The question German buyers ask Korean food and consumer-goods exporters has changed. A few years ago, the conversation often started with “is this packaging eco-friendly?” As PPWR (Packaging and Packaging Waste Regulation) application gets closer, the first request is more concrete: “send the evidence files.”
This blog already covers the six-documentation-package view of PPWR (“PPWR Asks for Proof, Not Promises”) and the basic supplier request package (“Documents SMEs Should Request from Packaging Suppliers First”). This post narrows the scope further. It focuses on five evidence files a packaging supplier should be able to send within 48 hours when a German buyer asks.
Why German Buyer Questions Are More Specific
Signals from KOTRA’s Germany market coverage show that food buyers are checking PPWR together with PFAS, BPA, food-contact safety, and recyclability. A reply such as “we are preparing for PPWR” is no longer enough. Buyers want files.
Typical requests include:
- Material composition sheet
- Restricted-substance declaration or test report
- Food-contact safety records
- PPWR declaration of conformity or readiness status
- Packaging weight, label, and recyclability evidence
The German market is less interested in broad sustainability language than in whether the document can be sent immediately. For packaging suppliers, a SKU folder and a standard reply template are more useful than a long legal memo.
File 1: Material Composition Sheet
The first file is the material composition sheet. Even a paper carton may include surface paper, fluting, coating, label, adhesive, and ink. The buyer is not simply asking whether the pack is “paper” or “plastic.” The real question is what each component is made of and whether it can be separated.
Minimum fields:
| Field | Reply Basis |
|---|---|
| Packaging item | Connected to SKU or product name |
| Main material | Paper, corrugated board, plastic, metal, etc. |
| Secondary materials | Label, tape, coating, adhesive, ink |
| Recycled content | Whether used, percentage where available |
| Separability | Whether parts can be separated by consumers or in recycling |
| Preparation date | Used to check document validity |
If a supplier cannot disclose formulation ratios, request material classification and a compliance confirmation instead. The key is consistency between sales wording and regulatory documentation.
File 2: PFAS, BPA, and Heavy-Metal Evidence
German food-packaging buyers often ask about PFAS and BPA separately. The EU has tightened rules on BPA and related substances in food-contact materials, and PPWR also pushes packaging toward clearer control of substances of concern. Paper-based packaging can still be in scope when coatings, inks, adhesives, or laminated layers are used.
Build one of three reply routes:
- Test report available: include the lab, test date, scope, and applicable SKU.
- Supplier confirmation available: attach confirmations from paper, coating, ink, or adhesive suppliers.
- No document available: state the gap and provide the planned test date or material-substitution plan.
“Not applicable” is also part of evidence. But it needs a reason, such as no food-contact surface or no relevant coating.
File 3: Food-Contact Safety Records
K-food exporters should first separate direct, indirect, and non-contact packaging. An outer corrugated shipper may not be a food-contact material, while inner wraps, trays, cups, lids, coated paper, labels, and adhesives may fall into direct or indirect contact categories.
For buyer replies, separate the pack like this:
- Direct food contact: food-contact declaration, test report, temperature and use conditions
- Indirect contact: migration risk, separation structure, ink and adhesive evidence
- Non-contact outer packaging: packaging structure photo or description proving it is an outer pack
Food-contact records do not stand alone. The material sheet, test report, use condition, and actual packaging structure must match.
File 4: PPWR Conformity Status
Under PPWR, packaging connects to recyclability, packaging minimization, substance restrictions, labeling, and producer-responsibility data. What buyers ask for now is not always a finalized declaration. They also want to know which files exist and when missing files will be ready.
A supplier response should use four statuses:
| Status | Meaning | Reply Wording |
|---|---|---|
| Available | Test or confirmation records exist | Attach file name and applicable SKU |
| In progress | Test or supplier confirmation is being obtained | State expected receipt date |
| Substitution needed | Current specification has a risk | Suggest alternative paper, coating, or label |
| Not applicable | Outside the scope | State the reason |
This turns “we do not have it yet” into a manageable buyer conversation.
File 5: Weight, Label, and Recyclability Evidence
PPWR looks at packaging minimization and recyclability together. If a German buyer asks why the pack uses a specific size and weight, the supplier needs weight, dimensions, and recyclability evidence in one reply.
Prepare:
- Unit packaging weight in grams
- Weight by component: box, cushioning, label, tape, and other parts
- External and internal dimensions in millimeters
- Label and print files
- Recyclability assessment or internal checklist
- Packaging-minimization memo
If the pack claims to be recyclable, state the recycling system or test basis. A file name tied to a SKU is more persuasive than a generic “eco-friendly” line.
A 48-Hour Reply Folder
The most practical structure is five folders.
01_material-composition
02_restricted-substances
03_food-contact
04_ppwr-conformity-status
05_weight-label-recyclability
Prefix every file name with the SKU or packaging item code. For example: A100_folding-carton_material_2026-06.pdf. A buyer should be able to identify the product, packaging item, document type, and preparation date from the file name.
Supplier Request Email
Use this as a base message.
To prepare evidence for German buyer requests under PPWR and food-packaging rules, please provide the following records for the packaging item below.
Target: product name / packaging item / SKU
Requested records: material composition sheet, PFAS/BPA/heavy-metal evidence status, food-contact safety records, PPWR declaration or readiness status, packaging weight/dimensions/label/recyclability evidence.
If a record is not available, please mark it as “not held” and state the expected availability date or whether an alternative specification can be proposed.
Conclusion
German buyer response is not about explaining PPWR at length. It is about whether the supplier can send evidence for material, restricted substances, food contact, conformity status, and weight/label/recyclability when asked. If packaging suppliers build five SKU-level folders now, buyer replies become faster and more credible.
For the broader PPWR documentation package, see “PPWR Asks for Proof, Not Promises”. For the wider supplier request scope, see “Documents SMEs Should Request from Packaging Suppliers First”.
About the Author
PackingMaster: Editor of PaperPackLog. Curates and organizes market trends, product information, and technical insights for the paper-packaging industry.
References
- KOTRA, Germany market signal on packaging regulation and buyer requests — https://dream.kotra.or.kr/kotranews/cms/news/actionKotraBoardDetail.do?CONTENTS_NO=2&MENU_ID=80&SITE_NO=3&bbsGbn=242&bbsSn=242&pNttSn=240471
- KATI, EU packaging regulation and Germany market response trend — https://www.kati.net/board/exportNewsView.do?board_seq=105168
- EUR-Lex, Regulation (EU) 2025/40 on packaging and packaging waste — https://eur-lex.europa.eu/eli/reg/2025/40/oj
- EUR-Lex, Commission Regulation (EU) 2024/3190 on BPA in food contact materials — https://eur-lex.europa.eu/eli/reg/2024/3190/oj
- SGS, European Commission issues guidance for PPWR — https://www.sgs.com/en/news/2026/05/safeguards-06026-european-commission-issues-guidance-for-ppwr