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

> Canonical: https://shippeu.com/resources/blog/ppwr-declaration-of-conformity
> Published: 12 November 2026 · Last source review: 12 November 2026 · ShippEU

The PPWR declaration of conformity is the statement, signed by the manufacturer of the packaging, that it meets the requirements of Articles 5 to 12 of Regulation (EU) 2025/40 that apply to it. It follows the model of Annex VIII, rests on a technical file built under Annex VII, and is kept for the authorities, not sent to them.

## In short

- The manufacturer of the packaging draws up the declaration (Article 15(2)): the brand that has packaging or a packaged product made under its own name counts as manufacturer as a rule, even when another trademark is visible.
- It follows the eight points of Annex VIII and rests on technical documentation built under Annex VII, Module A: the manufacturer assesses its own packaging, and the annex gives no role to a notified body.
- Suppliers owe the manufacturer the information. An authorised representative can draft the declaration under a written mandate, but drawing up the technical documentation stays with the manufacturer.
- It is due before packaging is placed on the market, from 12 August 2026, and covers only the requirements that already apply to that packaging. Several start in 2028 or 2030.
- You don't send it to an authority. You keep it with the technical documentation for 5 years (single-use packaging) or 10 years (reusable), and hand it over within 10 days of a national authority's reasoned request.

## Key facts

- **8** — Points in the model declaration (Annex VIII)
- **1** — Conformity assessment procedure: internal production control (Article 38, Annex VII (Module A))
- **5 / 10 years** — Kept after single-use / reusable packaging is placed on the market (Article 15(3), Annex VII, point 4)
- **10 days** — To produce the documents after a national authority's reasoned request (Article 15(10))

## 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](https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng), the [PPWR](https://shippeu.com/ppwr). Article 39 sets out what it declares, and Annex VIII gives its model.

> The EU declaration of conformity shall state that the fulfilment of the requirements laid down in or pursuant to Articles 5 to 12 has been demonstrated. […] By drawing up the EU declaration of conformity, the manufacturer assumes responsibility for the compliance of the packaging with the requirements laid down in this Regulation.
>
> Regulation (EU) 2025/40, Article 39(1) and (4), https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng

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).

**Who does what around the declaration**

- **The manufacturer** (Articles 15 and 39): Carries out the conformity assessment, or has it carried out; Draws up the technical documentation; Draws up and signs the declaration, and keeps both
- **The supplier and the representative** (Articles 16 and 17): The supplier gives the manufacturer the information and documentation it needs; A representative can draft the declaration and keep the file, under a written mandate; Neither takes over the technical documentation
- **The importer** (Articles 18 and 21): Checks, before placing on the market, that the assessment was made and the file drawn up; Keeps a copy of the declaration for the authorities; Becomes the manufacturer if it sells under its own name

### 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](https://shippeu.com/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 obligations laid down in Article 15(1) and the obligation to draw up the technical documentation referred to in Annex VII and required under or pursuant to Articles 5 to 11 shall not form part of the authorised representative’s mandate.
>
> Regulation (EU) 2025/40, Article 17(2), last subparagraph, https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng

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](https://shippeu.com/tools/who-is-the-producer).

## 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](https://shippeu.com/tools/ppwr-declaration-of-conformity): 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.

> **Our reading:** Annex VII provides a single procedure, internal production control, in which no notified body intervenes. Point 7 of the model will usually read “not applicable”. The Commission's FAQ notes that a manufacturer can have the assessment carried out on its behalf, by a laboratory or a certification scheme for example: the declaration stays the manufacturer's.

### 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 technical documentation, Annex VII, point 2**

- [ ] **A general description** of the packaging and its intended use.
- [ ] **Conceptual design, manufacturing drawings** and the materials of the components.
- [ ] **The descriptions and explanations** needed to understand those drawings and how the packaging works.
- [ ] **The list of standards** and specifications applied, in full or in part, or a description of the solutions adopted where none was applied.
- [ ] **How the assessments of Articles 6, 10 and 11 were carried out**: recyclability, minimisation, reuse, in a qualitative description.
- [ ] **Test reports.**
- [ ] **The analysis and assessment of the risks** of non-conformity.

