PPWR Declaration of Conformity: Requirements & Examples

Quick answer: A PPWR EU Declaration of Conformity is the manufacturer’s formal statement that a packaging type meets the applicable requirements of Regulation (EU) 2025/40. For packaging placed on the EU market from 12 August 2026, the manufacturer must complete the applicable conformity assessment, prepare the Annex VII technical documentation, and draw up the declaration using the Annex VIII model. An Authorised Representative may perform specified tasks under a written mandate, but responsibility for conformity remains with the manufacturer.

Free downloadable resource: Get the PPWR Declaration of Conformity template and evidence pack: an editable Annex VIII model, fictional completed example, supplier evidence checklist and change-review checklist.

Key takeaways

• A PPWR Declaration of Conformity has been required since 12 August 2026 for packaging placed on the EU market.
• The manufacturer draws up the DoC and retains sole responsibility for conformity. An Authorised Representative may perform tasks permitted by its written mandate, but the manufacturer’s responsibility does not transfer.
• The DoC is backed by Annex VII technical documentation covering the conformity-relevant evidence for the packaging type.
• One DoC covers a defined packaging type, not automatically every SKU.
• PPWR packaging conformity and product CE conformity have different scopes. Article 39(3) permits combined declarations where appropriate.

Who must issue and sign the PPWR Declaration of Conformity?

The manufacturer issues the DoC and assumes responsibility for packaging conformity. The EPR producer is a separate role responsible for national registration and waste-management obligations. Establish these roles separately; one company may hold both.

Specific exception: Article 15(11) exempts custom-made transport packaging for configurable medical devices and medical systems used in industrial and healthcare environments from Article 15(2) and (3). Check the actual scope before applying the general DoC rule.

Do I create the PPWR DoC or collect it from my supplier?

Start with your legal role for the packaging concerned. The manufacturer issues the declaration after demonstrating conformity. An importer normally verifies the manufacturer's assessment, keeps a copy of the DoC and ensures that the technical documentation can be made available. A supplier provides the evidence needed by the manufacturer. Buying packaging or receiving a supplier declaration does not, by itself, settle which role your company holds.

How to identify the manufacturer

1. Identify the packaging and packaged product. Record who manufactures them and who has them designed or manufactured under its name or trademark. Article 3(13) covers both packaging and packaged products; the physical packaging converter is not automatically the responsible manufacturer in every supply chain.
2. Check own-brand and modification arrangements. Under Article 21, an importer or distributor takes on manufacturer obligations if it places packaging under its own name or trademark, or modifies packaging already placed on the market in a way that may affect conformity.
3. Check the micro-enterprise provisions before allocating responsibility. Article 3(13)(b) addresses a supplier in the same Member State. Article 15(12) separately treats an EU-established supplier as the manufacturer for Article 15 where the specified micro-enterprise conditions are met. Article 21 includes a related exception. Do not apply the same-country test as the only rule.
4. Document the conclusion. Keep the relevant supply agreement, specifications, branding arrangements and reasoning in the file. Allocate responsibilities per packaging type rather than assuming one answer covers every component and sales route.

Legal basis: Articles 3(13), 15, 16, 18 and 21 of Regulation (EU) 2025/40.

Can I use my packaging supplier's declaration?

Yes, as the relevant manufacturer's declaration or as supporting evidence, depending on the roles and scope. Check who issued it, which packaging type and version it covers, and whether it addresses the packaging in its final intended use. If your company is the manufacturer, a declaration for a purchased component does not automatically discharge your obligations for the packaging you place on the market. Obtain the missing evidence and complete your assessment before signing.

Under Article 16, suppliers must provide the information and documentation manufacturers need to demonstrate conformity. An EPR registration number, a generic material specification or a statement saying “PPWR compliant” is not a substitute for the required assessment and declaration.

Can an authorised representative take over the manufacturer's obligations?

The manufacturer retains responsibility. Article 17 permits specified tasks under a written mandate, including keeping documents available and cooperating with authorities. It expressly excludes the Article 15(1) conformity obligation and the specified obligation to draw up technical documentation from the AR mandate. Technical preparation support must be distinguished from transferring those legal obligations. An appointment for EPR representation alone does not authorise PPWR conformity tasks.

Why must the supporting evidence come before the declaration?

Complete the assessment and gather the evidence for applicable requirements before signing. A template records a conformity conclusion; it cannot create the evidence supporting that conclusion.

Not sure what evidence your DoC needs? We build the technical file and draft the declaration for you. Book a free call →

What must the PPWR Declaration of Conformity contain?

Article 39 requires the Annex VIII model. The following field guide explains how to complete it; the numbered fields and signature block must be considered together.

