Is a supplier declaration sufficient as evidence?

A supplier declaration can form part of the technical documentation and can be an important basis for demonstrating conformity. Article 16 expressly obliges suppliers to make available to the manufacturer the information and documents needed to demonstrate conformity. The European Commission confirms that the manufacturer's EU declaration of conformity may be based on this supplier information.

What matters is therefore not merely whether information comes from a supplier declaration, but whether it robustly and sufficiently substantiates the requirement in question. Responsibility for that assessment, and for the conformity of the packaging, remains with the manufacturer.

Independent testing or certification can reliably underpin that evidence, particularly where product characteristics are to be demonstrated to customers, retailers, authorities or consumers. It is not a mandatory requirement of the PPWR, but it is considerably more robust than a self-declaration from the supply chain.