Your Supplier File Is Full. That Is Not the Same as Usable.

I asked a supplier a simple question last quarter. What sits behind the 30 percent recycled content figure printed on this shampoo bottle?

What came back was one page.

SUSTAINABILITY STATEMENT. We confirm that products within our PCR bottle range are manufactured with up to 30 percent post consumer recycled (PCR) content. Our facilities operate to recognized environmental standards. Issued: March, two years ago.

I have changed the identifying details. I have not changed the shape of it, because I receive a version of this document from roughly one supplier in three.

That page proves exactly one thing. The supplier owns letterhead. It does not prove what is in the bottle.

Here is the part I moved to the top, because it is the part that changed. A thin supplier file used to be a future audit problem. It now carries two live prices.

The first is a fee. Under PackUK's disposal fees modulation policy, red rated household packaging pays 1.2 times the amber base fee in assessment year 2026 to 2027, 1.6 times in 2027 to 2028, and 2.0 times in 2028 to 2029. Ratings under the Recyclability Assessment Methodology are self reported by producers, and the environmental regulators check that those self reported ratings are accurate. So the file behind the rating is what you are actually defending. Not the rating.

The second price is larger, and almost nobody in packaging is budgeting for it. I will come to it in a moment, because a regulator has already written it down.

The sourcing manager who owned that supplier relationship told me his file was healthy because it was full. Full and usable are different tests. Most packaging teams have only ever run the first one.

The regulator has already described your supplier file

This is normally the point where a compliance article starts guessing. This one does not have to.

On 22 January 2026 the Competition and Markets Authority published guidance on how UK consumer law applies to environmental claims across a supply chain. It carries five worked examples. The first one is almost exactly the situation I opened with.

A retailer sells its own brand products. It claims they are made from recycled polyester. The basis for the claim is a statement from a fabric supplier describing the material as greener because it is recycled, with no certification attached. The retailer has no policy for making environmental claims about its own brand products, and no process for verifying them.

The CMA's read on that scenario: the business that made the claim is the more likely enforcement target, not the supplier who wrote the loose statement.

Sit with that for a second. The supplier writes the weak document. The brand carries the exposure.

Intent does not rescue you either. The guidance states that where the CMA pursues civil enforcement, an "innocent" or unwitting breach is still a breach of the law, and that taking all reasonable precautions is not a defence. Genuine compliance effort can reduce a penalty. It does not remove the liability.

The penalty side moved as well. Under the Digital Markets, Competition and Consumers Act 2024, in force since April 2025, the CMA can decide that consumer law has been infringed and fine a business directly, without going to court.

Sarah Cardell, Chief Executive of the CMA, put the underlying concern plainly when the regulator opened its work on consumer goods claims. Shoppers, she said, are worried about products that are not what they seem:

So: a fee multiplier under packaging EPR, and a consumer law exposure that scales with your revenue. Both of them resting on a one page PDF that somebody in procurement filed two years ago and never opened again.

What that certificate actually proves

Read it again with a buyer's eye and the holes stack up fast.

• No part number. The "range" covers nine different bottles.
• No resin grade.
• No production site, and this supplier runs three.
• "Up to" 30 percent, which is a ceiling wearing the costume of a number.
• An issue date that predates the current resin contract, so it may describe material the company stopped receiving a year ago.

Now the test that matters. Could you hand this to HMRC examining a recycled content position under the Plastic Packaging Tax? No. To a producer responsibility organization validating a fee discount? No. To a retailer auditing the claim printed on the pack? Also no.

As marketing collateral it is fine. That is what it was written to be.

Suppliers are not hiding anything

This is the part buyers get wrong, and it costs them the relationship before it costs them the evidence.

Nobody sends a range statement in bad faith. A supplier answering a questionnaire reaches for the most reusable document in the drawer. A portfolio level statement costs nothing to attach. A component level declaration costs engineering time, a sign off from a named technical role, and somebody willing to put their name against a number.

Ask for the cheap document and you get the cheap document. Every time.

Then the gap sits quietly for years. It surfaces on the day the claim meets somebody whose job is to check it, by which point the buyer who filed it has moved to another category and the certificate has expired.

