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 has applied since 12 August 2026. Many brands only became aware of it close to the deadline, and some are still catching up.
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. There are two exceptions. If the brand is a micro-enterprise buying from a supplier in the same Member State, the supplier is the manufacturer. For custom-made or unbranded packaging, whoever placed the order and set the design specification is the manufacturer.
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 holds the DoC and technical documentation and acts as the EU contact point for authorities. Article 17 does not allow the mandate to include drawing up the technical documentation; the manufacturer must do that itself. 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 make sure their own name and address appear on the packaging, 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. If the manufacturer has appointed an Authorised Representative, the AR’s details can also be included.
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 a person authorised to sign on the manufacturer’s behalf, such as a director or head of quality or compliance. 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 placed on the EU market since 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 (lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg combined, in any packaging layer or component)
- 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 chemical restrictions (Article 5), recyclability (Article 6), recycled content (Article 7), biobased feedstock and compostability (Articles 8 and 9), packaging minimisation (Article 10), reusability (Article 11), and labelling (Article 12).
These requirements come into effect at different stages. Substance limits (heavy metals and PFAS), minimisation, and manufacturer and importer identification have applied since 12 August 2026. Harmonised labelling follows from 2028. Recyclability grading, recycled-content targets and the 50% empty-space limit follow 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 still draw up and sign your own PPWR Declaration of Conformity. However, authorities need an EU-based party they can contact and request documents from. That is either your EU importer (Article 18) or an Authorised Representative you appoint (Article 17).
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 holds your DoC and technical documentation and is the named point of contact for market surveillance authorities. The AR cannot draw up the technical documentation for you; that stays with the manufacturer.
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 sell directly to EU customers with no EU importer and no Authorised Representative, there is no one in the EU for authorities to contact. That leaves your packaging exposed, so in practice most non-EU manufacturers without an EU importer appoint an AR.
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. If you haven’t started these conversations yet, start now. Identifying and closing gaps in supplier data takes time.
How to Get Your Packaging Compliant Under PPWR
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. If you are a non-EU manufacturer without a PPWR Authorised Representative in place, and without an EU importer, identify who will hold that role and put the mandate in place as soon as possible.
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.
Since August 2026, both must exist and be available to authorities independently.
Don’t confuse PPWR with EPR. The PPWR Declaration of Conformity is about whether your packaging meets the design and substance rules. Extended Producer Responsibility (EPR) is a separate obligation: registering with national packaging schemes and paying waste fees in each country where you sell. You need to handle both separately.
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, and our PPWR module, which guides you step by step through building your Declaration of Conformity (Annex VIII) and technical documentation (Annex VII). The declaration is signed by your own company, and the software helps you keep everything structured and ready for authorities. If you are not sure where your packaging compliance stands, 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, The European Commission has said Member States should first warn an operator and give a reasonable period to fix non-compliance before ordering a recall or withdrawal.
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 and technical documentation yourself. A PPWR Authorised Representative can hold them for you and act as your EU contact point, but cannot draw up the technical documentation 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.
Yes. Under Article 39(2), the DoC must be in the language or languages required by each Member State where the packaging is placed or made available on the market. You only need the languages for the countries you actually sell in, not every EU language.
It doesn’t need to be destroyed, remade or relabelled. According to the European Commission’s PPWR FAQ, the required identification details (a unique ID and the manufacturer’s name and address) can be provided in an accompanying document rather than on the packaging itself.