1. Packaging identifier

What to enter: A unique packaging identifier linked to the approved specification and technical file.

Avoid: Using a product SKU without identifying its packaging.

2. Manufacturer and AR

What to enter: The legal manufacturer's name and address; the manufacturer's AR where applicable. Check entity records and the mandate.

Avoid: Automatically naming the converter or EPR representative.

3. Responsibility statement

What to enter: The Annex VIII statement that the declaration is issued under the manufacturer's sole responsibility.

Avoid: Transferring responsibility to the test laboratory or supplier.

4. Object of the declaration

What to enter: A traceable packaging description. Use drawings, component specifications and version references to define its scope.

Avoid: A blanket description such as “all our packaging”.

5. Union legislation

What to enter: Identify Regulation (EU) 2025/40 and other Union acts covered by the declaration where relevant. Base this on the applicability assessment.

Avoid: Copying unrelated legislation from a CE template.

6. Standards and specifications

What to enter: Identify the harmonised standards, common specifications or other technical specifications actually used. Keep versions and scope consistent with the file.

Avoid: Listing a standard that was never applied.

7. Notified body, if applicable

What to enter: Where relevant, body identity, intervention and certificate details. PPWR Module A does not ordinarily require a notified body.

Avoid: Inventing a certificate or treating a testing lab as a notified body.

8. Additional information

What to enter: Relevant supplementary details, such as a controlled list of covered variants or file references.

Avoid: Using this field to disguise missing evidence.

Signature block

What to enter: The entity on whose behalf it is signed, place, date, signatory name, function and signature.

Avoid: An unsigned document or an unexplained signatory.

DoC number versus EPR number: Annex VIII includes an identification number for the declaration and a unique packaging identifier. Manage these through document control; they are not an EU-wide packaging EPR registration number. National producer registration is a separate process.

Source: Article 39 and Annex VIII.

How many PPWR Declarations of Conformity do I need?

The PPWR requires a written DoC for each packaging type. Multiple product SKUs can rely on the same DoC only where they genuinely use the same packaging type and the conformity-relevant characteristics covered by the declaration remain unchanged.

Can several sizes or SKUs share a declaration?

A product count is not a declaration count. Use a controlled mapping from product SKU to packaging specification, version and DoC. Several SKUs using the same assessed packaging type can point to the same declaration. Different sizes, materials, coatings, adhesives or intended uses require a documented assessment of whether the existing scope and evidence still cover them. Do not group variants solely because they look similar.

Primary, secondary and transport packaging: identify the packaging types and responsible manufacturer for each level. A declaration for a retail box does not automatically cover the shipping carton, protective insert or pallet wrap. Where documentation is grouped, each covered type and its evidence must remain identifiable. These mapping practices implement the packaging-type requirement in Annex VII; they are not a separate statutory SKU rule.

When must I update or reassess a PPWR declaration?

Review changes that could affect conformity. Article 15(4) requires reassessment where conformity could be affected, and Article 39(2) requires the declaration to be kept up to date. A new product SKU alone is not an automatic trigger for new testing.

• Material, coating, ink or adhesive change: obtain revised composition and substance evidence; reassess affected requirements.
• Size, weight, structure or intended-use change: check whether the existing packaging-type scope and assessment remain valid.
• Supplier or manufacturing-process change: verify equivalence and production controls; do not assume old reports cover the replacement.
• New applicable requirement or specification: review the assessment at the relevant application date and update the declaration as needed.
• New non-conformity evidence: investigate, reassess and take corrective action where required.

As a document-control practice, retain the previous version, record the reason for change and approval, and link the revised declaration to the affected production batches. A review can conclude that no new DoC is needed, but the reasoning should be recorded.

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What technical documentation supports the PPWR DoC?

The technical documentation is defined in Annex VII. The conformity assessment follows Article 38 and Annex VII, Module A (internal production control). Under the PPWR itself this procedure is manufacturer-led and does not ordinarily require a notified body; Annex VIII nevertheless includes a notified-body field where applicable.

The technical file must explain why the packaging complies, not merely store supplier PDFs. Annex VII calls for an analysis of non-conformity risks and documentation sufficient to assess design, manufacture and operation, as relevant.

• Description and intended use: packaging identifier, configuration, materials, components and use conditions.
• Design and manufacture: drawings, component material specifications and explanations needed to understand the packaging.
• Applicable requirements: identify the relevant provisions, their application dates and the evidence supporting each conclusion.
• Assessment methods: list standards and specifications used, any parts applied, and alternative solutions where relevant.
• Assessments and reports: include the relevant explanations for recyclability, minimisation and reusability assessments, and applicable test reports.
• Production controls: keep manufactured packaging consistent with the assessed design and evidence.

