The PPWR declaration of conformity: who draws it up, what it contains, and the technical file behind it

What is the PPWR declaration of conformity?

It is the document in which the manufacturer of a packaging states that the packaging meets the sustainability, safety, labelling and information requirements of Regulation (EU) 2025/40, the PPWR. Article 39 sets out what it declares, and Annex VIII gives its model.

The declaration is the last step of a procedure, not a form you fill in on its own. Article 15(2) puts the steps in order: before placing packaging on the market, the manufacturer carries out the conformity assessment of Article 38, draws up the technical documentation of Annex VII, and, once compliance has been demonstrated, draws up the declaration.

Articles 5 to 12 are the packaging's own requirements: substances, recyclability, recycled content in plastic, compostability, minimisation, reuse and labelling. Article 8, on biobased content, asks a review of the Commission and nothing of the manufacturer.

Who draws it up: manufacturer, supplier, importer or representative?

The manufacturer. The regulation defines it as whoever manufactures the packaging or the packaged product, with one turn that matters to sellers: when you have packaging or a packaged product designed or manufactured under your own name or trademark, you are the manufacturer, whatever other trademark is visible on it (Article 3(1), point 13(a)). Point 13(b) sets an exception for some micro-enterprises and their suppliers.

An importer or a distributor that places packaging on the market under its own name or trademark, or modifies it in a way that could affect compliance, becomes the manufacturer too (Article 21).

Your packaging supplier gives information, not the declaration

Article 16(1) makes the supplier of packaging or packaging material provide the manufacturer with all the information and documentation needed to demonstrate conformity, including the technical documentation required under Articles 5 to 11, in a language the manufacturer understands.

The Commission's FAQ sums it up: the supplier provides the technical information, while the manufacturer remains the economic operator legally responsible for placing compliant packaging on the market. A supplier's paper is an input to your file. The declaration is yours.

The Commission also reads the drawings and materials of Annex VII, point 2(b) as the manufacturer's to keep, not only the supplier's (FAQ, section X, question 10).

The authorised representative can draft, not take over

A manufacturer may appoint an authorised representative by written mandate (Article 17). The mandate lets the representative keep the declaration and the technical documentation for the authorities, cooperate with them, and hand over documents within 10 days. Article 17 draws the line.

The Commission's FAQ adds that a representative may draft the declaration itself, and that the manufacturer stays the sole operator legally responsible for the packaging, whatever a contract says.

The importer checks and keeps a copy

The importer is the business established in the EU that places packaging from a third country on the market. Before doing so, it makes sure the manufacturer carried out the conformity assessment and drew up the technical documentation (Article 18(2)(a)). It then keeps a copy of the declaration for the market surveillance authorities, for 5 or 10 years (Article 18(7)).

If you make packaged goods outside the EU and sell them into it, expect your importer to ask for the declaration and the assurance that the file behind it exists.

A distributor's checks are shorter: the producer's registration in the EPR register, the labelling of Article 12, and the identification and contact details that the manufacturer and the importer must put on the packaging (Article 19(2)). The declaration is not on that list.

The manufacturer who signs the declaration is not always the producer who registers for EPR and pays a scheme: the producer is defined separately, in Article 3(1), point 15. Find out who the producer is for your packaging.

What does the declaration contain?

Article 39(2) gives it the model structure of Annex VIII, the elements of the module in Annex VII, and one more duty: to be continuously updated. Annex VIII has eight points and a signature block.

• 1. Unique identification of the packaging

  A number. The Commission reads it as the packaging's type, batch or serial number.

• 2. Manufacturer

  Name and address, and those of the authorised representative where there is one.

• 3. Sole responsibility

  Fixed wording: the declaration is issued under the sole responsibility of the manufacturer.

• 4. Object of the declaration

  Identification of the packaging allowing traceability, and a description of it.

• 5. Union legislation

  The statement of conformity with the relevant Union harmonisation legislation, with a reference to the other Union acts applied.

• 6. Standards and specifications

  References to the harmonised standards, common specifications or other technical specifications against which conformity is declared.

• 7. Notified body Where applicable

  Name, number, intervention and certificates of a notified body, where one took part.

