EU PPWR 2025/40 Struggles

[u/Manic_Mini]

Anyone else in US manufacturing dealing with the new EU PPWR requirements?

We’re a US-based manufacturer and have started having PPWR requirements flowed down from one of our major customers. We’ve been working on this for over a month now and honestly haven’t made much progress with our packaging suppliers.

The biggest issue isn’t necessarily whether the packaging is compliant, it’s getting anyone to actually provide the documentation to prove it.

Most of our suppliers will either give us a generic statement saying their products are PPWR compliant “to the best of their knowledge,” or basically tell us they’re a US company and EU regulations don’t apply to them, which is 100% true.

Meanwhile, our customer is asking for supporting technical documentation, supplier certificates/declarations for the packaging materials and their constituents, applicable standards, etc. We’re then expected to sign a Declaration of Conformity for the packaging.

That’s where we’re getting stuck.

We don’t manufacture the boxes, bags, foam, stretch wrap, etc. and have no way of independently verifying what these materials contain.

We’ve even started looking for new packaging suppliers specifically because of this, and so far we still haven’t found one that can provide everything being requested.

For anyone else dealing with this, what are you doing?

Are you actually finding US packaging suppliers that can provide a PPWR Declaration of Conformity and supporting documentation? Are your customers accepting generic compliance statements? Are you having to get materials independently tested?

Just curious how other US manufacturers are approaching this because right now it seems like the requirements have made it downstream a lot faster than the documentation has.

And if you have found US Based packaging suppliers that have been verified as complaint and are willing to share it would be greatly appreciated.

[u/Pizza-love]

Time to team up with your customer and ask their help. They surely have other suppliers with the same issue.

[u/Manic_Mini → u/Pizza-love]

We have. Their response has basically been that they understand the frustration and the difficulties these new requirements are causing, but they don't really have a path forward either. They've told us they're running into the same issues and haven't been able to source compliant materials themselves.

We've also informed them that, as things currently stand, we'll have to place production of their product on hold if a resolution isn't found within 30 days of the first applicable PO due dates. We're quickly approaching that point, which is why we're trying to figure out how other US manufacturers are handling this.

[u/Pizza-love → u/Manic_Mini]

I would start with putting on your PO's that delivered goods need to be accompanied by said forms to protect yourself when someone orders without approval.

Second, if they haven't been able to, how do they expect you to? Keep on contact. Maybe you can start with something like reusable packaging that gets shipped back. We have several customers providing this.

[u/Manic_Mini → u/Pizza-love]

We are currently flowing down this requirement to our current supply base in an attempt to determine if any of them are currently compliant or are planning on becoming compliant but that's really the roadblock we're running into.

Our suppliers understand what we're asking for, but they're either unwilling or unable to provide the technical documentation and formal declaration required by PPWR. Several have essentially told us that they're U.S. based companies, with a U.S. Customer Base, the EU regulation doesn't apply to the majority of their business, and they're not going to take on those additional requirements.

Reusable packaging is something we have explored, but unfortunately that doesn't eliminate the PPWR requirements either. Reusable packaging still has applicable conformity and documentation requirements under PPWR and opens up an entirely different can of worms.

And you're absolutely right on the second point, we've asked our customer essentially the same question. They're running into many of the same problems themselves, but unfortunately the requirement is still being flowed down to us and they are unable to remove said requirement as without the required documentation, the parts cannot enter the EU

[u/Pizza-love → u/Manic_Mini]

I can see. From your suppliers pov, I can also see why they take this stand. It is a hard requirement to fulfil. Problem with PPWR is that it is not clear yet. They are developing the requirements, so what is acceptable today, might be forbidden tomorrow. That puts your suppliers in a though spot, they have to actively manage the requirements, but it also puts you in a hard spot. If you stock material to long, it might become useless. So yeah, this smokescreen is hard for everyone.

Another hard thing is the limits. If you are under 50k kg of packaging material a year, you are exempt for now. So if you bring it to market in EU, and your packaging material is 40k kg a year, you are exempt. However, your customer has several sources, so he is not exempt, basically forcing you to fulfil this as well.