Evidence required now versus later: assess against requirements applicable to the packaging at the relevant placement date. The general application date does not make every future recycled-content, recyclability or labelling requirement immediately mandatory. Mark each requirement as applicable, not applicable with a reason, or future with its trigger date. Existing obligations continuing under transitional provisions also need to be considered.

What should I request from my packaging supplier?

• Identification: supplier legal entity, packaging reference, specification version, intended use and component list.
• Composition: material grades, component weights and relevant inks, adhesives, coatings and additives.
• Substance evidence: declarations and reports relevant to applicable restrictions; for food-contact packaging, evidence addressing the PPWR PFAS provisions and applicable food-contact rules.
• Supporting assessments: methods, calculations and test reports relevant to the requirements being assessed, with a clear link to the supplied material or type.
• Change notification: an agreed process for notifying material, supplier and manufacturing changes. This is a practical control supporting ongoing conformity.

Does every packaging type need new laboratory testing? Module A does not impose a universal third-party certification step. Determine what evidence the applicable requirement demands and whether existing reports are suitable for the exact materials and use. Testing may be necessary where evidence is missing or inadequate; neither a generic supplier assurance nor a blanket “no testing needed” statement is sufficient.

Source: Articles 15–16, 38–39 and Annex VII.

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Is a PPWR DoC the same as a CE Declaration of Conformity?

A CE Declaration of Conformity concerns the product obligations under relevant Union legislation; the PPWR declaration addresses packaging. PPWR does not introduce CE marking for packaging. A product CE declaration alone does not demonstrate packaging conformity.

Can they be combined? Article 39(3) provides for a single EU declaration covering multiple applicable Union acts where appropriate, including a dossier of relevant individual declarations. The scope and evidence for each act must remain clear. Separate documents can be easier to manage, but the law does not impose an absolute two-document rule. See our product Declaration of Conformity Guide.

How do I check whether a supplier DoC is usable?

Before accepting a declaration into your compliance file, check these six points:

1. Issuer: does the named entity hold the manufacturer role for the packaging concerned?
2. Scope: can the identifier and description be matched to the packaging supplied, including its version and use?
3. Completeness: are the Annex VIII fields and signature block addressed, with conditional fields treated appropriately?
4. Evidence: can the conformity conclusions be traced to a technical file and relevant supplier records?
5. Applicability: does the declaration address the right legislation and current obligations without treating future requirements as already mandatory?
6. Maintenance: is the version current, is the required language available, and is there a process to retrieve the evidence and assess changes?

A missing identifier, wrong responsible entity, unsupported claim or signature gap should be resolved before relying on the declaration. These are practical review checks, not an authority-issued approval or certification.

Which language and retention period apply?

Article 39(2) requires the declaration in the language or languages required by the Member State where packaging is placed or made available. Under Article 15(3), keep the DoC and technical documentation for five years from placement on the market for single-use packaging and ten years for reusable packaging. Article 18(7) requires importers to keep a DoC copy and ensure the technical documentation is available. Record placement dates and keep the evidence accessible, rather than relying on a supplier's temporary download link.

PPWR DoC examples: three business scenarios

These fictional examples apply the rules above to defined supply chains. They assume covered packaging is newly placed on the EU market after 12 August 2026 and that the businesses do not qualify for the micro-enterprise exceptions. The conclusions must be revisited if the contracting entities, packaging, branding or sales route change.

Example 1: US cosmetics brand selling through French and German importers

Situation: A US cosmetics company commissions packaging from an Italian converter under its own brand. The packaging is shipped to the US, filled there and supplied as finished cosmetics to separate French and German businesses. Each local business imports the products and sells them domestically to retailers. The US company does not sell directly to EU consumers in this example.

• Manufacturer and DoC: Under the assumed own-brand arrangement, the US company is the PPWR manufacturer for the branded packaging concerned. It completes the assessment and issues the DoC for each packaging type. The Italian converter supplies the supporting information; its component documentation does not automatically replace the brand's assessment.
• Evidence: Collect bottle or jar, closure, label and outer-box specifications, relevant substance evidence and information about the final packaging configuration and use. Identify transport packaging separately. Cosmetics packaging is not automatically food-contact packaging merely because it is contact-sensitive.
• Importer: Each EU importing business checks the manufacturer's compliance under Article 18, retains the DoC copy and ensures technical documentation can be made available. The cosmetics Responsible Person is a separate product-law role; that appointment alone does not settle PPWR duties.
• EPR producer: On these facts, the French and German businesses are the respective domestic first suppliers of the packaged cosmetics, making them the EPR producers for that sales packaging under Article 3(1)(15)(b). They must arrange the applicable local registration, scheme participation and reporting. Packaging unpacked before retail sale needs its own allocation.
• Representatives: A manufacturer AR under Article 17 has a different mandate from an EPR representative. This wholesale arrangement does not, by itself, make the US brand the direct-to-consumer EPR producer in both countries.

