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// INTRODUCTION

What will an EU buyer ask for?

The Packaging and Packaging Waste Regulation — PPWR for short — sets the requirements packaging must meet to be placed on the EU market, and it has applied since 12 August 2026, the date on which Directive 94/62/EC was repealed. For a buyer shipping into the EU, that means asking their supplier for documentation.

DEKA Plastik had this file ready by the date the regulation became applicable. Below you will find which documents exist, which Articles they address, and what cannot yet be claimed.

// DOCUMENTS

The file we hold

PPWR Technical File
Annex VII — Module A, internal production control
EU Declaration of Conformity
Conformity with Articles 5–12
Declaration of Material Composition and Recycled Content
Articles 6 and 7
Declaration of Conformity — Heavy Metals and PFAS
Article 5 · 94/62/EC Art. 11
Supplier Conformity Information
Article 16
Customer Information
PPWR general

The technical file is drawn up under the Module A — internal production control procedure defined in Annex VII of Regulation (EU) 2025/40. Document numbers are shared on request, at order stage.

// ARTICLE BY ARTICLE

How each Article is met

Art. 5

Substances in packaging

The sum of lead, cadmium, mercury and hexavalent chromium concentrations is limited to 100 mg/kg. This is a content limit, distinct from a migration measurement; conformity is verified by analysis of the finished product at an accredited laboratory. On the PFAS side, no raw material, additive or processing aid containing fluorinated compounds is used in our processes.

Art. 6

Recyclability

A mono-material structure is used for our PE products; there is no lamination, no coextruded barrier layer, no metallised layer and no non-PE component such as paper, aluminium or polyamide. As stated in its own text, our material composition declaration covers PE bags only; it does not cover polypropylene (CPP, OPP) or polyamide/PE products. This follows from the technical file being drawn up under Annex VII Module A — internal production control: we extrude PE film in our own facilities, whereas PP film is sourced from approved suppliers. In PA/PE products the barrier function requires a multilayer structure.

Art. 7

Recycled content

On request, between 20% and 100% post-consumer or pre-consumer recycled polyethylene can be used. Recycled PE is chemically polyethylene as well; whatever the blend ratio, the product keeps its mono-material PE character. Traceability rests on our GRS 4.0 and RCS 2.0 scope certificates.

Art. 10

Minimisation

Our products carry no double walls, no false bottoms and no layer without a functional purpose. Film thickness is set together with product protection, process stability, logistics strength and regulatory requirements; the tolerance for thickness and grammage is ± 8%.

Art. 11

Reusability

Our products are designed and placed on the market as single-use packaging. The reusability conditions listed in Art. 11(1) do not apply; this Article is out of scope.

// BOUNDARY

What cannot yet be claimed

We do not claim a recyclability performance class. Under Art. 6(4), design-for-recycling criteria and performance classes are to be set by the Commission through a delegated act by 1 January 2028. Because the criteria have not been published, no class can be assigned today under Annex II Table 3.

We can document the mono-material structure and the material composition; we cannot give you a letter or a percentage class. We are telling you now because this is exactly the question an audit will raise, and we will update the file once the criteria are published.

// REQUESTS

What you can request

At order stage you can request the EU Declaration of Conformity, the material composition declaration, the heavy metals and PFAS declaration of conformity, and accredited laboratory analysis results. For production with recycled content, a Transaction Certificate can be issued at shipment level.

For all of our quality documentation see the Quality Certificates section, and for our recycled-content product see the GRS Bag page.

Do you need documentation for your PPWR file?

Tell us which document you need and which market you ship to, and we will prepare and send the relevant declarations.

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