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.

| Requirement | When it applies | Basis |
| --- | --- | --- |
| **Article 5**, requirements for substances in packaging | Since 12 August 2026: the limit on lead, cadmium, mercury and hexavalent chromium in all packaging, and the PFAS limits for food-contact packaging. | Article 5(4) and (5), Article 71 |
| **Article 6**, recyclable packaging | Packaging has had to be recyclable since 12 August 2026, but the Commission's guidance says the conformity assessment for recyclability waits for the delegated act on design for recycling. Grades A to C apply from 1 January 2030 at the earliest. | Article 6(1) and (2); Commission guidance C/2026/3084, point 6 |
| **Article 7**, minimum recycled content in plastic packaging | From 1 January 2030, or three years after the implementing act on calculating and verifying recycled content, whichever is later. | Article 7(1) |
| **Article 9**, compostable packaging | From 12 February 2028: permeable tea, coffee and other beverage bags, soft single-serve units for beverages, and stickers on fruit and vegetables must be industrially compostable; other packaging, biodegradable plastics included, must be designed for material recycling. | Article 9(1) and (3) |
| **Article 10**, packaging minimisation | From 1 January 2030: weight and volume reduced to the minimum the packaging's function needs, and nothing that only adds perceived volume, such as double walls, false bottoms or unnecessary layers. | Article 10(1) and (2); Commission FAQ, X.2 |
| **Article 11**, reusable packaging | For packaging placed on the market as reusable: the criteria have applied since 11 February 2025, and the authorities check them from 12 August 2026. | Article 11(1); Commission guidance C/2026/3084, point 12 |
| **Article 12**, labelling of packaging | From 12 August 2028, or 24 months after the implementing acts on the harmonised label, whichever is later. | Article 12(1) |

Where a later date depends on a delegated or implementing act, the later of the two dates applies. Read in the regulation, and in the Commission's guidance and FAQ where they set the date in practice, on 12 November 2026.

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.

> **Limit:** Recyclability is the trap. Packaging has had to be recyclable since the regulation applies, but the Commission's guidance says manufacturers do not need to run the conformity assessment for recyclability until the delegated act on design for recycling under Article 6(4) enters into force.

## 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.

> The manufacturer shall draw up a written declaration of conformity for each packaging type and keep it together with the technical documentation at the disposal of the national authorities for 5 years after single-use packaging has been placed on the market, and 10 years after reusable packaging has been placed on the market.
>
> Regulation (EU) 2025/40, Annex VII, point 4, https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng

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](https://shippeu.com/streams/packaging) registrations and declarations, country by country, are another, and the [scope check](https://shippeu.com/start) lists them for the countries you sell to.

## FAQ

**Can I use my packaging supplier's declaration?**

Not as your own. The supplier owes you the information and documentation you need (Article 16(1)); you, as manufacturer, carry out or commission the assessment, draw up the technical documentation and sign the declaration (Article 15(2)). The Commission's FAQ says the manufacturer remains the operator legally responsible.

**Is there an EU template for the declaration?**

The model is the text of Annex VIII to Regulation (EU) 2025/40. The Commission has published no fillable form. Our free [PPWR declaration of conformity template](https://shippeu.com/tools/ppwr-declaration-of-conformity) follows the annex point by point.

**Do I need a notified body?**

The regulation provides for none. The only conformity assessment procedure, in Annex VII, is internal production control (Module A): the manufacturer assesses its own packaging, and the annex gives no role to a notified body. You can have the assessment carried out on your behalf, by a laboratory for example, without changing who declares.

**Can the declaration be signed electronically?**

The regulation and the Commission's FAQ set no rule on the form of the signature. Annex VIII asks for the name and function of the signatory, the place and date of issue, and the signature.

**Does the declaration have to list requirements that do not apply yet?**

It states that the requirements of Articles 5 to 12 that apply to the packaging have been met (Annex VII, point 1). A requirement with a later date, such as minimisation, from 1 January 2030, is declared once it applies, and the declaration is kept up to date (Article 39(2)).

## Sources

- Regulation (EU) 2025/40 on packaging and packaging waste, Articles 3, 5 to 12, 15 to 19, 21, 38, 39, 70 and 71, Annexes VII and VIII — https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng
- Commission Notice C/2026/3084, guidance document for Regulation (EU) 2025/40, points 2, 5, 6 and 12 — https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52026XC03084
- Packaging and Packaging Waste Regulation (PPWR): frequently asked questions, 3 August 2026, sections X and XV — https://environment.ec.europa.eu/publications/faq-packaging-and-packaging-waste-regulation-ppwr_en

ShippEU is a private service. It is not an authority, a register or a collective scheme. Figures come from published guidance; rules change. The scope check at https://shippeu.com/start is reviewed by a person before any quote.