For each of Articles 5 to 12 you say declared as met or not applicable, with a line saying on what basis. A draft can be saved and left. Issuing needs every requirement answered, and Article 5 cannot be set aside — the substance restrictions applied from 12 August 2026 with no transition.
A supplier's declaration is their word with their name on it, recorded and dated. Your own declaration is your word, assembled from your data and signed by you. Neither is a test report, and neither is the technical documentation under Annex VII — that you hold yourself.
Tarafex also does not certify anything, does not decide whether packaging complies, and the assistant is forbidden from answering that question. Ask it, and it will point you at the place in Tarafex where the judgement is recorded, because the judgement is yours.
Retention follows the file, not a setting: five years, or ten where any of that supplier's packaging is reusable. Tarafex says when a period ends; it never deletes anything on a date.
Both documents are cut from the catalogue. Recycled content on the data sheet is the same figure Article 7 is looking at. A supplier answer that landed through a link is the same answer sitting under Article 5 as a suggestion. There is no second set of numbers to keep in step.
A microenterprise may not be the manufacturer at all. Under the definition in Art. 3(1)(13)(b), where a microenterprise has packaging made under its own name or trademark and the supplier is established in the SAME MEMBER STATE, the supplier is the manufacturer — and with it the declaration and the technical documentation; the Commission reads it the same way. Article 15(12) words the same relief more widely: a supplier located in the Union. It is an allocation of responsibility, not an exemption from the regulation. Establish which side of that line you are on before signing anything: the two wordings do not say the same thing.
Article 5 also carries a limit that is older than the regulation. The sum of lead, cadmium, mercury and hexavalent chromium may not exceed 100 mg/kg — 100 ppm — in the packaging or in any of its components, inks, coatings and adhesives included. It came across from Directive 94/62/EC and applies whatever the material, so a supplier answer that covers only the main material does not answer it.
One number is misplaced more often than any other. The empty-space ratio — no more than 50 % void in grouped, transport and e-commerce packaging — is Article 24, and it applies from 2030. It is not Article 10, which is minimisation, and it is not 40 %. If a declaration cites the wrong article, it is wrong in the one document whose whole purpose is to say which requirements were assessed.
A crate built to your customer's drawing and a pallet sold off the shelf do not have the same answer. The Commission's FAQ, second edition of August 2026, separates two questions that are easy to merge: the final form of the empty packaging is the point at which the manufacturer is identified, not the answer to who it is. If a name or trademark is on the packaging, that company is the manufacturer. If nothing is on it and the packaging is generic and standardised, it is normally the company that physically makes it. If nothing is on it and the packaging is made to order, it is the company that placed the order and set the design specification.
One shipment can therefore carry packaging from several manufacturers, each owing its own technical documentation and its own declaration. A shipping sticker is not branding.
What cannot be moved: the conformity assessment may be carried out by someone else, and an authorised representative may draft the declaration, but the technical documentation is drawn up by the manufacturer, and no contract transfers the legal responsibility. A supplier, for their part, cannot refuse you the information you need for it — Article 16(1).
The manufacturer of the packaging, in their own sole responsibility — a person entitled to sign for the company. An importer or a distributor does not sign in the manufacturer's place; they have to check that the declaration and the technical documentation exist before placing the packaging on the market. A packaging supplier can give you test data and their own declaration, but that does not move the responsibility for yours.
Not all of them at once. Article 5 on restricted substances applies now, including the PFAS limits for food-contact packaging, and so do the conformity assessment, the EU declaration and the technical documentation. Other articles start later — minimum recycled content in plastic and the minimisation rules from 2030, harmonised labelling from 2028. A declaration may only state as met what is applicable on the day it is issued; the rest is marked not yet applicable.
Article 16(1) obliges suppliers of packaging and packaging materials to give the manufacturer all the information and documentation needed to demonstrate conformity, including the Annex VII technical documentation and what is required under Articles 5 to 11 — in one or more languages the manufacturer easily understands. That last point is a right, not a courtesy: a supplier cannot answer only in their own language and leave you to translate it. This is why Tarafex asks the supplier directly instead of guessing: a link, no account, no password. The answer arrives with a name and a date on it, and is kept as their word, not rewritten as yours.
PFAS is one of the substance questions put to the supplier, next to heavy metals, REACH substances of very high concern, phthalates, flame retardants and substances in inks and adhesives. Tarafex does not test for PFAS and does not decide whether a packaging is compliant. It records who answered, what they answered and when — and a supplier who declared PFAS present must never end up looking like one who declared it clean.
No. The conformity assessment for packaging is internal production control, which the manufacturer carries out themselves. There is no third-party body to appoint and no certificate to buy. What you do need is the technical documentation behind the declaration, kept so that it can be produced on request.
Five years for single-use packaging and ten years for reusable packaging, counted from the packaging being placed on the market. In Tarafex the retention follows the document rather than a setting, and the tool says when a period ends. It never deletes anything by itself.
Being small is not an exemption. There is one narrow relief: where the person having the packaging designed or made under its own name or trademark is a micro-enterprise within Recommendation 2003/361/EC as applicable on 11 February 2025, and the supplier of that packaging is located in the Union, the supplier counts as the manufacturer under Article 15(12). Note the wording — the Union, not the same Member State; the narrower phrasing belongs to the definition in Article 3, not to this one. It changes who issues the declaration; it does not remove national registration and reporting duties, which are separate and stay yours.
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One register per country, and in six of the 27 it does not exist yet. The table gives the register, the threshold and whether a foreign producer needs a representative — dated, with the source at every line.
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