If you sell a packaged product in the EU, you now have to sign a document describing what your packaging is made of. You probably did not make it, so you do not have those facts.
A supplier data request is how you get them, and the form below is a ready-made one.
Send it to every company that supplies packaging or packaging material to you. Fill in your company name and a return date, then pass it on. The rest is for the supplier, and every field is writable so they can type straight into the PDF.
What a supplier data request actually is
A supplier data request is a written set of questions you send to the companies that make your packaging. It asks them for facts about their materials that you have no way of looking up yourself, such as what a film is made of or how much recycled plastic is in a bottle.
You need those facts because of PPWR, the EU Packaging and Packaging Waste Regulation. It applies from 12 August 2026, and it asks anyone putting packaging on the EU market to sign an EU declaration of conformity.
That declaration is a short document where you state, in your own name, that your packaging meets the EU rules. Signing it is a legal act, so you want to be sure the facts underneath it are real.
Why the duty lands on you and not on the factory
This is the part that surprises people. PPWR treats you as the manufacturer of your packaging whenever it reaches the market under your own name or trademark, even if a completely different company made it. That is Article 3(1)(13)(a).
So a coffee brand that buys printed pouches from a packaging converter is, in the eyes of the regulation, the manufacturer of those pouches. The converter made them, but the brand is the one who has to declare them.
To put it plainly, you carry the signature and the risk, while the facts sit in someone else's factory. Closing that distance is the whole job of a supplier data request.
The evidence folder behind the declaration
The declaration is only the visible part. Behind it sits a second document called the technical documentation, set out in Annex VII of the regulation. It helps to think of it as an evidence folder.
If an inspector ever asks how you know your packaging complies, that folder is your answer. It holds the material breakdown, the weights and drawings, the standards you used and any test reports.
Nobody checks or certifies the folder for you. Annex VII has the manufacturer declare "on his sole responsibility" that the packaging meets the rules, which means there is no notified body to lean on and no certificate to buy. The conformity assessment is yours alone.
Why your supplier has to give you the answers
It is easy to assume you are asking your suppliers for a favour, and that they can politely decline. They cannot. The regulation puts a matching duty on their side of the relationship.
Article 16 requires suppliers of packaging and packaging materials to give the manufacturer all the information and documentation needed to demonstrate conformity, including the technical documentation in Annex VII.
It has to be in a language you can easily understand, and paper or electronic form both count. Two useful things follow from how that is worded.
- It is an obligation, not a courtesy. If a supplier tells you the information is confidential or not their problem, you can point at Article 16.
- The timing and the format are up to you. Article 16 sets no deadline and prescribes no template, so you decide when to ask and what to ask on.
One limit is worth knowing before you write anything. Article 16 covers Articles 5 to 11 of the regulation, which leaves labelling under Article 12 off the list. Your supplier does not owe you the label, although their material breakdown is what you need to get it right.
The full regulation is on EUR-Lex if you ever want to read the wording yourself, and the European Commission keeps a plainer summary on its packaging waste pages.
What to gather before you send your first request
A little preparation is the difference between one clean round of questions and four rounds of chasing. Get these four things together first.
- A list of every packaging type you sell. You sign one declaration per packaging type, so this list tells you how many requests to send and how many declarations you will end up with.
- The separate parts inside each type. An outer box, an inner bag, a closure, a label, a leaflet, the padding. If a different company makes it, it belongs on its own line.
- Your purchase records. These show who actually manufactures each part, which is not always the company you send your orders to.
- A quick check on whether this is even your job. If you are a micro-enterprise, meaning fewer than 10 staff, and your packaging supplier is in the same EU country as you, Article 3(1)(13)(b) makes that supplier the manufacturer instead of you.
Step 1. List every packaging component and who supplies it
Start with a single product and take its packaging apart on paper. Annex VII asks for the "materials of components", so a component, not the finished product, is the unit everything else is built on.
Most products break into four to six parts, and they very rarely come from one company. A bottled product can easily involve a board converter, a plastics moulder, a closure maker and a label printer before anything is even filled.
Watch for the parts you never think of as packaging. Padding, pallet wrap and tape all count under the rules. They usually come from a wholesaler who buys them in rather than makes them, so the facts may sit one step further up the chain than your invoice suggests.

