Skip to main content

Compliance data: Content & substances

Material composition and substance information required for PPWR and DPP compliance, covering recycled, biobased, hazardous, and certified content for transparency and conformity reporting.

Updated this week

The Content & Substances section collects all material-composition and chemical-substance information required under the:

  1. Packaging & Packaging Waste Regulation (PPWR) – Regulation (EU) 2025/40

  2. Ecodesign for Sustainable Products Regulation (ESPR) & Digital Product Passport – Regulation (EU) 2024/1781

  3. Upcoming Green Claims Directive

These fields do not impact your footprint, but they do appear in the Digital Product Passport and must be correct for regulatory reporting. Every compliance field in this section follows the same workflow:

How you enter compliance data

1. Turn the claim ON only when it applies

If you don’t have evidence or the claim is not true → keep it OFF.

2. Enter the verified value or description

(Number, % share, concentration, certification scheme, etc.)

3. Select your proof type

Pick the type of documentation you have (certificate, test report, supplier declaration).

Important: Pickler does not audit or validate your compliance data.
You remain responsible for evidence and accuracy.


Entering your compliance data for content & substances

Plastic-free

The plastic-free fields show whether the packaging contains no plastic materials at all, including polymers, coatings, linings, or adhesives. This is a voluntary claim, but under EU law it must be fully verifiable.

Product is plastic free

Enable Plastic-free only if the product contains zero plastics according to EU definitions (Regulation (EU) 10/2011 and Directive 2019/904).

Plastic-free evidence

Select your evidence type, or select from the dropdown:

  • Accredited lab test report – Verified lab analysis proving no plastics are present.

  • Third-party certification – Independent certification confirming compliance with EU plastic-free definitions.

  • Supplier declaration – Written statement confirming no plastics are used in materials or components.

  • Material composition documentation – Verified material list showing full absence of plastic content.

  • Manufacturer self-declaration – Internal declaration supported by technical or test data.

  • None available

Keep the underlying proof available in your internal documentation for audits or customer requests.

Legal context

  • Defined under Regulation (EU) 10/2011 and Directive (EU) 2019/904.

  • A voluntary claim, but must be verifiable under the Green Claims Directive (COM/2023/166).

  • Evidence requirement applies from the Green Claims enforcement timeline (~2026–2027).

  • Under EU law, “plastic-free” excludes both fossil-based and biobased plastics.


Recycled content

The recycled-content fields show how much of the packaging comes from post-consumer or post-industrial sources. This becomes a core PPWR requirement, especially for plastic packaging from 2030.

Contains recycled content

Switch Recycled content to ON if the product contains any recycled material.

Recycled content type

  • Post-consumer recycled content (%) - material that comes from post-consumer sources.

    • e.g.: Used bottles, trays, cups, pouches, Household packaging waste, Retail or commercial packaging collected after use

  • Post-industrial recycled content (%) - material that comes from post-industrial sources

    • e.g.: Production scrap (cutting waste, trimmings, offcuts), defects or rejects from manufacturing, or factory waste from converting or forming processes

Recycled content certificate or standard

Enter certificate or verification method confirming the presence of recycled content in the materials used, or select from the dropdown:

  • EN 15343 certificate – EU standard for verifying traceability and recycled plastic content.

  • ISO 14021 self-declared claim – International standard for self-declared recycled content claims.

  • ISO 14025 EPD (Environmental Product Declaration) – Verified declaration including recycled content data.

  • Accredited test report – Lab test confirming recycled material proportion in the product.

  • National/private certification (e.g. RecyClass, UL, SCS, TÜV) – Third-party certification of recycled content.

  • Manufacturer self-declaration – Internal claim based on supplier or production documentation.

  • None available

Legal context

  • PPWR Art. 6(2) + Annex II — recycled content reporting for all packaging.

  • Mandatory recycled content targets for plastic packaging apply from 2030.

  • Claim documentation required under PPWR Art. 6(5) and future Green Claims Directive.

  • Under PPWR, recycled content must be declared per packaging component, not only per finished product.


Biobased content

Biobased content shows the verified % of material derived from renewable biological sources such as paper, fibres, PLA, or bio-PE.

