What a standard vendor pack already holds

A supplier onboarding file for an Indian exporter contains much the same things everywhere: certificate of incorporation, the Importer Exporter Code (IEC, the ten digit registration every Indian exporter must hold to clear goods), GST registration, a bank letter, management system certificates such as ISO 22000:2018 and ISO 9001:2015, a signed code of conduct, product specifications and an insurance certificate. That pack is portable. It answers the same questions for a buyer in Dubai, Sydney or Rotterdam.

The European additions are different in kind. They are not evidence about the supplier. They are evidence about a specific product entering a specific market, and about who inside the European Union carries the legal obligation once it arrives. That is why a supplier who has never shipped to the European Union will not have them waiting in a folder.

The four EU additions and who owns each one

The table compares the four documents on what each one evidences and where the obligation actually sits.

Whose EPR number goes in the buyer’s portal field?

Most European vendor portals contain a field labelled something like “supplier EPR registration”. The field is misleading. Packaging extended producer responsibility, the national schemes that charge whoever first places packaging on a market for its end of life collection, attaches to the operator placing that packaging on that market. On a delivery from India on any Incoterms 2020 rule short of DDP, that operator is the European buyer.

A supplier offering to hand you “our EPR number” is therefore almost always offering something that does not discharge your obligation. Indian manufacturers are not registered with Zentrale Stelle Verpackungsregister, the German packaging register that runs the LUCID database, or with CITEO in France, or with Afvalfonds Verpakkingen in the Netherlands, because they are not placing packaging on those markets. The question of who registers for EPR when you import from India has a settled answer in most cases, and the answer is you.

Run one check before you accept anyone’s number. Zentrale Stelle Verpackungsregister publishes its register of producers openly, including the registration number and the brand names declared against it. If a supplier or forwarding agent gives you a LUCID number, look it up and confirm the entity name and packaging types match what you were told.

What the supplier owes you here is data, not a number: material type and net weight per packaging component, per carton and per pallet, in the format your scheme reports in. The supplier data you need to file an EPR return is the part an Indian manufacturer can and should deliver.

What a Declaration of Compliance does and does not prove

Regulation (EC) No 1935/2004, the EU framework regulation on materials and articles intended to come into contact with food, sets the general requirement in Article 3: materials must be manufactured under good manufacturing practice so that, under normal or foreseeable conditions of use, they do not transfer constituents to food in quantities that could endanger human health, change the food’s composition unacceptably, or deteriorate its organoleptic characteristics.

Article 16 requires that materials covered by a specific measure carry a written declaration stating compliance, with appropriate documentation available to competent authorities on demand. Article 17 adds traceability: operators must be able to identify the businesses from which and to which materials were supplied.

Three failure modes recur. The first is a declaration naming a material rather than an article, so it cannot be matched to the plate on the pallet. The second is a declaration asserting compliance with no supporting file behind it, which fails the second sentence of Article 16(1) even where the first is satisfied. The third is a declaration signed by a trading company that never held the supporting data. Taking the Declaration of Compliance apart field by field before you accept it is faster than discovering the gap during an inspection.

Read the scope line on a compostability certificate

A compostability certificate is issued to a named holder for named products. The Seedling mark, owned by European Bioplastics and issued under licence by certification bodies including TÜV AUSTRIA, certifies conformity with EN 13432, and the certifier maintains a public database of certified products.

The scope line is the whole document. A certificate covering a supplier’s 10 inch square plate does not cover its 12 inch Reinforced Round Traditional Patravali Meal Plate. A certificate held by a raw material supplier does not transfer to a converter’s finished article. A lapsed certificate looks identical to a current one on a PDF. Check holder name, product list, standard version and expiry against the public register rather than the copy the supplier emailed. What a compostability certificate proves and what it does not is the difference between a defensible claim and one you withdraw later.

Here is the part that reduces your document count rather than increasing it. If you make no compostability claim on the product, its packaging or your own marketing, you do not need a compostability certificate to import the goods. Many buyers ask for one reflexively and never use the claim. Decide whether the claim is part of your commercial proposition before you make the certificate a condition of onboarding.

The economic operator statement

This is the shortest of the four and the one most often missing. It is a signed statement confirming the supplier’s registered legal name and address, its company or LLP identification number, its IEC, whether it manufactures the goods itself or buys them in, and that it has no establishment in the Union.

The statement does two things. It lets you record, in your own compliance file, that you are the operator placing both goods and packaging on the EU market under Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation, which has applied since 12 August 2026 and transfers manufacturer obligations to the importer. It also gives you a traceability record answering Article 17 of Regulation (EC) No 1935/2004 without a separate exercise. Where the line between importer and manufacturer obligations under PPWR falls is worth reading before you sign your own name to anything.

The manufacturer or trader field is answered loosely most often. Ask for it in writing, with the factory address, and state whether that address is owned or contracted.

Who inside the supplier owns each document

On a small or mid sized Indian manufacturer these four documents sit with three different people, and asking the wrong one costs a week. EPR packaging data sits with production or packing, because it is a weighing exercise on the carton and pallet actually in use. The Declaration of Compliance and its supporting test file sit with the quality or food safety lead, who holds the laboratory reports. The compostability certificate and the economic operator statement sit with the director or the export documentation desk.

Send the four requests separately, addressed to the function rather than a general sales inbox, and give the packaging data request a weighing specification: which components, weighed empty, to what precision. That instruction removes the most common round trip.

Frequently asked questions

Related reading

• The Declaration of Compliance, field by field
• You or your supplier: who registers for EPR when you import from India
• The supplier data you need before you can file an EPR return
• What a compostability certificate proves, and what it does not
• Importer or manufacturer: who carries the PPWR obligation on goods from India

References