The CMA guidance is fair about this too. It accepts that the information needed to verify a claim often sits with a different business, and that getting hold of it can be genuinely difficult. Its answer is not sympathy. If you cannot obtain what you need to satisfy yourself the claim is accurate, make the claim differently, in a way you can actually verify. And if the supplier will not or cannot verify it, the guidance suggests you reconsider the trading relationship for that product.

Score the document, not the supplier

This is the change that made the difference for the teams I work with. Stop debating whether a supplier is trustworthy. Grade the paper against four factors and let the score carry the conversation.

Rate each factor strong, adequate or weak. Then one rule keeps the meetings short. A document weak on two or more factors supports no claim, no fee input and no report. It goes on the supplier's corrective list and everybody moves on.

Nobody has to argue about honesty. The document failed a stated test.

Three grades cover almost everything that crosses my desk. Usable is third party certification of the specific resin grade, from the named site, covering the supply period. Or a signed declaration from a named technical role, at part number level, in date. Conditional is a signed part number declaration with no stated expiry, or site level linkage with no batch reference. It holds an internal record together and nothing else. Unusable is the document in the blockquote above.

One reason to write the scoring down rather than carry it in your head: the CMA treats the absence of internal processes for verifying claims as an aggravating feature when it decides where to aim enforcement. A documented scoring rule is that process. It is also the cheapest one you will ever build.

So what does a better request look like?

Vague requests produce brochures. The second request for that shampoo bottle ran four lines.

Component 40218, bottle, HDPE. Please provide: the resin grade and PCR percentage, split into post consumer and post industrial; the certificate or chain of custody documentation for that grade from the named production site; an issue date within the current contract period; and a named technical contact accountable for the data.

Eleven days and one escalation later, it landed. It was also the first document in that file capable of surviving an audit.

Notice what those four lines do. They name a component, not a product. They ask for the split, because post consumer and post industrial are not the same number once that figure travels into an EU or US state filing. They pin the site. They put a human name on the answer.

This is where a structured record starts paying for itself. In Packgine's Packaging Specification Hub, the certificate attaches to the specification it supports instead of to a thread in somebody's inbox. Spec records are shared with packaging suppliers for verified data submission, and every change is versioned, timestamped and attributed, so an updated declaration supersedes the old one rather than living beside it in a shared drive. Those same fields then feed the RAM assessment and the fee model. The evidence and the number stop being two separate projects.

RAM 2027 just widened the ask

If your supplier request template is more than a few months old, it is already short.

PackUK published RAM 2027 on 1 July 2026. Producers keep using RAM version 1.1 to assess packaging supplied during 2026, and RAM 2027 applies to packaging supplied from 1 January 2027. The new version adds automatic red criteria, including packaging that contains substances of concern above the limits permitted under UK REACH, POPs and biocides rules.

Read that as a data request, because that is what it is. To rate a component under RAM 2027 you need composition detail on coatings, inks, adhesives, electrical components and restricted substances. Almost none of that sits in your ERP. All of it sits with the supplier who made the part.

The RAM 2027 overview also does something quietly useful. It tells producers to weigh their RAM ratings against the CMA's Green Claims Code when they make packaging decisions. Two regulators, one file. If you needed a signal that the fee question and the claims question have merged, that is it.

Teams that put the wider data request into the 2027 contract round will have what they need. Teams that ask during the reporting window will be rating components red because they cannot evidence anything better.

Put it in the contract, or lose it at renewal

Evidence collected on goodwill lapses on goodwill. Four clauses turn it into a performance obligation, and the moment to raise them is onboarding or renewal, never mid crisis. These are not my invention. Each one maps to something the CMA now expects businesses to have arrangements for.

• Data provision. The agreed documentation set per component, before first delivery.
• Change notification. No change to material, grade, recycled content, coating or site without notice. This is also the clause that protects your filing when a supplier quietly lightweights a bottle.
• Renewal. Time limited documents reissued before expiry, without being chased.
• Audit support. Cooperation with regulator or tax authority requests inside a defined response window.