Contains biobased content

Switch Biobased content to ON if the product includes plant-based or renewable materials.

Biobased content percentage

Enter the % biobased content (based on verified weight share).

Biobased content certificate or standard

Enter the certificate, test report, or standard used to verify biobased content, or select from dropdown.

  • EN 16785-1 – EU standard for verifying biobased content in packaging and materials.

  • ASTM D6866 – International method measuring biobased carbon via radiocarbon analysis.

  • ISO 16620 – Global ISO standard for determining biobased carbon in plastics.

  • Accredited test – Lab-verified test confirming biobased content without full certification.

  • National or private certification (e.g. DIN CERTCO, TÜV, USDA) – Recognised third-party label proving verified biobased content.

  • Manufacturer self-declaration – Internal statement supported by technical or test data.

Legal context

  • PPWR applies from 12 August 2026 (general application date).

  • Environmental composition claims must be substantiated under the Green Claims Directive.


Certified wood

This section captures whether any paper, board, or wood in the packaging is certified under a recognised scheme.

Contains certified wood

Switch ON if the packaging contains certified wood.

Percentage certified wood

Share of total paper/wood weight that is certified.

Wood certification

Enter the certification or scheme applied or select from dropdown.

  • FSC 100% – All wood comes from FSC-certified forests.

  • FSC Mix Credit – Mix of FSC-certified, controlled, and recycled wood.

  • FSC Recycled – Wood sourced entirely from verified recycled material.

  • PEFC Certified – Certified under the Programme for the Endorsement of Forest Certification.

  • National or private certification – Recognised local scheme equivalent to FSC or PEFC.

  • Manufacturer self-declaration – Internal statement based on supplier documentation.

Legal context

  • Voluntary claim, but must be substantiated under the Green Claims Directive.

  • Supports due-diligence requirements under other EU laws (e.g. EUDR).


Hazardous substances

This section covers PFAS, heavy metals, and other regulated substances of concern, as required under PPWR and ESPR/DPP.

Hazardous substances present and concentration per substance

Select which substance group(s) are relevant.

  • PFAS concentration (ppb)

    • Total concentration of PFAS expressed in parts per billion (ppb). Used to demonstrate compliance with PPWR Article 5 restrictions for food-contact packaging.

  • Heavy metals concentration (mg/kg)

    • Total concentration (mg/kg) of regulated heavy metals — lead (Pb), cadmium (Cd), mercury (Hg), and hexavalent chromium (Cr VI). Must not exceed the maximum limits under PPWR Article 5.

  • Other substances of concern (SVHC or other regulated substance)

    • Name of the hazardous substance identified under REACH or DPP registry. Used when a regulated substance other than PFAS or heavy metals is present.

Analytical or test method reference

Enter the test method or evidence used, or select from dropdown.

  • EN 62321 series – EU standard methods for detecting restricted heavy metals and substances.

  • ISO 21672 – International method for analyzing volatile and semi-volatile organic compounds.

  • ASTM D7979 – US standard for identifying PFAS and similar fluorinated compounds.

  • Accredited lab test report – Verified laboratory report from an accredited testing facility.

  • National or private certification – Recognised test or conformity label confirming substance compliance.

  • Manufacturer self-declaration – Internal documentation based on test data or supplier confirmations.

Legal context

  • PPWR Art. 5 — restrictions on heavy metals & PFAS

    • PFAS restrictions apply to food-contact packaging from 12-08-2026

    • Heavy metal limits apply from the general PPWR date (12–08–2026)

  • ESPR/DPP Art. 8–10 — DPP reporting of substances of concern, incl. test methods, phased per product group from 2027 onward


6. EU Declaration of Conformity (DoC)

The DoC confirms that the packaging meets the applicable EU requirements (materials, food-contact rules, PPWR, etc.).

EU Declaration of Conformity (DoC) available

Indicates whether a signed Declaration of Conformity exists for this packaging unit or type. If yes, keep the DoC in your own documentation system.

Legal context

  • Required under PPWR, effective 12 August 2026.

  • Relates to PPWR technical documentation obligations.

  • PPWR requires DoC to be made available electronically upon request

Did this answer your question?