The documents EU buyers ask for with tapes and films in 2027

When two families in India arrange a marriage, a file goes back and forth before anyone says yes. Kundli, photos, the job letter, sometimes a property paper. A file for a roll of tape going to an EU buyer is starting to look the same.

In 2027, expect requests in five groups. First comes data for the declaration of conformity that your EU customer signs under the EU packaging law. Then come statements on chemicals, evidence against forced labour before 14 December 2027, origin papers for customs, and deforestation data if the tape is paper.

Most of it can come from the records of your supplier. You only have to ask for the right thing.

Checked against official sources on 28 October 2026.

We make tapes and films in Jaipur and export to 20+ countries. I wrote this guide to list what each request means, which law sits behind it and what to ask your tape or film supplier for, whether that is us or someone else.

I am not a lawyer. Confirm the legal points with your customer or adviser.

Who signs what under the EU packaging law

The EU Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, has applied since 12 August 2026. Before packaging is placed on the EU market, the "manufacturer" must assess conformity, keep technical documentation (Annex VII) and sign an EU declaration of conformity (Annex VIII). That is Article 15(2).

The Commission guidance, Commission Notice C/2026/3084 of 10 June 2026, explains who that manufacturer is. For sales and grouped packaging it is normally the filler, who is often the brand owner. For transport packaging it is normally the maker, unless the name or trademark of the user is on it.

In the words of the Regulation, a tape maker is a "supplier". Article 16(1) says suppliers must give the manufacturer all the information and documentation needed to show conformity, in a language the manufacturer understands, on paper or electronically.

So the declaration is not ours to sign.

We give the facts it rests on.

One exception matters for distributors. Under Article 21, an importer or distributor that places packaging on the market under its own name or trademark is treated as the manufacturer. If you import our tape and sell it under your brand, the declaration for that tape is yours to sign.

The data a declaration needs from a tape supplier

Annex VII asks for a description of the packaging and its use, the materials of its components, the standards applied, how recyclability and other assessments were done, and test reports. For a roll of tape, that translates into this:

The heavy metals limit is the oldest rule in this list. Article 5(4) says the four metals together may not exceed 100 mg/kg in packaging or packaging components. I would start any check with printed and coloured tapes, because colour comes from pigments.

Traceability gets sharper under the new law. Article 15(5) asks the manufacturer to put a type, batch or serial number on the packaging. Your customer will want to link each box back to a batch of tape. The Indian standard for plastic-backed tapes, IS 13262:1992, already asks makers to mark month of manufacture and batch, so this should be easy for any serious supplier.

For the recyclability side, the guide on tape and carton recyclability explains what is known and what is not.

Chemicals: REACH, the Candidate List and PFAS

A roll of tape is an "article" under the EU chemicals law, REACH (Regulation (EC) No 1907/2006). Article 33 says a supplier of an article containing a Candidate List substance above 0.1% by weight must pass on enough information for safe use, at least the name of the substance.

So EU buyers ask for an "SVHC statement". I check three things on any such statement, ours included:

1. It names the exact product, not "all our products".
2. It says clearly whether any substance from the ECHA Candidate List is present above 0.1% by weight.
3. It gives the date of the Candidate List version it was checked against. ECHA adds substances to the list from time to time, so an old statement goes stale.

For PVC tapes, such as some floor-marking and electrical tapes, ask one more question. REACH Annex XVII, entry 51, restricts four phthalate plasticisers (DEHP, DBP, BBP and DIBP) at 0.1% or more in plasticised material in articles. Phthalates are a PVC question, so ask it for the PVC range.

PFAS is the third chemical question. Under the PPWR, the limits in Article 5(5) apply to food-contact packaging only. The guide on PFAS in adhesive tapes covers where fluorochemistry can hide in a tape and what declaration to ask for.

Forced labour: the 14 December 2027 date

From 14 December 2027, products made wholly or partly with forced labour may not be placed on the EU market, made available on it or exported from it. The law is Regulation (EU) 2024/3015. It covers all products and all countries, packaging included.