Next action: Agree a written responsibility map with each importer and obtain a supplier evidence pack linked to the specific packaging types before issuing the declarations.

Example 2: Electronics company with 300 SKUs and 15 packaging configurations

Situation: A German electronics company commissions its products and branded packaging, imports the finished goods from outside the EU and sells only within Germany. Its 300 product SKUs use 15 recorded packaging configurations.

• Manufacturer and importer: The German company holds the manufacturer role for the assumed own-brand packaging and also imports the goods. Its conformity assessment must cover the actual packaging it places on the market.
• Number of DoCs: Neither 300 nor 15 is automatically the correct answer. First establish the packaging types within the 15 configurations, including relevant retail and transport packaging. If the assessment establishes exactly 15 packaging types, a declaration for each of those 15 types can cover the linked product SKUs. A configuration containing several distinct types may require more.
• Evidence: Maintain a mapping from each SKU to the packaging type, specification version, DoC and evidence file. A changed insert, adhesive, material grade or intended use can require reassessment even when the carton dimensions stay the same.
• EPR producer: The company is the domestic first supplier of the imported packaged products on the assumed German route. Its packaging reporting follows the materials and quantities placed on that market, not the number of DoCs. Product WEEE or battery obligations require a separate assessment.
• Representatives: This domestic-only route does not trigger the cross-border EPR representative rule simply because there are many SKUs. Expansion to another country requires a fresh sales-route analysis.

Next action: Audit the 15 configurations and build the SKU-to-packaging-type register before choosing the declaration count. Reuse evidence where it is valid and traceable.

Example 3: Non-EU seller shipping directly to consumers in Germany, France and Italy

Situation: A US company commissions its own-brand products and packaging from a Chinese factory. It remains the seller of record and ships directly from outside the EU to consumers in Germany, France and Italy through its own store or marketplace listings. There is no EU distributor buying and reselling the goods.

• Manufacturer and DoC: Under this own-brand arrangement, the US company holds the manufacturer role for the packaging concerned. It obtains evidence from the factory and packaging suppliers, completes the assessment and issues the relevant DoCs. The delivery country does not, by itself, create a new packaging type, although language and other applicable requirements must be addressed.
• EPR producer: Direct first supply to end users in each destination brings the seller within the cross-border producer rules in Article 3(1)(15)(c) and (d), as applicable to the packaging. Assess and fulfil packaging EPR separately in Germany, France and Italy; one registration is not an EU-wide registration.
• EPR representatives: Article 45(3) governs cross-border appointments and includes a specific provision allowing Member States to require representatives for third-country producers. For this US seller, verify the operative national requirements and appointment process in each destination. Do not assume a single EU mandate satisfies all three markets.
• Importer: Identify whether an EU-established entity actually places the third-country packaging on the market and therefore meets Article 3(1)(17). Do not automatically label the consumer, customs broker, marketplace or fulfilment provider as the PPWR importer.
• Marketplace and evidence: A marketplace account or fulfilment contract does not automatically transfer the seller's obligations. Keep DoCs, supplier evidence, registration details and destination-level packaging data available. Platform-specific processes must be checked separately.

Next action: Prepare a country-by-country EPR action list alongside the packaging technical files. If an EU distributor starts buying and reselling the goods, reassess the role allocation for that route.

Legal basis for these examples: Regulation (EU) 2025/40, Article 3(1)(13), (15) and (17); Articles 15–18, 21, 39 and 45; and Annex VII. The examples illustrate role allocation and documentation; national registration mechanics and product-specific rules must be checked for the actual transaction.

PPWR Declaration of Conformity checklist

1. Inventory every packaging design you place on the EU market.
2. Gather evidence from suppliers: materials, recyclability, recycled content and substance data.
3. Assess each design against the applicable PPWR requirements.
4. Compile the Annex VII technical documentation for each packaging type.
5. Draw up the Annex VIII Declaration of Conformity as the manufacturer. If an Authorised Representative performs permitted tasks, ensure they are covered by the written mandate; the manufacturer retains responsibility.
6. Retain and provide the DoC and technical documentation on request: 5 years from placement on the market for single-use packaging and 10 years for reusable packaging.

Get your PPWR documentation ready

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Always check the current PPWR text on EUR-Lex for the precise DoC and documentation requirements. Last legally reviewed 13 September 2026.

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More packaging guidance: visit the PPWR resource hub for requirements, practical guides, templates and the relationship with packaging EPR.