Declaration of compliance: direct food contact or PPWR?
“Could you send us the declaration of compliance for this packaging?” It seems like a simple question, but which declaration is actually meant?
Now that the initial commotion surrounding the PPWR has settled somewhat, we would like to take a moment to clear up a common misunderstanding. We have noticed that food contact compliance and PPWR compliance are often confused.
Both concern packaging. However, they answer different questions. What is the difference, and which declaration do you need?
Food contact: is the packaging safe for food?
A Food Contact Declaration of Compliance (DoC) relates to materials intended to come into contact with food. One example is a plastic bag in which food is packed directly.
For plastic food contact materials, relevant legislation includes Regulation (EU) No 10/2011 and its amendments. Various legal requirements and guidelines apply to food safety. Our technical team will be happy to answer questions about the requirements that apply to your packaging and its intended use.
The central question is: can this material be used safely for the intended food contact application?
PPWR: does the packaging meet European packaging requirements?
The Packaging and Packaging Waste Regulation (PPWR) concerns packaging and packaging waste. It covers aspects such as composition and design, recyclability, recycled materials, reuse, substances in packaging, information requirements and waste prevention.
The central question here is: does this packaging meet the applicable PPWR requirements?
A PPWR declaration of conformity can be relatively concise, but it must be supported by appropriate technical documentation and evidence. The applicable obligations depend on the type of packaging, the material, its intended use and the date on which the relevant requirements become applicable.
One declaration does not replace the other
Packaging that is suitable for direct food contact is not automatically PPWR-compliant. Conversely, PPWR-compliant packaging is not automatically suitable for direct food contact.
Both legal frameworks may therefore be relevant to the same packaging. Each declaration serves a different purpose, and they are not interchangeable.
Which declaration do you need?
When requesting a declaration from AVI, please tell us which packaging it concerns and how you use it. Does the packaging come into direct contact with food, for example? Are you requesting a food contact declaration, a PPWR declaration, or both?
This information allows us to assess your request and provide the appropriate declaration and supporting documentation.
Not sure which declaration you need? Contact us. We will be happy to help.