• 8. Additional information

  Then the signature: signed for and on behalf of, place and date of issue, name, function.

To fill in these points, use our free PPWR declaration of conformity template: it follows Annex VIII point by point in your browser, and leaves every blank marked until you complete it. The Commission has published no form of its own: the model is the text of the annex.

Which standards go in point 6?

The harmonised standards of the old packaging directive (EN 13427 to EN 13432) can be used only as guidance under the PPWR, the Commission's FAQ says: they no longer give a presumption of conformity. The exception is the minimisation standard, EN 13428, until the end of 2029 (Article 70(1)(b)).

The presumption returns from the date a Commission decision listing harmonised standards for the PPWR is published, the FAQ adds. Without such a list, point 6 names the specifications you actually used, and the technical documentation describes the solutions you adopted where no standard was applied.

One declaration for several EU laws

Where the packaging or the packaged product falls under more than one EU act requiring a declaration of conformity, a single declaration is drawn up, where appropriate, naming each act and its publication reference. It may be a dossier of the individual declarations (Article 39(3)).

The Commission's FAQ gives food-contact rules as the example, and asks that a single declaration clearly distinguish the packaging from the packaged product.

What goes in the PPWR technical documentation?

The technical documentation is the file that proves what the declaration states. Annex VII, point 2 asks that it make it possible to assess the packaging's conformity, that it include an adequate analysis and assessment of the risks of non-conformity, and that it contain, wherever applicable, at least six elements.

The Commission's FAQ adds that an exemption you rely on under Article 6 (recyclability) or Article 7 (recycled content) is assessed and recorded in the same file.

The manufacturer also makes sure production stays in line with the file (Annex VII, point 3), and reassesses when the design, the characteristics or the standards declared against change (Article 15(4)).

Since when, and for which requirements?

The regulation applies from 12 August 2026 (Article 71), and the articles on the declaration set no later date of their own. Packaging placed on the market from that day needs its assessment, its file and its declaration. But the declaration only states what applies to that packaging, and several requirements of Articles 5 to 12 start later.

Packaging placed on the market before 12 August 2026 can stay on the market, the Commission's FAQ says. Its guidance dates placing on the market to the offer or agreement to transfer the packaging, and for imported packaging, to its release for free circulation. On our reading, the date therefore counts unit by unit, not model by model.

One declaration per packaging, per size, per SKU?

Annex VII, point 4 asks for a written declaration for each packaging type. The Commission reads “type” as each packaging format or batch or series, not each packaging material.

• The whole unit

  One assessment and one declaration for a bottle, its closure and its label together, with information on each component.

• Sizes that change nothing

  Bottles of different sizes holding the same product can share a declaration, if the size changes nothing under Articles 5 to 12.

• Different products

  Where the packaged products differ, one declaration for all packaging is not enough.

• Transport packaging

  No exemption: pallets, pallet collars, wrappings and straps each have their own assessment and declaration.

Those four answers come from the Commission's FAQ (section XV, questions 5, 10 and 11). The text itself has one exception: Article 15(11) lifts the duty for custom-made transport packaging for configurable medical devices and medical systems used in industrial and healthcare environments.

Where does the declaration go?

Nowhere, until someone asks. The Commission's FAQ says a manufacturer does not notify the authorities of each country where its packaging is sold: the authorities contact the manufacturer when they check.

On a national authority's reasoned request, the manufacturer provides the information and documentation, including the technical documentation, in a language the authority understands, electronically, and on paper if asked, within 10 days of the request (Article 15(10)). Article 39(5) asks the authorities to endeavour to check the accuracy of at least part of the declarations every year, on a risk-based approach.

The declaration is drawn up in, or translated into, the languages required by each member state where the packaging is placed or made available (Article 39(2)).

If you find that packaging you placed on the market does not comply, the regulation asks you to act immediately: bring it into conformity, withdraw it or recall it, and inform the market surveillance authority of the member state where you made it available (Article 15(8)).

The declaration is one obligation of the PPWR. Your packaging EPR registrations and declarations, country by country, are another, and the scope check lists them for the countries you sell to.

Questions sellers ask