PPWR Declaration of Conformity: What You Must Prepare

Quick answer: Since 12 August 2026, packaging placed on the EU market under the PPWR must be covered by a Declaration of Conformity (DoC) — a signed statement, backed by technical documentation, confirming your packaging meets the regulation's requirements. As the manufacturer — meaning whoever places the packaging on the EU market under their own name or trademark — you draw it up and take responsibility for it, and you must be able to produce it and the supporting file on request. This is new for packaging and is separate from the CE Declaration of Conformity. It's one of five obligations introduced by the PPWR — see PPWR Explained for Non-EU Manufacturers for the full picture.

Key takeaways

• A PPWR Declaration of Conformity has been required since 12 August 2026 for packaging on the EU market.
• The manufacturer (or its Authorised Representative) signs and is responsible for it.
• The DoC is backed by a technical file — material, recyclability, recycled-content and substance evidence.
• One DoC covers a defined packaging type, not every SKU.
• The PPWR DoC is separate from the CE product Declaration of Conformity — you may need both.

Are you the manufacturer or the producer?

PPWR uses two roles that are easy to confuse. The manufacturer is whoever places packaging on the EU market under their own name or trademark — this role carries the conformity assessment, technical documentation and DoC obligations (Articles 15 and 39). The producer is the role that carries Extended Producer Responsibility — national registration, fee payment and volume reporting. They are often the same company, but not always: if you put your brand on a supplier's packaging, you become the manufacturer even though you didn't make it (Article 21). Note that each role has its own type of Authorised Representative — an EPR representative does not sign your DoC.

Why start on the Declaration of Conformity first?

Because it depends on evidence you have to gather, not just a form to sign. Assembling material composition, recyclability assessments, recycled-content data and substance checks from your suppliers takes time. Leave it to the week before the deadline and you'll be signing a declaration you can't back up.

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

What must the PPWR Declaration of Conformity contain?

The DoC is set out in Article 39 of Regulation (EU) 2025/40, and its required structure is in Annex VIII.

While the detail sits in the regulation's annexes, a PPWR DoC broadly identifies:

• The packaging — type, materials, and the product it's used for.
• The responsible producer — you, or your Authorised Representative.
• The requirements met — recyclability, recycled content, substance limits, minimisation, labelling, as applicable.
• A statement of conformity — with place and date of issue and an authorised signature.

One declaration covers a defined packaging type; you don't need a fresh DoC for every SKU, but it must accurately reflect each packaging design you place on the market.

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What technical documentation sits behind the DoC?

The technical documentation is defined in Annex VII. The conformity assessment follows Article 38, Module A (internal production control) — you assess conformity in-house and no notified body is involved.

The DoC is the cover sheet; a technical file must substantiate every claim. That file typically includes material specifications, a recyclability assessment, recycled-content evidence, and records showing substance restrictions (such as the PFAS limits on food-contact packaging) are met. Authorities can request this file, so "sign now, evidence later" is not a strategy.

EcoComply's platform assembles ~80% of the technical file automatically and our compliance managers finish the rest — the same way we handle CE technical documentation. See how it works →

PPWR DoC vs CE Declaration of Conformity: what's the difference?

PPWR deliberately does not use CE marking for packaging — a CE mark on packaging could be confused with product-level CE marking. Packaging conformity is shown only through the DoC and its technical file.

They are separate documents. The CE Declaration of Conformity covers your product against EU product directives (like the EMC Directive or RoHS); the PPWR DoC covers your packaging. They have different scope and different evidence, and you may need both for the same shipment. For the product-side declaration, see our Declaration of Conformity Guide; this article is strictly about packaging under the PPWR.

Your PPWR DoC checklist

1. Inventory every packaging design you place on the EU market.
2. Gather evidence from suppliers: materials, recyclability, recycled content, substance data.
3. Assess each design against the applicable PPWR requirements.
4. Compile the technical documentation file per packaging type.
5. Draft and sign the Declaration of Conformity (you or your AR).
6. Store and be ready to produce the DoC and file on request — keep both for 5 years after the last unit is placed on the market, or 10 years for reusable packaging.

Get your PPWR documentation ready

The declaration is quick to sign; the evidence behind it is not. The sooner your technical file is in place, the lower the risk you carry now that PPWR is in force. We can build it for you.

Book a free assessment →

Always check the current PPWR text on EUR-Lex for the precise DoC and documentation requirements. Last updated July 2026.