The EU Declaration of Conformity for Packaging — What It Is, What Goes in It, and Who’s Responsible
If you sell products in the EU, you have likely come across the Declaration of Conformity. Under product safety legislation, it is the self-declaration that sits behind CE marking and confirms your product meets the relevant requirements.The EU’s Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, introduces a separate Declaration of Conformity for packaging. This is not an extension of your product DoC and is not linked to CE marking. It is a standalone obligation under a different regulatory framework, and it applies from 12 August 2026. Many brands only become aware of it when they are already close to the deadline.
Why the PPWR Changes How Packaging Compliance Works
The old Packaging and Packaging Waste Directive was primarily about what happens to packaging after it is used, including waste streams, recovery targets, and recycling infrastructure. Compliance lived at the back end of the product lifecycle.
The PPWR changes this approach. Compliance must now be established before packaging reaches the shelf. The regulation introduces requirements covering chemical restrictions, minimisation, recyclability, reuse, recycled content, and labelling. It also introduces a formal documentation obligation, a Declaration of Conformity supported by a technical file, to prove that packaging meets these requirements before it enters the EU market.
What Is the EU Declaration of Conformity for Packaging?
Under Article 39 of Regulation (EU) 2025/40, the manufacturer must draw up a written Declaration of Conformity confirming that the packaging meets the applicable requirements under Articles 5 to 12 of the PPWR. The DoC must follow the model structure set out in Annex VIII of the regulation.
It is a self-declaration and not a certificate issued by a third party. But it needs to be backed by a full technical file that evidences what is being declared. A declaration without that supporting evidence will not withstand scrutiny from market surveillance authorities.
Who Is the Manufacturer Under PPWR?
This is the most important concept to get right, and it is frequently misunderstood.
Under PPWR, the “manufacturer” is not necessarily the entity that physically produced the packaging. The manufacturer is defined as the entity whose brand or name appears on the packaging. If a packaging converter produces bottles and a brand puts its own name on them before placing them on the EU market, the brand is the manufacturer under PPWR — and the DoC obligation sits with that brand.
The European Commission’s own guidance is explicit: the manufacturer is the sole economic operator bearing legal responsibility for the packaging’s compliance with the sustainability and labelling requirements, regardless of who may have actually drafted the Declaration of Conformity or parts of it.
This matters enormously for how compliance responsibilities are allocated across the supply chain.
The Economic Operator Hierarchy Under PPWR
PPWR sets out distinct and different obligations depending on your role in the supply chain:
Manufacturer (Articles 5–12, 39, and Annex VIII): The entity whose brand or name is on the packaging. Responsible for drawing up the Declaration of Conformity, ensuring it follows the Annex VIII model, holding the technical file under Annex VII Module A, and retaining documentation for the required period.
Authorised Representative (Article 17): A legally established entity in the EU appointed by a non-EU manufacturer by written mandate. The Authorised Representative can draft the DoC on the manufacturer’s behalf and hold the technical file, but legal responsibility for the packaging’s compliance remains with the manufacturer at all times.
Importer (Article 18): Responsible for verifying that the manufacturer has drawn up the DoC and that it is available. Importers must keep a copy of the DoC and make it available to market surveillance authorities on request. Importers do not draw up their own DoC.
Distributor (Article 19): Responsible for verifying that the packaging bears the required labelling and that a DoC exists upstream in the supply chain.
Understanding which role you occupy determines what you are actually required to do. These are not interchangeable obligations.
What Does the Declaration of Conformity Need to Include?
Under Article 39 and Annex VIII, the DoC is required to include:
A clear description of the packaging. Material type, format, components, and intended use. This applies to each distinct packaging type placed on the market, not to your product range as a whole.
The identity of the manufacturer, or Authorised Representative. Name, registered address, and contact details of the entity legally responsible. For manufacturers based outside the EU, this will typically be the Article 17 Authorised Representative (see below).
The specific requirements being declared against. The DoC must reference which requirements under Articles 5 to 12 the packaging is declared to meet, and the conformity assessment procedure applied.
A reference to the supporting technical file. The DoC points to the evidence behind it. It is not a standalone document. A dated signature from the manufacturer or Authorised Representative. The declaration must be signed, dated, and retained for the applicable period: five years for single-use packaging, ten years for reusable packaging.
What Evidence Goes Into the Technical File?
The technical file is the documented evidence that makes the DoC credible. The PPWR conformity assessment follows Module A — internal production control, set out in Annex VII of the regulation. Under Module A, the manufacturer carries out the conformity assessment internally and holds the technical file without third-party involvement, unless implementing acts require otherwise.
For packaging entering the EU market from August 2026, the technical file will typically need to include:
- Supplier declarations confirming the absence of restricted substances
- Test reports where declarations alone are not sufficient
- Documentation evidencing compliance with the chemical concentration limits for PFAS (for food-contact packaging: ≤25 ppb for any individual PFAS, ≤250 ppb for the sum of targeted PFAS, and ≤50 ppm for all PFAS including polymeric PFAS) and heavy metals
- Technical drawings, material datasheets, and references to any harmonised standards applied
From 2030, when mandatory minimum recycled content targets apply to plastic packaging, the file will also need to include verified post-consumer recycled content percentages tracked through the supply chain. These targets are phased across packaging categories through to 2040, and the verification mechanism is subject to the relevant implementing acts.
