Reading time: 5 minutes
Updated August 11, 2026: This post has been revised to reflect the European Commission’s expanded PPWR FAQ, published August 3, 2026, which directly addresses who is the manufacturer of transport packaging, including stretch film and strapping.
From August 12, 2026, every packaging type placed on the EU market requires a Declaration of Conformity confirming it meets the sustainability requirements of the Packaging and Packaging Waste Regulation (PPWR). For transport packaging, determining who is responsible for the Declaration of Conformity comes down to whether the packaging has reached its final form when it is sold, whether it carries a name or trademark, and whether it was custom ordered to a specific design. This applies the same way to rigid formats like pallets and creates and to flexible formats like stretch film and strapping. Many supply chain teams have relied on a rigid-vs-flexible split to determine this, based on earlier Commission guidance that the August 2026 FAQ update has since superseded.
Understanding this now matters. It determines who builds the technical documentation, who issues the Declaration of Conformity, and who carries the legal obligation if something is wrong.
PPWR Transport Packaging: Who Counts as the Manufacturer
Under the PPWR, the obligation to issue a Declaration of Conformity falls on the manufacturer, defined as the party that manufactures packaging under their name or trademark, or that effectively controls the manufacturing of such packaging. For transport packaging, the Commission’s FAQ, updated August 3, 2026, sets out a clear test: the manufacturer is identified at the stage where the empty packaging has reached its final form, meaning it can be used as transport packaging without any further components or ancillary elements added to it.
This test applies the same way to rigid and flexible formats. A cardboard box reached its final form even flat and unfolded. Stretch wrap has reached its final form once it is sold on a roll, even though it is later cut and wrapped around a pallet load. The act of cutting and wrapping is using the packaging, not manufacturing it.
For unbranded, standard transport packaging, including the generic stretch film and strapping, the manufacturer is the company that physically produces it and places it on the market, not the company that purchases it and applies it to secure a shipment. This holds for pallets, crates, stretch film, and strapping alike: if you are buying standard, off-the-shelf material and using it to wrap or secure your own shipments, you are typically not the manufacturer of that material under PPWR.
Two exceptions are worth knowing. If the packaging carries a name or trademark, whoever owns that name or trademark is the manufacturer, regardless of who physically produces it. A shipping label or sticker applied for logistics purposes does not count as branding for this purpose. Separately, if you commission packaging custom-made to your own design specifications rather than buying a standard product, you become the manufacturer, because you hold the decisive control over its characteristics.
Each distinct transport packaging type in a shipment, a pallet, a stretch wrap, a set of straps, is treated as its own packaging item. Each requires its own conformity assessment and its own Declaration of Conformity, and there can be multiple manufacturers, each responsible for their own component, within a single shipment.
The practical takeaway: if your operations use standard stretch film or strapping bought off the shelf, your supplier is very likely the manufacturer responsible for the Declaration of Conformity, not you. Confirm this directly with your supplier and, if possible, secure their Declaration of Conformity and any supporting technical documentation as a part of your own audit trail.
What the Technical Documentation Must Cover
If you are the manufacturer for any of your transport packaging, whether a custom-ordered format or branded packaging under your name, you need to build the technical documentation that supports your Declaration of Conformity.
At the August 12, 2026 application date, component-level data is sufficient for material composition. This means confirming the material makeup of each packaging component. Your documentation must also confirm conformity with the heavy metals limit: the combined concentration of lead, cadmium, mercury, and hexavalent chromium in packaging and its components must not exceed 100 mg/kg.
If you are not the manufacturer, for most standard stretch film and strapping purchases, your role shifts from producing documentation to verifying duties of preceding actors in the packaging supply chain. While you don’t need each supplier’s Declaration of Conformity or the technical documentation behind it, you need to exercise due care to check whether the manufacturer/importer complied with their duties (such as conformity assessment, labelling, contact markings, and EPR registration) before you make the packaging available in the downstream supply chain. You also need to be able to show, on request, which supplier’s material is behind which shipment.
If your supplier provides it to you, the Declaration of Conformity and the supporting technical documentation must be kept available for national market surveillance authorities for five years for single-use packaging.
What This Means for Your Operations
If your warehouse or outbound logistics team uses stretch film, strapping, or other transport packaging, here is what to act on now.
- Identify what you buy standard versus what you commission custom-made.
Standard, off the shelf stretch film, strapping, pallets, and crates: your supplier is typically the manufacturer. Packaging custom-made to your specific design: you are typically the manufacturer. - Check whether your transport packaging carries a name or trademark.
If it does, whoever owns that name or trademark is the manufacturer, regardless of who physically produces it. A shipping sticker does not count as branding. - Align with your suppliers on who holds which obligation.
Confirm they understand they are likely the manufacturer for standard materials, and confirm they will comply with their duties: conformity assessment, labelling, contact markings, and EPR registration. - Treat each packaging type separately.
A pallet, its stretch wrap, and its strapping each need their own conformity assessment and Declaration of Conformity, potentially from different manufacturers within a single shipment. Be sure to verify all of them comply with their obligations.
Getting your role, and your suppliers’ roles, correctly identified now is the first step to having the right documentation in place before the deadline.
How PAQR Can Help
If you are the manufacturer for your transport packaging, the Declaration of Conformity and its supporting technical files are your responsibility to produce and retain. PAQR’s PPWR compliance workspace gives you a central place to organise your packaging data by format, collect the material documentation you need from your suppliers through the supplier request portal, and generate your Declaration of Conformity when your technical files are complete.
Click “Try now for free” on paqr.com to start a free trial:
