PPWR: What Your Tin Supplier Can and Cannot Give You

Regulation (EU) 2025/40, the PPWR, has applied since 12 August 2026 (Art. 71). Since then, EU brands have been sending suppliers questionnaires: declarations to sign, certificates to attach, registration numbers to enter.

Some of those lines a tin maker can answer completely, with test data behind them. Some it can answer with a declaration, provided it says plainly what the declaration rests on. And some it cannot answer at all, and a supplier who signs those anyway has not solved your problem: it has created a liability with your name on it. We keep a PPWR technical documentation pack per product, alongside the food-contact and recyclability declarations, and go through it with you while the tin is being specified. The wider picture is in what packaging buyers need to know about PPWR.

What a tin maker can give you

• A component-level bill of materials. Steel grade and thickness, tin coating weight, interior lacquer, exterior inks and varnishes, and every non-steel component: gaskets, windows, trays, sleeves, ribbons, weighed in grams. The grams matter: Art. 6(9) assesses recyclability per unit across all components, and from 2030 Art. 7 reaches any plastic part unless it is under 5% of unit weight (Art. 7(5)(b)).
• Accredited migration testing, and a clear line around it. We hold ISO/IEC 17025 accredited food-contact reports on the lacquered tin: specific migration of metals, specific migration of bisphenol A, and overall migration in three simulants. That is migration into food. Art. 5(4) asks a different question: it caps the sum of lead, cadmium, mercury and hexavalent chromium at 100 mg/kg as content across the packaging and its components, so inks, lacquers and gaskets count, and there is no derogation for metal. The Commission's method for it is CEN report CR 13695-1:2000. Our position on that sum rests on controlled sourcing and supplier declarations, and we say so rather than imply a content determination we have not run.
• Our PFAS position, and exactly what it rests on. Art. 5(5) sets 25 ppb for a single PFAS by targeted analysis, 250 ppb for the sum and 50 ppm including polymeric PFAS. In a tin it sits in the lacquer and varnish, not the steel. Our interior coating is specified and supplied as PFAS non-intent and the coating maker's declaration is on file, which is a declared position rather than a measured one. There is no harmonised EU test method yet, and the Commission's screening starts with total fluorine at 50 mg/kg, which can be commissioned on a given build if your file needs a number. These are limits, not a ban, so we will not write "PFAS-free", and we will not present a supplier declaration as laboratory evidence.
• The food-contact declaration under Regulation (EC) No 1935/2004, with a precise BPA position: under Regulation (EU) 2024/3190 the main transition ended on 20 July 2026, while exterior-only BPA-based coatings on metal articles and some preserved fruit, vegetable and fish uses have until 20 January 2028, filling to 20 January 2029.
• Dimensional and headspace data for your minimisation file. From 1 January 2030, Art. 10(2) bars features aimed only at increasing perceived volume: double walls, false bottoms, unnecessary layers. Annex IV Part A point 4 keeps gift and seasonal purpose as a criterion, but it must be argued and documented; consumer acceptance and marketing were removed (recital 60). The argument is yours.

What a tin maker cannot give you

• The EU declaration of conformity. Art. 39 says the manufacturer draws it up, and under Art. 3(1)(13)(a) the manufacturer is whoever has packaging made under its own name or trademark. Commission guidance: there is only ever one manufacturer in a supply chain. For a brand-printed tin, that is you. Our duty is Art. 16, to give you everything you need to draw it up. Plain, unprinted tins sold under our own name are the exception; there we carry Art. 15.
• EPR registration. It sits with the EU-side operator; a non-EU supplier cannot register for you. You are also the importer: Art. 18(2) requires you to check that the Art. 38 assessment was done by the manufacturer and the Annex VII file exists, and Art. 18(3) puts your name on the pack.
• An authorised representative. It is optional under Art. 17, and a B2B sale from Turkey to an EU brand does not require one. Art. 21 is the trap: an importer or distributor that sells packaging under its own name, or modifies it, becomes the manufacturer.
• A recyclability grade. Nobody can issue one before the delegated act defining the criteria and grades, due by 1 January 2028 (Art. 6(4)). Grades A, B and C sit at 95%, 80% and 70% or above, assessed per unit across all components (Art. 6(9)), and from 2030 below C cannot be placed on the market. What is safe to say: steel packaging is recycled as a separate stream in the EU, and 84% of steel packaging placed on the EU market was recycled in 2024 (Steel for Packaging Europe, EU harmonised method). That is the material, not a grade for your unit.
• A "PPWR certificate". There is no such thing: no CE marking (recital 109), no notified body, no scheme, no mark. Conformity assessment is Annex VII Module A, internal production control, self-assessed by the manufacturer. Anyone selling a PPWR certificate is selling nothing.
• A recycled-content percentage as PPWR evidence. Art. 7 covers minimum recycled content in plastic packaging, and every operative paragraph is limited to plastic parts. There is no recycled-content percentage for metal anywhere in PPWR. We can state what the mill says about the scrap content of the steel, but it is a material fact, not evidence of a PPWR requirement, because for metal there is none.

The failure mode to avoid

A signed declaration with nothing behind it is worse than no declaration. It closes the question in your file without closing it in fact, and does not move the duty: Art. 18(2) still puts the check on you, and a manufacturer must produce documentation to a national authority within 10 days of a request. Test data and weights survive that request. A signature nobody could lawfully give does not.

What to ask your tin supplier for

Paste this into your next email. Every line is a fair question to put to any tin factory, including this one.

• A bill of materials with every component weighed in grams.
• Heavy-metals results for the Art. 5(4) sum across the whole unit, with the method named.
• Total-fluorine and PFAS data on the lacquer and varnish against the Art. 5(5) limits, and no "PFAS-free" wording.
• The Regulation (EC) No 1935/2004 declaration and a dated BPA position.
• Dimensions, headspace and insert weights.
• In writing: who they believe the Art. 3(1)(13)(a) manufacturer is. If it is not you on a brand-printed tin, ask why.

We answer all six, and we mark which answer is a test report and which is a declaration. On PFAS the honest answer today is a coating specification and the coating maker's declaration, with total-fluorine testing available if your file needs a measured number. If you are specifying a tin for the EU, request a quote.

Frequently asked questions

Can our tin supplier sign the EU declaration of conformity for us?

Not for a tin printed with your brand. Under Art. 3(1)(13)(a) the manufacturer is whoever has packaging made under its own name or trademark, and Commission guidance says there is only one manufacturer in a supply chain. The Art. 39 declaration is yours; the supplier's duty is Art. 16.

Is there such a thing as a PPWR certificate?

No. There is no CE marking (recital 109), no notified body and no certification scheme. Conformity assessment is Annex VII Module A, internal production control, self-assessed by the manufacturer.

Can a supplier tell us the recyclability grade of our tin?

No. The delegated act defining the criteria and grades is due by 1 January 2028 (Art. 6(4)). Grades A, B and C sit at 95%, 80% and 70% or above, assessed per unit across all components (Art. 6(9)).

Does PPWR require recycled content in a steel tin?

No. Art. 7 covers recycled content in plastic packaging, and every operative paragraph is limited to plastic parts. Any plastic component is in scope from 2030 unless it is under 5% of unit weight (Art. 7(5)(b)). Art. 7(15) requires a review of non-plastic materials by 12 February 2032.

What PFAS evidence should we ask a tin supplier for?

Ask for three separate things and ask which one you are being given: the coating specification, the coating maker's declaration, and any laboratory data. The Art. 5(5) limits are 25 ppb for a single PFAS, 250 ppb for the sum and 50 ppm including polymeric PFAS. There is no harmonised EU test method yet, so if a report exists, ask which method it used.