Can Your Business Rely on Supplier Declarations for Packaging Compliance?
As businesses review packaging against the EU Packaging & Packaging Waste Regulation (PPWR), many are discovering that supplier statements can vary significantly in quality and detail.
A supplier may provide a statement such as "PFAS not intentionally added", "complies with applicable regulations", "food safe", or a declaration addressing heavy metals.
These statements can be useful, but they may not always provide enough information to establish the compliance position of the packaging being placed on the market.
The key question is therefore not simply whether a supplier has provided a declaration. It is:
What has the supplier actually confirmed, what evidence supports that confirmation, and does it relate to the packaging being used?
What does the PPWR say about substances of concern?
Article 5 of the PPWR contains requirements relating to substances of concern in packaging.
These include a general requirement to minimize the presence and concentration of substances of concern in packaging.
The Regulation also establishes specific requirements for certain substances.
For example, Article 5(4) sets a combined concentration limit of 100 mg/kg for lead, cadmium, mercury and hexavalent chromium in packaging or packaging components.
Article 5(5) establishes specific restrictions for PFAS in food-contact packaging, including limits relating to individual PFAS, the sum of PFAS and PFAS including polymeric PFAS.
These requirements are not all applicable in the same way or on the same timescale, so businesses should consider the particular packaging and requirement involved rather than treating all substances of concern as one single testing requirement.
What does a supplier declaration actually demonstrate?
There can be a significant difference between different types of supplier statements.
For example:
"PFAS not intentionally added" — indicates that PFAS were not deliberately used, but does not necessarily demonstrate that PFAS are absent.
"PFAS-free" — represents the supplier's assertion regarding PFAS, but the basis for that assertion may need to be understood.
"Heavy metals compliant" — may provide a useful compliance statement, but businesses should establish what materials, components and limits the statement covers.
"Food safe" — may address food-contact suitability, but does not necessarily demonstrate compliance with every applicable PPWR requirement.
"Complies with applicable regulations" — is a broad assertion and may not identify which regulations or specific requirements have been assessed.
The wording of the declaration therefore matters.
A business should understand what the supplier is actually declaring rather than treating different statements as interchangeable.
What should businesses check?
Before relying on a supplier declaration, an SME should consider several practical questions.
1. Is the declaration current?
Check when the declaration or supporting information was issued and whether it remains applicable to the packaging currently being supplied.
Older documentation may not reflect current requirements or changes to the packaging specification.
2. Does it relate to the correct packaging?
A declaration should be capable of being linked to the packaging being purchased and used.
This is particularly important where a supplier provides a generic declaration covering multiple products, materials or packaging formats.
Where possible, businesses should be able to establish a connection between the declaration and the relevant product, packaging specification or SKU.
3. What exactly is being declared?
Businesses should establish whether the supplier is making a statement about:
intentional use of a substance;
analytical testing;
compliance with a specified limit;
food-contact suitability; or
general regulatory compliance.
These are not necessarily equivalent.
4. Is there supporting technical evidence?
Where a particular regulatory requirement needs to be demonstrated, a supplier declaration may be supported by additional technical evidence.
Depending on the circumstances, this could include:
test reports;
material specifications;
declarations of compliance;
technical data;
information relating to coatings, treatments or other components; or
other evidence held within the supplier's technical documentation.
The appropriate level of evidence will depend on the specific packaging and compliance requirement.
5. Can the information be traced?
Good documentation should allow the business to establish what the evidence relates to.
For example:
Supplier → Packaging specification → Product/SKU → Declaration/test evidence
The objective is to avoid having a collection of documents that cannot be confidently connected to the packaging actually being placed on the market.
PFAS: a specific example
PFAS provides a good example of why the wording and supporting evidence behind a supplier statement matters.
Since 12 August 2026, Article 5(5) of the PPWR has applied specific restrictions to PFAS in food-contact packaging.
The Regulation establishes limits of:
25 ppb for any PFAS;
250 ppb for the sum of PFAS measured through targeted analysis, where applicable; and
50 ppm for PFAS including polymeric PFAS.
The precise analytical approach can depend on the packaging material and circumstances.
A supplier statement that simply says "PFAS not intentionally added" may therefore be useful information, but businesses should understand what that statement actually demonstrates in relation to the applicable requirement.
