DoC (Packaging)
What is a Declaration of Conformity for Packaging?
A Declaration of Conformity (DoC) for packaging is a formal document in which a producer or manufacturer confirms that packaging placed on the EU market meets the essential requirements set out in applicable packaging legislation, including PPWR. It functions similarly to declarations of conformity used under other EU product frameworks, providing a documented, traceable statement that the packaging has been assessed against the relevant legal requirements.
Why It Matters
A packaging DoC is one of the key pieces of evidence regulators and business partners look for when verifying that packaging placed on the EU market is compliant. Businesses that cannot produce a valid DoC when requested may struggle to demonstrate compliance, even if the packaging itself would otherwise meet requirements.
For importers and distributors sourcing packaged goods from third-country manufacturers, requesting and reviewing the packaging DoC is a practical way to verify that packaging obligations have been addressed before the product reaches the EU market.
Where enforcement authorities investigate non-compliant packaging, the absence of a proper DoC can be treated as an indicator that due diligence was not carried out, which can expose importers and distributors to liability alongside the manufacturer.
Key Requirements
Who Is Required to Hold or Request a Packaging DoC?
Packaging DoC obligations and expectations apply across the supply chain, including:
- Manufacturers and producers, who are generally responsible for drawing up the DoC
- Importers, who must ensure a conformity assessment has been carried out and should request and retain a copy of the DoC before placing packaged products on the EU market
- Distributors, who should confirm a DoC exists where compliance concerns arise
- Responsible Persons or Authorised Representatives, where appointed to support market access
This is relevant wherever packaging is subject to essential requirements, including:
Consumer packaging for retail products
E-commerce and shipping packaging
Food and beverage packaging
Industrial and transport packaging
Responsibilities Relating to the Packaging DoC
Businesses involved in placing packaging on the EU market are generally expected to:
- Confirm that a DoC has been drawn up by the manufacturer before sourcing packaging or packaged products
- Review the DoC to ensure it references the correct packaging category and applicable requirements
- Retain a copy of the DoC alongside other supply chain compliance records, for five years generally or ten years for reusable packaging
- Request an updated DoC where packaging design, materials, or specifications change
- Make the DoC available to enforcement authorities or business partners on request
The Packaging DoC and Technical Documentation
The DoC for packaging is typically supported by underlying technical documentation, such as material specifications, recyclability assessments, and test results, which substantiate the claims made in the declaration and must generally be retained for five years (ten years for reusable packaging). Importers and distributors should understand that the DoC itself is a summary statement, and requesting sight of the supporting documentation provides a stronger basis for verifying compliance.
Packaging Compliance Under PPWR
Selling packaged products in the EU? Every unit now falls under the Packaging and Packaging Waste Regulation (EU) 2025/40. Euverify handles your Declaration of Conformity, technical file, and compliance documentation as part of your plan, no expertise required on your end.
Related Terms