The Commission guidelines, published in the Official Journal as C/2026/4637 on 3 September 2026, make two points worth knowing. The ban applies to products on the market from that date even if they were made or imported earlier. And the Regulation itself does not impose a due diligence duty, but documented evidence helps a company show its products are clean.

The guidelines list the kind of evidence an authority may look at. It includes product identification (HS code, batch number), raw-material traceability, bills of materials, certificates of origin, supplier onboarding records, grievance mechanisms and independent audit reports.

Expect your EU customer to send a questionnaire in 2027 built from that list.

For an Indian factory, much of the answer already sits in papers that Indian law asks for. The Occupational Safety, Health and Working Conditions Code, in force since 21 November 2025, requires an appointment letter for every employee, as the Government of India's backgrounder of 22 November 2025 explains. Wage records, appointment letters and a list of raw-material suppliers answer a large part of any forced labour questionnaire. We keep all three, and I would expect any tape maker you buy from to keep them too.

Origin and tariff papers

Customs needs the right code and, if a preference is claimed, proof of origin.

1. Self-adhesive plastic tapes and films are classified under heading 3919. Paper tapes fall in Chapter 48. Agree the full 8-digit code with the customs broker your customer uses, before the first shipment. Keep it the same on every invoice.
2. India has no EU GSP tariff preference on "plastics and articles thereof" (section S-7a) for 2026 to 2028, under Commission Implementing Regulation (EU) 2025/1909. The same section was suspended for 2023 to 2025 too, so this is not new. A plastic tape from India pays the full EU duty in 2026. Paper (section S-10) is not in the suspended list for India.
3. A new GSP regulation, Regulation (EU) 2026/1395, replaces the old one from 1 January 2027, and a fresh list of suspended sections applies from that date. Whether that list keeps Indian plastics suspended had not been confirmed on 28 October 2026.
4. Where a GSP preference is claimed, the exporter makes out a statement on origin. Above EUR 6,000 per consignment, the exporter must be registered in the REX system of the EU, as the Access2Markets page on REX explains.
5. The EU and India concluded a free trade agreement in January 2026, as the European External Action Service announced on 28 January 2026. It is not in force yet, so no FTA preference can be claimed today.

Paper tapes and the deforestation regulation

This applies to paper tape only. The EU Deforestation Regulation covers paper and paperboard of Chapter 48 from 30 December 2026. Commission Delegated Regulation (EU) 2026/2102 (Official Journal, 17 September 2026) sets the scope.

Paper sold as a product in its own right, such as rolls of kraft paper tape, is in scope. Packing material used only to support, protect or carry another product is out. Products made from recovered paper are also excluded.

India is classed as a low-risk country. The importer can use simplified due diligence but must still collect the information the law asks for, including the geolocation of the forest plots the fibre came from. That data starts at the paper mill, so a tape maker has to get it from its paper supplier. Ask early. I would not leave it to the month before a shipment.

What to ask for, in one list

If you sell tape or film into the EU, or pack goods for an EU customer, these are the requests I would send to any supplier in early 2027:

1. A product data sheet with backing, adhesive, core and weights per roll.
2. A heavy-metals test report for printed or coloured tapes.
3. A REACH Article 33 statement, dated against a named Candidate List version.
4. A PFAS declaration if any tape touches food.
5. Batch numbers on every carton.
6. The HS code, and the origin basis if a preference is claimed.
7. Answers for the forced labour questionnaire from your EU customer.
8. For paper tape sold as a product, the EUDR information chain from the mill.

One honest limit from our side. Some of these we can give from our own records the day you ask. Others, such as a heavy-metals test, depend on whether that test has been done for your exact product. I will not send you a report for a different product and call it yours.

If you buy tape or film from us for Europe, write to us through the contact page. Send the product name, the invoice or batch number and the list your EU customer gave you. We will tell you what we can send now, and what will take time.