The CMA checklist adds two habits worth copying into your own process. Run random checks on a sample of claims and ask for the evidence behind them rather than waiting for a challenge. And apply extra scrutiny when you change supplier, because a new source can quietly invalidate a claim that was accurate under the old one.

When a supplier stalls, escalate in steps. A dated reminder. A formal notice citing the clause. Then consequences sized to your exposure, scorecard impact and withheld new business among them.

At the end of that ladder sits the step most companies will not write down. If the evidence is not there, the claim and any fee input relying on it are suspended until it arrives. A supplier who cannot evidence a claim is asking you to carry its risk. You are allowed to decline.

What buyers ask me most

What documents should a packaging supplier provide?

At minimum: a component level composition declaration, weight and site data, recycled content evidence with chain of custody where content is claimed, safety declarations appropriate to the market, and identification of coatings, adhesives and inks. The exact set flexes by category and by market. The part number specificity never does.

Is a supplier declaration enough, or do I need third party certification?

It depends who reads it. Some authorities accept a signed declaration backed by records. Others weight independent certification heavily. The CMA accepts that a supplier declaration confirming the evidence is held can work where a certificate is not available for every product, which tells you the declaration must be specific and signed by somebody accountable, not a marketing statement. Score the document on source, specificity, currency and traceability, then check what that authority expects for that claim.

How often should supplier documents be refreshed?

Two triggers. The document's own expiry or review date, and any notified change to material, grade, site or process. A document with no stated validity gets an internal review date. It never gets permanent status.

Who is liable if a supplier's document turns out to be wrong?

The producer whose name is on the pack, in the first instance. The CMA has been explicit that more than one business in a chain can be liable, and that it will weigh who made the claim and who is best placed to fix it. Suppliers hold the evidence. The brand owner holds the obligation. That asymmetry is the entire reason this article exists.

Does any of this matter if I only sell in the US?

The mechanics change, the logic does not. The Federal Trade Commission's Green Guides require competent and reliable evidence behind recycled content claims, and US state packaging EPR programs increasingly ask producers to support the material data they file. A range statement with no part number fails both tests for the same reason it fails in the UK.

Ask one question at your next supplier review

If an auditor asked for the evidence behind this component's claim tomorrow morning, would the file answer, and whose signature is on the answer?

Suppliers who can meet that question keep the business. The rest get a corrective list and a date.

Send us one live component. We will score what your supplier returns against the four factors, and you will find out in an afternoon whether your file is full or usable. Book a working session, or check your obligation status first with the EPR checker.

Sources

• Competition and Markets Authority, Making green claims: Getting it right, across the supply chain, 22 January 2026: https://www.gov.uk/government/publications/making-green-claims-getting-it-right-across-the-supply-chain/making-green-claims-getting-it-right-across-the-supply-chain
• Competition and Markets Authority, Green Claims Code: making environmental claims: https://www.gov.uk/government/publications/green-claims-code-making-environmental-claims
• PackUK, Extended Producer Responsibility for packaging: producer disposal fees modulation statement: https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-modulated-disposal-fees/packuk-extended-producer-responsibility-epr-for-packaging-producer-disposal-fees-modulation-statement
• PackUK publishes Recyclability Assessment Methodology (RAM) 2027, 1 July 2026: https://www.gov.uk/government/news/packuk-publishes-recyclability-assessment-methodology-ram-2027
• Assess packaging recyclability: recyclability assessment methodology (RAM) 2027 overview: https://www.gov.uk/government/publications/assess-packaging-recyclability-recyclability-assessment-methodology-ram-2027/ram-2027-overview
• HMRC, Plastic Packaging Tax: check if you need to register: https://www.gov.uk/guidance/check-if-you-need-to-register-for-plastic-packaging-tax
• Federal Trade Commission, Guides for the Use of Environmental Marketing Claims, 16 CFR Part 260

Images licensed via Adobe Stock.

About the author

Kevin Kai Wong, Managing Partner at gCurv Technologies. He works with consumer brands and importers on packaging compliance data, covering US state EPR reporting, UK pEPR and EU PPWR conformity evidence.