This step is done when every component has a name, a weight you can check later, and a company written next to it.
Step 2. Match each rule to the exact fact you need
If you simply ask a supplier to "confirm PPWR compliance", you will get a friendly sentence back and nothing you can actually file. The trick is to turn each rule into one specific thing you are asking them to send.
The table below does that translation for you. It is also, roughly, the shape of the free form at the top of this page.
| The requirement and what it limits | What to ask your supplier for |
|---|---|
| Article 5(4), a combined 100 mg/kg limit on lead, cadmium, mercury and hexavalent chromium | Written confirmation plus the test report behind it |
| Article 5(5), PFAS in food-contact packaging from 12 August 2026, at 25 ppb for any single PFAS, 250 ppb summed and 50 ppm including polymeric PFAS | Test results for every component that touches food |
| Article 6, recyclability, which will be graded A, B or C once the criteria exist | The design for recycling assessment they already hold, and the method behind it |
| Article 7, recycled content in plastic parts, with minimum percentages from 1 January 2030 | The percentage as a plant and year average, plus the certificate |
| Articles 10 and 24, weight, volume, and a 50 percent cap on empty space from 1 January 2030 | Internal and external dimensions, wall thickness and weights |
Two of those rows trip people up, so they are worth a closer look.
Article 7 measures recycled content as "an average per manufacturing plant and year". That is not something you can work out from your own purchase records, however hard you try.
The figure only exists inside the converter's plant, which makes it the clearest example on the whole list of a fact you have to ask for rather than estimate. PPWR requirements for plastic packaging covers those percentages and which packaging each one applies to.
Article 6 works the other way round. The EU criteria that will decide the recyclability grades are due by 1 January 2028 and, as of August 2026, have not been published.
Asking for a grade today means asking for something that does not legally exist yet. Ask what assessment they already hold instead.

Step 3. Put every question into one form
Asking these questions by email feels quicker, and it is not. Answers come back across several threads, in different formats, from different people, and none of it arrives in a shape you can drop into your evidence folder.
A single form solves that by making the structure the supplier's job rather than yours. Give it these seven parts.
- Who they are and what the answers cover, so you can trace a completed form back to specific products.
- What each component is made of, with every layer named in order for anything multi-material.
- Recycled content in each plastic part, with the plant and the year the figure covers.
- Substances of concern, as separate lines for the metals limit and each PFAS threshold.
- Recyclability, asking what assessment exists rather than for a grade.
- Dimensions and weights, internal measurements as well as external.
- A signature, which turns a set of claims into something a named person stands behind.

One small instruction saves a whole round of chasing. Ask them to write "not applicable" rather than leaving anything blank, because a blank box never tells you whether the question was considered or simply skipped.
Step 4. Send it to the right person with a clear deadline
Send the form to a technical or quality contact rather than the sales rep who looks after your account. Account managers do not have material specifications on hand, and a request that lands in the wrong inbox tends to get forwarded once, answered vaguely, and never finished.
Then pick your own return date, because the regulation does not pick one for you. Article 16 gives you the right to the information and says nothing at all about when it has to arrive.
There is a hard deadline in this story, though, and it sits at the other end. Under Article 15(10), once a national authority formally asks to see your documentation, you have 10 days to hand it over.
Ten days is plenty of time to fetch a folder you already have. It is nowhere near enough to build one from scratch while four suppliers work out between them who should reply.

So give the request a date you chose deliberately, comfortably before you plan to sign anything, and explain what happens next so the deadline reads as a plan rather than a threat.
Step 5. Check each answer for what is missing
Most completed forms look finished at a glance. The real test is not whether a box has words in it, but whether those words would let you explain to an inspector how you know.
Three answers come back again and again, and none of them settles anything.
- "Recyclable" does not say by what method or against which criteria, so there is nothing to record in your evidence folder.
- "PFAS free" does not say which of the three limits in Article 5(5) it was measured against, or whether anyone measured at all.
- "30% recycled" does not say which plant or which year, and that is the only form the Article 7 figure legally takes.