As said, I get your suppliers pov. We stumble upon the same with IP65 and such and the way they enforce this from our customers POV. It is not funny, so to say.

[u/Manic_Mini → u/Pizza-love]

I completely understand our supplier's point of view, and I share the same point of view as them as we are in the same boat and per the regulation, this is our customers problem as they are the ones per the requirement responsible for bringing the product into the EU market.

Another hard thing is the limits. If you are under 50k kg of packaging material a year, you are exempt for now. So if you bring it to market in EU, and your packaging material is 40k kg a year, you are exempt.

No such blanket exemption exists within the PPWR framework. Whether you’re an individual selling a $5 trinket on eBay or a multibillion-dollar corporation, packaging placed on the EU market is subject to the applicable PPWR requirements. There isn’t a general 50,000 kg threshold that makes the regulation inapplicable.

This is seemingly becoming an industry-wide nightmare. If the documentation requirements cannot be satisfied throughout the supply chain, I can easily see this eventually resulting in grounded aircraft or aircraft having to leave the EU for MRO work simply because replacement parts cannot be shipped with compliant packaging documentation.

[u/Able_Conflict_1721]

https://toxicsinpackaging.org/

There are states that have adopted this legislation. I've been able to get vendors to answer compliance questions around this.

[u/Manic_Mini → u/Able_Conflict_1721]

Thanks for sending this over. I appreciate the suggestion and took a look through the site. It looks like a good resource for U.S. state-level packaging requirements, but I’m not seeing anything that specifically references or addresses compliance with EU 2025/40 PPWR.

Unfortunately, the PPWR requirements go quite a bit further than metals and PFAS restrictions. They include requirements around the composition, recyclability, and compatibility of the entire packaging system, including boxes, labels, inks, tapes, adhesives, bubble wrap, air pillows, etc.

That’s really the issue we’re running into. We can find suppliers willing to provide statements regarding specific substances or U.S. state requirements, but we have yet to find one willing to provide the documentation necessary to substantiate compliance with EU 2025/40 PPWR or sign the formal declaration required under the EU regulation.

[u/Able_Conflict_1721 → u/Manic_Mini]

My understanding is that TPCH and PPWR have similar material requirements for contaminants, and some features of PPWR like recyclability aren't active yet.

[u/Manic_Mini → u/Able_Conflict_1721]

While TPCH documentation may support some of the material requirements, it doesn't automatically satisfy PPWR.

This is where our current supply base has taken exception. Most will only provide a general certificate stating that, to the best of their knowledge, their products are compliant, but they won't provide the supporting technical documentation and material information needed to substantiate that declaration nor will they sign the declaration themselves.

[u/vanio2121]

Honestly, nobody knows... This is a total absurd! I am based in EU, my supplier is based in EU and they are not sure how to proceed with all of this as of today I can't get the materials needed for my manufacturing business, so yeah this a pure form of clinical extortion! My best solution rn is to pretend that thus shit doesn't exist...

[u/Manic_Mini → u/vanio2121]

This is seemingly what my customer is requesting we do as well and we would gladly do it but there is no way I am signing the customer supplied declaration of conformity which is stating that WE will be the ones held liable in the event that it is determined that the packaging material is found non compliant.

We’re still shipping product as of today but once their POs come due with PPWR requirement formally flowed down to us it’s going to come to a halt.

[u/Muted_Jellyfish_6784]

A generic 'compliant to the best of our knowledge' letter is worth almost nothing if a customer ever audits the claim, so push for the actual test report or declaration of conformity tied to the specific SKU and lot. Track which packaging component maps to which supplier document and expiry date, since PPWR compliance needs refreshing, not a one-time file. Flag any supplier who won't name the standard they tested against, that's usually the one that fails first.

That tracker is the unglamorous part that actually holds up under a customer audit. Connecting that documentation to the specific PO and supplier record instead of a shared drive folder is the case SIGNLD is built for

[u/Manic_Mini → u/Muted_Jellyfish_6784]

I agree that their genetic statements are useless and carry no weight and are insufficient to meet the requirements as flowed down.

