product Registry

On a supplier record you generate a secure link and choose document kinds (for example technical documentation, PFAS or heavy-metal test reports). You copy the link and share it yourself. Product Registry does not send email, SMS or chat messages to suppliers.

Suppliers upload files through the public portal. Status moves from draft to shared, opened, partial or complete as files arrive. You can set a due date on each request for your own workflow.

Org-wide evidence requests board

The board at Suppliers then Evidence requests lists every EvidenceRequest for your organisation with supplier name, requested kinds, status, due date, days overdue when applicable, last reminder timestamp and created date. Filter open requests, overdue items or a single supplier. Print the page or download CSV with UTF-8 encoding for spreadsheets.

Each row links back to the supplier detail page where you manage links and uploads. This board does not replace your contracts or legal advice.

How Product Registry helps

Product Registry keeps suppliers, packaging and SKU records on one graph. Request missing PPWR evidence once per supplier, track overdue flags, and attach received files to packaging checklists and declarations.

These features organise your workspace. They do not certify conformity and do not contact suppliers on your behalf.

Related guides

Primary legal text

Product Registry organises evidence and inspection files. It is not legal advice and does not file anything with an authority for you.

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