When an answer falls short, go back and ask for the one missing piece rather than resending the whole form.
There is also one situation where you can push harder. If a supplier tells you total fluorine is above 50 mg/kg, Article 5(5)(c) lets you require proof of the fluorine quantity, measured as PFAS or non-PFAS content, specifically so that you can complete your Annex VII file.
Step 6. File the answers into your technical file
An answer sitting in someone's inbox is not evidence. Move each one into the part of the technical documentation it belongs to, so that the folder, rather than your memory, is what holds everything together.
| Where the answer goes | Annex VII element |
|---|---|
| Material and layers per component | (b) conceptual design, manufacturing drawings and materials of components |
| Datasheets and drawings | (c) descriptions and explanations |
| The standard or method used | (d) standards and specifications applied |
| Recyclability and minimisation assessments | (e) qualitative description of the assessments |
| Test and analysis reports | (f) test reports |

Then hold on to it for a long time. Annex VII keeps the declaration and the folder available to national authorities for 5 years after single-use packaging goes on the market, and 10 years for reusable packaging.
Article 15 also asks you to keep conformity true for as long as you keep selling. In practice a changed material, coating, layer or production site sends you back to the supplier, and then back to the declaration.
What changes once you have more than a handful of packaging types
Everything above can be run with a document and a calendar, and for one or two packaging types that is genuinely fine. The free form is the whole request, laid out and ready for a supplier to type straight into.
One form covers one supplier. Fill in your company name and a return date, send a copy to everyone who makes packaging for you, and every field is writable so they can type their answers straight in.
The strain does not come from asking. It comes from everything afterwards, because one form per supplier per packaging type adds up quickly. Every answer has to be matched to the right declaration, and every declaration reissued whenever a specification moves.
The whole set then has to stay findable for 5 or 10 years, while people change jobs and shared drives get reorganised. That is a decade of filing discipline resting on a folder somebody has to remember to update.
How Repax Declare turns the answers into a declaration
Declare is the part that picks up once the answers are in. You enter a packaging type once, it confirms which declaration fields apply, and it generates, signs and versions the document for you.
- Answers become fields, so a supplier's material breakdown and recycled content feed the declaration instead of being retyped into it.
- A changed answer becomes a new version, which is what Article 15 asks for whenever a specification moves.
- The declaration stays live, hosted with a QR code that keeps working for the full retention period rather than pointing at a page that quietly disappears.
To be clear about what a tool can and cannot do, no software makes you compliant. Compliance is the manufacturer's responsibility under Article 15, and the packaging itself still has to meet the rules in Articles 5 to 12.
What Declare does is keep the declaration correct, traceable and ready for inspection, at any number of packaging types.
If you want the wider picture first, the EU declaration of conformity overview explains what the document is. The guide to creating one step by step picks up exactly where this page ends.
Five mistakes that make a request come back useless
These are the ways a request gets sent properly and still produces nothing you can use.
- One generic letter to every supplier. A label printer and a plastics moulder do not owe you the same answers, and a request covering both invites each of them to skip the parts they assume belong to someone else.
- No component named. An answer about "your packaging" cannot be traced to a packaging type, so it cannot support a declaration that has to identify one.
- A specification sheet instead of an answer. A datasheet describes a product. It rarely confirms a legal limit, and it almost never carries a signature.
- Asking for a recyclability grade. The criteria are not published as of August 2026, so a supplier who hands you a confident grade is telling you something the law cannot yet back up.
- Asking only once. Your duty runs for as long as you keep selling the packaging, so a request with no repeat built into it quietly expires the first time a supplier changes a coating.
Frequently asked questions about supplier data requests
Short answers to what producers ask most often when they start collecting this data.
How long does a round of supplier data requests take?
Plan for four to six weeks per round. Suppliers who already answer these questions for other EU customers reply in days, while those meeting them for the first time often need to go to their own suppliers first.
What if a supplier refuses to answer?
Article 16 obliges suppliers to provide what the manufacturer needs to demonstrate conformity, so point to it directly. If they still will not, the practical options are to escalate commercially or to change component supplier before you have to sign.
Can I send one request covering all my packaging?
You can send one form per supplier, but it has to identify each component they supply. You sign one declaration per packaging type, so answers that are not tied to a specific component cannot support it.
Do I have to ask again when the packaging changes?
Yes. Article 15 requires you to keep conformity true across a production run, so a change of material, layer, coating or production site means new answers, an updated technical file and a reissued declaration.
Does a supplier's declaration replace mine?
No. A supplier's information feeds your technical documentation, but under Annex VII the assessment and the declaration stay your responsibility. The one exception is the micro-enterprise case in Article 3(1)(13)(b), where the supplier becomes the manufacturer.

