What data must I request from my packaging supplier?

Material data, weight and a declaration of conformity are the foundation

From your packaging supplier, request at least three types of data: the material composition of the packaging (which type of plastic, cardboard, metal or composite, and in what proportion), the weight per material type, and a declaration that the packaging remains below the limit value for heavy metals and — in case of food contact — is free of PFAS. You will also need the EU declaration of conformity according to the model in Annex VIII, together with the underlying technical documentation. This documentation must be kept for five years, even if the supplier has prepared it.

You need the same data on material type and weight for registration in the producer register of each country where the packaging is first placed on the market: the registers typically request precisely these figures. Also ask the supplier in which Member State it is established. This may seem incidental, but in one specific situation it determines who is considered the manufacturer: if the brand owner is a micro-enterprise and the supplier is established in the same Member State, then the supplier is the manufacturer and not the brand owner. If the supplier is in another country, that exemption does not apply and the brand owner remains the manufacturer. Without the establishment country of the supplier, this question cannot be answered.

Where this follows from: Annex VIII and the guidelines on the concept of manufacturer

The obligation to provide a declaration of conformity with technical documentation is set out in Annex VIII of Regulation (EU) 2025/40, which also prescribes the five-year retention period. The name and postal address of the responsible party must appear on or with the packaging, also according to that regulation. The micro-exemption and the role of the establishment country of the supplier are elaborated in the Commission guidelines C/2026/3084 on the concept of manufacturer.