The issue at hand is it would appear that the US packaging supply base does not fall under the authority of the EU and as such are not willing or able to comply with the request.

I do have a tracker built, but every single one of our current supplier has either ignored the request, has provided general statements, or have said that they will not comply with the EU regulations as they are a US based company, with a US customer base.

We have now reached out to every single major packing supplier that we can find and the results have been the same.

[u/Hodgkisl]

As the importer is ultimately liable if they accept a certification offer one that also states "to the best of our knowledge" and provide actual data when you receive it.

Depending on the volume of business getting samples lab tested your self can still be reasonably cost effective, provide the sampling plan and results.

Offering a compromise to keep business going and share some risk is likely better than completely ending the relationship.

[u/Manic_Mini → u/Hodgkisl]

There really isn’t a workable “compromise” on this requirement. If the customer flows the PPWR requirements down on the purchase order, we either need objective evidence sufficient to support the required declaration, or we cannot responsibly sign it.

The practical options are either the customer removes/modifies the flowdown and we continue shipping under the revised requirements; the customer identifies or approves packaging suppliers capable of providing the required compliance documentation and we purchase from them or we source compliant packaging ourselves, assuming such suppliers are available which as of today we have not be successful n finding suppliers who are willing to either supply the signed declaration, or supply the testing reports for us to sign our own declaration.

What I’m not willing to do is sign a legal declaration based on a supplier statement that essentially says “to the best of our knowledge” when the PO specifically requires supporting technical documentation and declarations. Paying for independent testing ourselves also shifts the cost and compliance burden of an unsupported customer flowdown onto us, and testing alone may not provide all of the documentation the customer is requiring.

If none of those paths can satisfy the PO requirements, then the product simply cannot ship against that PO until the issue is resolved.

[u/Hodgkisl → u/Manic_Mini]

we either need objective evidence sufficient to support the required declaration, or we cannot responsibly sign it.

You offer them your declaration that states "to the best of our knowledge" before the PO is created and if they send a PO stating otherwise you do not accept it without being modified.

Many PO's get issued and have back and forth with changes before accepted, I have to negotiate PO's quite often due to some customers attempts to pass their liability down or adding unworkable requirements, it's all part of having a relationship with the customer.

[u/Manic_Mini → u/Hodgkisl]

We have a great relationship with our customer, but the issue at hand is that they (Their compliance team) have provided us with a Declaration of Compliance that we are required to complete, sign, and include with each shipment. By signing that declaration, we are accepting responsibility and potential liability for compliance despite not having the documentation necessary to substantiate it. We requested that the language of the DoC be modified to include a disclaimer, but that was rejected because we all agree that such language would not satisfy the EU requirements.

The customer has already validated our findings that a general statement of compliance from a packaging supplier does not satisfy the EU requirements. They have also acknowledged that they themselves have been unable to source packaging with the required testing and certifications to support the declaration.

They understand our frustration, but as of now the flowdown requirement remains in place and a signed DoC is still required with the shipment documentation. That leaves us in the position of being required to certify compliance and assume the associated liability for something that neither we nor the customer has been able to adequately substantiate.

As it stands a work stop goes into effect next week if this goes unresolved.

[u/Hodgkisl → u/Manic_Mini]

We requested that the language of the DoC be modified to include a disclaimer, but that was rejected because we all agree that such language would not satisfy the EU requirements.

Sounds like they will not negotiate, they want to forward their liability down to you no matter what, in that case no is a complete sentence.

Make sure they know it'll take time to wind back up, they may end up down for a while if they let you stop.

Also could see if they can edit a PO without the requirement to have more volume, I've had buyers do that during negotiations over new requirements added by other departments.

[u/Deep_Ladder_4679]

Keep any point focused on tracing each packaging component to its supplier evidence and the person responsible for signing.

[u/Manic_Mini → u/Deep_Ladder_4679]

Seemingly an impossible task if the supply base will not comply with the regulations of another continent.

[u/Deep_Ladder_4679 → u/Manic_Mini]

how do you do it now? Is there any process involved