A retailer asks for packaging data per product

A retailer that sells your packaged product is a distributor of the packaging, and since 12 August 2026 the Packaging and Packaging Waste Regulation (EU) 2025/40 gives it checks of its own (Article 71). Before making packaging available, a distributor verifies that the producer subject to extended producer responsibility is registered in the national register of producers, that the packaging is labelled in accordance with Article 12, and that the manufacturer and the importer have put the identification and their name and address in place (Article 19(2)). A packaging data sheet is how many retailers collect the facts for that check.^[1]

Much of what is asked sits in documents the manufacturer must hold anyway. Before placing packaging on the market, the manufacturer carries out the conformity assessment, draws up the technical documentation in Annex VII and draws up an EU declaration of conformity (Articles 15(2) and 39). The technical documentation contains a general description of the packaging, the design and the materials of its components, the standards applied, a description of how recyclability, minimisation and reusability were assessed, and test reports. The requirements it covers are those of Articles 5 to 12: substances, recyclability, recycled content in plastic, compostability, minimisation, reusability and labelling. Several of them are phased in; minimisation, for example, must be ensured by 1 January 2030 (Article 10(1)).^[1]

Who must hold what depends on the role. The manufacturer is whoever manufactures packaging or a packaged product, but where a company has it designed or manufactured under its own name or trademark, that company is the manufacturer (Article 3(1), point 13). Suppliers of packaging or packaging materials must give the manufacturer all the information and documentation needed to demonstrate conformity (Article 16(1)). An importer ensures that the manufacturer has done the assessment and drawn up the documentation, and puts its own name and postal address on the packaging (Article 18(2) and (3)).^[1]

The registration question belongs to the producer: the manufacturer, importer or distributor that first makes the packaged product available in a Member State, or sells it directly to end users in another one (Article 3(1), point 15). Producers register in each Member State concerned and report by 1 June for each preceding calendar year (Article 44(2) and (7)). Member States set up the registers within 18 months of the entry into force of the first implementing act on the registration and reporting format (Article 44(1) and (14)); until a register exists, check what the authority in each country of sale requires. Market surveillance authorities can in any case require documents and information on compliance from economic operators (Regulation (EU) 2019/1020, Article 14(4)(a)).^[1][2]