A declaration of conformity (DoC) arrives for a corrugated export package. The heavy-metals field says only “without.” The buyer cannot tell which packaging was assessed, how it was tested or where the supporting report is. This guide gives purchasing and quality teams a short, copyable check before treating that PDF as a finished compliance handoff.
In a September 24, 2026 Packaging Europe opinion article, Emission Core founder Adrian Reyes said the declarations he had reviewed for clients were sent back for correction or re-issue. In one example, a declaration contained “without” in the heavy-metals field, but, in the author’s account, no laboratory, method or report number supported it. That is one consultant’s account of client documents—not an official EU rejection statistic or an industry-wide failure rate. We use it as a prompt to check the underlying regulation, not as proof that every supplier is in breach.
What the law requires—and what the buyer should request
The EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, began applying on August 12, 2026. Article 5(4) limits the sum of lead, cadmium, mercury and hexavalent chromium concentrations arising from substances in packaging or packaging components to 100 mg/kg. Article 5(6) says compliance must be demonstrated in the technical documentation drawn up under Annex VII. A general chemical statement about the product inside the packaging is not evidence about the packaging itself.
Annex VII calls for the relevant requirements, technical specifications and applicable test reports in the technical documentation, and a written declaration for each packaging type. Article 39 points to Annex VIII for the EU declaration’s model structure. Do not misstate this as a literal legal rule requiring a test-report number to be printed in a specific “heavy metals” box on every DoC. But a buyer still needs an auditable connection between the identified packaging, the evidence and the claim. Requesting the report number, revision and sample identifier is a sensible internal control.
Five fields to check when a DoC arrives
This is an internal buyer/importer review aid, not a substitute for Annex VIII or the rules applicable to a particular package and Member State.
| Check | What to find | Decision and owner |
|---|---|---|
| Packaging identity | Packaging type, components, revision and delivery identifier | If the DoC and shipped item differ, purchasing pauses release for that order/SKU and asks the manufacturer to reconcile them. |
| Applicable requirements | Applicable PPWR provisions, including Article 5(4), distinguished from other laws | For a vague “complies with all regulations,” regulatory affairs requests the actual applicable provisions. |
| Test linkage | Sample ID, laboratory, method/specification, report ID and date | If absent, quality asks for the report covering the packaging components in question. |
| Interpreting the result | Results and units for the four substances, combined assessment and relevant detection limits | If it says only “not detected,” quality requests detection limits and the basis for comparison with the combined limit. |
| Declaration structure | Annex VIII packaging identification, responsible entity, references, date and signature | For missing fields, the buyer/importer asks the manufacturer for a corrected declaration and holds the current document for review. |
A concise request to the supplier might say: “Please provide the EU DoC for this packaging type and identify the heavy-metals test report, revision and sample it covers. If film or cushioning is a separate packaging component, show how each is covered.” This is an example of procurement correspondence, not an official EU submission form.
Do not treat a quick XRF screen as a complete four-substance result
Handheld X-ray fluorescence (XRF) can help screen for some elements. A total-chromium signal alone, however, does not establish how much of the chromium is hexavalent Cr(VI). US EPA SW-846 Method 6200 concerns elemental concentrations in soil and sediment: it is useful methodological background, not a PPWR-approved packaging test method. Coatings, inks, adhesives, sample preparation, detection limits and the actual analytical method can change what the result covers. Ask the testing laboratory which substances and packaging layers its report represents. Neither a device screen nor the words “not detected” by themselves establish that the four-substance sum is below 100 mg/kg. Select the analytical approach for the actual construction and relevant technical specification.
A handoff decision for each team
- Quality: Compare the sample construction with the produced packaging type and track changes in inks, coatings, adhesive and base paper. Reassess whether an older report still represents the current construction after a material change.
- Purchasing: Do not close the request as “document received” when the declaration cannot be tied to a sample and report. Ask the supplier for the missing linkage.
- EU importer/regulatory team: Under Article 18, verify before placing packaging on the market that the manufacturer has carried out the conformity assessment and prepared technical documentation, and that required markings and documents are present. If there is reason to believe the packaging does not conform, do not place it on the market until it is brought into conformity.
Our earlier six-package PPWR documentation overview lists the files to prepare. This article narrows the task to one decision: can a heavy-metals statement on a DoC be traced to the actual packaging and supporting measurement? Before the next handoff, compare the identified packaging type, its report and the material you will actually ship.
About the Author
PackingMaster: Editor of Paper Pack Log. We collect and organize market trends, product information, and technical insights for the paper packaging industry.
References
- European Union, Regulation (EU) 2025/40, Articles 5(4), 5(6), 15, 18, 39 and Annexes VII–VIII
- Adrian Reyes, “How to avoid the most common PPWR mistakes,” Packaging Europe, 2026-09-24 (client-document account; the regulation above is the source for legal requirements)
- European Commission, Packaging waste overview (background)
- US EPA, SW-846 Method 6200: Field Portable X-Ray Fluorescence Spectrometry (soil/sediment elemental-analysis background, not a PPWR packaging test method)