Compliance questions have moved from a tick-box on the supplier form to a document request before the first order. Here is what is actually being asked, and what we can evidence.
EU 2018/852 amended the packaging waste directive and set the direction the current PPWR regulation continues: less material, more recyclability, and evidence that the label does not block the recycling stream of the container. For a self-adhesive label the practical question is whether the liner and adhesive are compatible with the pack's end-of-life route.
Buyers now ask for a declaration against the current SVHC candidate list rather than a generic REACH statement. The number of substances on that list changes, so a declaration dated two years ago is treated as expired. We reissue ours on request and state the list revision it refers to.
For direct contact the framework is EU 10/2011 for plastics and FDA 21 CFR 175.105 for adhesives; for indirect contact, a migration test on the finished laminate is what the brand's own QA will ask for. We supply the adhesive supplier's declaration and, where the customer needs it, arrange migration testing on the finished construction.
EN 71-3 for heavy metal migration and CPSIA for the US market come up on gift packaging and children's products. These are material tests, not label tests, but the label is inside the scope of the article.
Supplier declaration, SVHC statement with the list revision, heavy metal test reports, and the food contact declaration where relevant. We issue these per material family rather than per order, so the same document set can be reused across purchases.
We do not describe a supplier's test report as our own certificate. The reports are issued to our material supplier; we pass them on with that stated on the face of the document. Buyers check this, and a mislabelled certificate is worse than a missing one.