Thank you for your reply. We buy Nylon, Polyethylene, Polyester, Polypropylene. Some of them are multi layer materials. I mean made of 20% of LDPE and 80% of something else etc but the material we buy is plastic materials wounded on the reels and our processes is printing inks, laminating a few layers together.
Our Technical director's opinion is that the Regulation 10/2011 does not obliged our Suppliers to give us their Test Results. I have a different opinion.
I don't think this is a matter of opinion. I would advise you to discuss this with your technical director. Your supplier (who is a converter) has to give you the information that the films comply with migration limits.
Let me paste the text here from 10/2011:
Declaration of compliance
At the marketing stages other than at the retail stage, a written declaration in accordance with Article 16 of Regulation (EC)No 1935/2004 shall be available for plastic materials and articles,products from intermediate stages of their manufacturing as well as for the substances intended for the manufacturing of those materials and articles.
The written declaration referred to in paragraph 1 shall be issued by the business operator and shall contain the information laid down in Annex IV.
And if we look at Annex IV;
adequate information relative to the substances used or products of degradation thereof for which restrictions and/or specifications are set out in Annexes I and II to this Regulation to allow the downstream business operators to ensure compliance with those restrictions;
adequate information relative to the substances which are subject to a restriction in food, obtained by experimental data or theoretical calculation about the level of their specific migration and, where appropriate, purity criteria in accordance with Directives 2008/60/EC, 95/45/EC and 2008/84/EC to enable the user of these materials or articles to comply with the relevant EU provisions or, in their absence, with national provisions applicable to food;
English is not my native language but I think it is perfectly clear that information on restricted materials (migration of these materials) has to flow downstream.
By the way since you modify the films you buy, you also have to make your own migration tests and declare them in DoC to the next in line (which is the food manufacturer). Your company is subject to same rules as your supplier.