One point that catches brands off guard: the obligation covers your full packaging system. Primary, secondary, and tertiary packaging must all be considered separately. If your primary packaging is clean but your secondary packaging contains a restricted substance, the non-compliance belongs to the manufacturer.
What Requirements Does the DoC Cover?
The Declaration of Conformity covers the full scope of Articles 5 to 12 of the PPWR. These include packaging minimisation (Article 5), reusability and refillability (Articles 6 to 9), recyclability (Article 10), recycled content (Article 11), labelling (Article 12), and specific provisions for innovative packaging.
These requirements come into effect at different stages, with chemical restrictions applying from August 2026 and recyclability criteria from 2030. All of these obligations fall within the scope of what the Declaration of Conformity framework is designed to cover.
What About Non-EU Manufacturers?
If you are a manufacturer based outside the EU, including the UK, US, Asia, or elsewhere, you cannot issue a PPWR Declaration of Conformity without a legally established entity within the EU acting on your behalf.
Under Article 17 of the PPWR, non-EU manufacturers can appoint an Authorised Representative by written mandate. The Authorised Representative is a defined legal role under the regulation — not an informal arrangement. With the right mandate in place, the AR can draft the DoC, hold the technical file, and be the named point of contact for market surveillance authorities.
Critically, appointing an AR does not transfer legal responsibility for compliance to the AR. That stays with the manufacturer. What the AR provides is a legally valid EU presence to fulfil the documentation and availability obligations under the regulation.
If you are operating in the EU market without a PPWR Authorised Representative in place, your packaging is exposed from August 2026 onwards. Authorities will be looking for a named, addressable entity. If one doesn’t exist, that is itself a non-compliance.
Why Your Packaging Supply Chain Is the Biggest Compliance Risk
Building a valid DoC sounds like an administrative task. In practice, the bottleneck is almost always data.
To declare that your packaging is free from restricted PFAS and heavy metals, you need your packaging suppliers to provide supporting evidence. This includes substance declarations, test data, and material composition information, all collected and documented in a form that can withstand scrutiny.
For manufacturers with complex supply chains, this is not a one-time exercise. Every time a packaging specification changes, the technical file must be updated and the Declaration of Conformity may need to be reissued.
Brands that run into issues are often the ones that wait for suppliers to come to them. These conversations should start early, not because August 2026 is imminent, but because identifying gaps in supplier data takes time to resolve, and that time may not always be available.
How to Prepare for the August 2026 PPWR Deadline
A few practical steps worth taking now.
Map your packaging portfolio. Every distinct packaging type used for EU-destined products needs its own DoC and technical file. Know what you’re dealing with before you begin building documentation.
Clarify your role in the supply chain. Determine whether you are the manufacturer under PPWR (i.e. whose name or brand is on the packaging), an importer, or a distributor. Your obligations differ significantly depending on your position.
Talk to your suppliers. Request substance declarations and material composition data. If they cannot provide it, that is a finding you need time to act on.
Check your representative structure. Check your representative structure. If you are a non-EU manufacturer without a PPWR Authorised Representative in place, identify who will hold that role and ensure the mandate is in place before August 2026.
Keep your packaging and product compliance separate. Your CE marking technical file covers your product. The PPWR technical file, held under Annex VII Module A, covers your packaging. These are separate obligations.
From August 2026, both must exist and be available to authorities independently.
How Euverify Helps Brands Meet PPWR Packaging Requirements
We work with brands across the EU and internationally to build the compliance infrastructure their packaging requires. This includes acting as a PPWR Authorised Representative for non-EU manufacturers under Article 17, preparing Declarations of Conformity under Article 39, and structuring technical files to be audit-ready under Annex VII Module A.If you are not sure where your packaging compliance stands ahead of August 2026, start with a conversation.
Get in touch with the Euverify team.
Free PPWR Template: Download the free Euverify Declaration of Conformity template — ready to fill, based on Annex VIII, with guidance notes included. Download the template →
Frequently Asked Questions
The PPWR covers all packaging materials placed on the EU market — plastic, paper, glass, metal, wood, and composite materials. There is no exemption based on material type. If it is packaging and it is going on the EU market, the DoC requirement applies.
Authorities can require you to withdraw or recall packaging from the market and can issue fines at the national level. Each EU member state sets its own penalties, but the direction across the bloc is toward significantly tougher enforcement than existed under the old Directive.
The DoC is tied to the packaging type, not the product inside it. If ten different products use the same packaging specification, one DoC can cover that packaging type. If you use five different packaging formats across your range, you need five separate declarations.
It depends on your role. If your supplier is the manufacturer under PPWR — meaning their brand or name is on the packaging — then the DoC obligation sits with them, and your obligation as an importer under Article 18 is to verify that their DoC exists and keep a copy. If you are the manufacturer — meaning your brand or name is on the packaging, even if a supplier physically produced it — then you must draw up the DoC yourself, or appoint a PPWR Authorised Representative under Article 17 to do so on your behalf. Your supplier’s documentation feeds into your technical file in either case, but it does not automatically replace your own obligations. Clarify which role you occupy before assuming the question is resolved.
The regulation requires the DoC to be in the language or languages of the member state where the packaging is placed on the market. Confirm translation requirements against the final implementing acts for your specific markets.