For a more detailed explanation of the PFAS requirements for food-contact packaging, see our guide:
What Irish Deli & Takeaway Businesses Need to Know About PFAS Packaging Rules
Heavy metals: another consideration
Heavy metals provide another example.
Article 5(4) establishes a combined limit of 100 mg/kg for lead, cadmium, mercury and hexavalent chromium in packaging or packaging components.
This requirement is broader than the specific PFAS restriction, which relates to food-contact packaging.
Businesses should therefore avoid assuming that a food-contact declaration or a general "food safe" statement necessarily addresses the separate heavy-metal requirement.
Where supplier documentation does address heavy metals, businesses should establish what packaging components and materials the declaration covers and whether it relates to the packaging currently being supplied.
What about other substances of concern?
The PPWR's approach to substances of concern extends beyond PFAS and the specified heavy metals.
However, this does not mean that an SME should automatically commission laboratory testing for every potentially relevant substance.
A proportionate approach is to first understand:
the materials and components used;
the intended use of the packaging;
the supplier's declarations;
available technical documentation; and
the specific PPWR requirements that apply.
Where there is an identified evidence gap, the appropriate next step may be to obtain clarification or additional documentation from the supplier.
In some circumstances, further technical assessment or laboratory testing may then be appropriate.
What if my supplier can't provide sufficient information?
This is where the situation can become more difficult.
A supplier may provide a short statement such as:
"Our packaging complies with all applicable regulations."
That may be useful, but it doesn't necessarily tell the business:
which requirements were assessed;
what packaging the statement covers;
whether it applies to the current specification;
what evidence supports the statement; or
whether individual PPWR requirements have been specifically considered.
Where the information is insufficient, the business should identify what is actually missing before deciding what further action is required.
That could mean requesting:
a more specific declaration;
an updated specification;
supporting test evidence;
clarification from the supplier; or
where justified, independent laboratory testing.
The objective should be to close the specific evidence gap rather than automatically commissioning the most extensive testing available.
Why this matters for SMEs
For a large organisation with established procurement and technical teams, reviewing supplier declarations may be part of a standard compliance process.
For an SME, the situation can be very different.
A business may receive a short email from a supplier stating:
"Our packaging is PFAS-free and food safe."
The business may then have little information about:
what materials the statement covers;
whether coatings or treatments are included;
whether it relates to the current packaging specification;
when the statement was issued; or
what evidence supports the declaration.
The challenge is therefore often not the absence of a supplier statement, but understanding whether the statement provides sufficient evidence for the particular compliance question being considered.
Imported and own-brand packaging
This can become particularly important where businesses:
import packaging or packaged products;
source packaging through distributors;
use own-brand packaging;
have multiple suppliers for similar products; or
supply products to larger retailers or food-service businesses.
The further a business is removed from the original packaging manufacturer, the more difficult it can become to establish exactly what evidence exists and what it relates to.
Own-brand arrangements can add another layer of complexity because the business's role under the PPWR may differ from that of a conventional distributor.
A practical approach for Irish SMEs
Rather than asking suppliers simply:
"Is your packaging compliant?"
consider asking for information that allows the compliance position to be properly understood.
1. Identify the packaging
What material, format and specification does the declaration relate to?
2. Identify the intended use
Is the packaging intended for direct food contact?
3. Establish what the supplier is actually declaring
Is the statement about intentional addition, analytical testing, a specific regulatory limit, food-contact suitability or something else?
4. Establish the evidence behind the statement
Are there supporting test reports or technical documents?
5. Check the date and applicability
Does the information relate to the packaging currently being supplied?
6. Maintain a traceable record
Keep the supplier declaration and supporting documentation linked to the relevant packaging or SKU.
The key takeaway
Supplier declarations can be an important part of your packaging compliance records.
But "PFAS-free", "PFAS not intentionally added", "heavy metals compliant" and "food safe" are not necessarily interchangeable statements.
The practical objective is not to create unnecessary testing or paperwork.
It is to establish:
What has the supplier actually confirmed, what evidence supports that confirmation, and does it relate to the packaging you are actually using?
Where the evidence is insufficient, the appropriate next step may be clarification, additional technical documentation or, where justified, laboratory testing.
TrailZero helps Irish SMEs review supplier packaging documentation, identify evidence gaps and establish practical, traceable packaging compliance records.
Need help reviewing supplier packaging documentation? Contact TrailZero for practical packaging compliance support.
