What Documents Should Buyers Request for Food Packaging Sold in the EU?

Request the right EU food packaging specifications, declarations, migration support, GMP, traceability and PPWR documents for the finished package.

EU Food Packaging Document FAQ

What Documents Should Buyers Request for Food Packaging Sold in the EU?

A current procurement checklist covering food-contact specifications, declarations, migration support, GMP, traceability and PPWR requirements from 12 August 2026.

The short answer: build a material- and use-specific compliance file

Request a complete specification and supply-chain file for the exact finished package, intended food and conditions. EU food-contact, GMP, traceability and material-specific documents remain separate from PPWR, EPR and market-labelling obligations.

Is there one EU food-safe certificate for every package?

No. Requirements depend on material layers, intended food, contact, time, temperature, Member State and economic-operator role. A generic certificate is not a complete compliance file.

What core specification should buyers request?

Request the finished bill of materials and layer diagram, supplier and grade identities, dimensions, coatings, inks, adhesives, direct-contact areas, intended food, time, temperature, filling and storage restrictions.

What does Regulation (EC) 1935/2004 require?

It establishes general safety and inertness, traceability and labelling principles for food-contact materials. Supporting evidence must show the intended article meets those requirements.

What GMP documents are relevant?

Request evidence of a documented quality assurance and control system under Regulation (EC) 2023/2006, including controls for printing on non-food-contact surfaces, set-off, curing and traceability.

When is an EU declaration of compliance required?

Specific measures define formal declaration requirements. Regulation (EU) 10/2011 requires a declaration for covered plastic materials and articles and certain intermediate stages; other materials may follow national or customer documentation practices.

What migration evidence should accompany the file?

Request reports, calculations or assessments linked to exact layers, simulants, time, temperature, surface-to-volume assumptions, restrictions, specific and overall migration where applicable, and a justified worst-case scope.

What should be requested for inks, coatings and adhesives?

Request exact product identification, supplier statements, application and cure conditions, composition or migration information needed for assessment, and confirmation of intended position and use.

What traceability records should be available?

The file should connect raw-material lots, production batches, finished SKUs, suppliers and customers and support withdrawal or investigation. Agree retention and change-notification requirements.

What changes on 12 August 2026 under the PPWR?

Regulation (EU) 2025/40 generally applies from that date. Packaging placed on the EU market then must meet applicable sustainability, marking, information and substance requirements, including PFAS limits for food-contact packaging.

Does PPWR replace food-contact law?

No. Packaging must meet both applicable food-contact safety rules and PPWR requirements. Evidence for one does not replace the other.

Who handles EPR, registration and national labels?

Responsibilities depend on the product flow, Member State and economic-operator role. The importer or brand should obtain country-specific advice and assign responsibility contractually.

What should be checked before shipment?

Verify document versions and product identity, authorised signatory, intended-use limits, test scope, traceability, PPWR date applicability, destination obligations and a process for notifying material or supplier changes.

EU food packaging compliance file

Keep food-contact and packaging-market obligations connected but distinct.

Document group Must identify Buyer check
Technical specification Finished layers and intended use Exact SKU and revision
Food-contact evidence Regulations, restrictions and migration basis Scope and worst case
GMP and traceability Process controls and batch links Supplier system and records
PPWR file Substances, sustainability and information duties Application date and role
National obligations EPR, registration and labels Destination-country review

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Need help specifying your packaging?

Send the package format, materials, intended use, destination market and required documents. UGI Packging can review the specification before sampling or production.