PPWR EU declaration of conformity: what it must contain

Since 12 August 2026, an EU declaration of conformity has been required for every packaging type placed on the European market. It is drawn up by the party defined as the manufacturer in Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation (PPWR), before the packaging is placed on the market. The document follows the model in Annex VIII of the Regulation, the only authoritative model: 8 headings, a number and a signature. It is supported by technical documentation proving conformity and must be kept for 5 years for single-use packaging and 10 years for reusable packaging.

The request often comes from a customer or importer asking for the packaging declaration of conformity (DoC), while no one in your organisation knows who must sign it. The answer depends first on the brand displayed on the packaging and the company that fills it.

1The manufacturer draws up the declaration of conformity

The PPWR makes the manufacturer solely responsible for drawing up the declaration: other operators check it or provide information, without signing on the manufacturer's behalf. The term can be misleading because the manufacturer is not necessarily the company that physically produces the packaging.

The PPWR definition of manufacturer

Article 3 defines the manufacturer as the party that manufactures the packaging or has it designed or manufactured under its own name or trademark. According to the Commission guidance of 10 June 2026, there is only one manufacturer in each supply chain, in principle the brand owner:

• Sales or grouped packaging: the company that fills it with its product, or the brand for which a contract packer fills it; for a caterer's tray, the manufacturer is the caterer, even if a thermoforming manufacturer produced the tray.
• Standard unbranded cardboard boxes or film: the physical manufacturer, even where a box is supplied flat; an e-commerce company that attaches its shipping label does not become the manufacturer.
• Bespoke unbranded packaging: the company that ordered it and specified its requirements.
• Micro-enterprises: the supplier becomes the manufacturer if it is located in the same Member State (Article 3, followed by the guidance), or simply within the Union under Article 15(12), a discrepancy explained in our article for micro-enterprises.

This manufacturer is distinct from the producer under extended producer responsibility (EPR) for household or professional packaging, which pays the EPR fee (éco-contribution) and obtains a unique identifier (identifiant unique, or IDU) in France: the 2 roles often fall to the same company, but this is not guaranteed.

Importers and distributors

The importer of packaging or a packaged product from a third country checks that the foreign manufacturer has drawn up the declaration, keeps a copy and adds its name and address to the packaging. The distributor checks the manufacturer and importer details, labelling and the producer's registration in the EPR register, without having to hold the declaration. Either becomes the manufacturer if it sells under its own name or trademark, or modifies packaging already on the market in a way that may compromise its conformity (Article 21).

Finally, the supplier cannot refuse to provide the manufacturer with the information and documentation it needs (Article 16). In our experience at Projet Celsius, the most costly mistake is relying solely on a supplier's compliance statement: it supports the file, but responsibility cannot be transferred by contract, and signing makes the manufacturer accountable to the authority.

2Annex VIII sets out the declaration's required contents

The model specifies the order and titles of the headings; the FAQ published by the Commission in August 2026 resolves most uncertainties about their content.

One declaration per packaging type

Annex VII requires one declaration per packaging type, meaning per format or manufacturing batch. Bottles of different sizes containing the same product may share a declaration if size does not affect their conformity. The declaration covers the complete packaging unit, including the bottle, cap and label, and its identification number matches the number on the packaging so an inspector can link the two.

Standards that no longer confer a presumption of conformity

Standards EN 13427 to EN 13432 under the former Directive no longer confer a presumption of conformity and serve only as guidance, except EN 13428 on source reduction, until the end of 2029. Heading 6 therefore lists the standards and test methods used; heading 7 is not applicable, as the PPWR procedure is internal production control, without a notified body.

One declaration covering several legal acts

Where packaging is subject to other legislation requiring a declaration, such as Regulation (EU) No. 10/2011 on food-contact plastics, a single declaration may cover all the acts, citing each one (Article 39) and distinguishing the packaging from the packaged product. The PPWR does not introduce CE marking: any such marking on packaging relates only to the product it contains.

3Since 12 August 2026, the declaration has mainly covered substance requirements

The declaration covers the requirements in Articles 5 to 12 of the Regulation, but each has its own application date: as at 28 September 2026, 2 quantified limits apply in full, while the recyclability criteria have yet to be set.

Heavy metals and per- and polyfluoroalkyl substances (PFAS)

The sum of lead, cadmium, mercury and hexavalent chromium remains capped at 100 mg/kg, a limit carried over from the 1994 Directive that must now be demonstrated in the technical documentation, with derogations retained for glass and for plastic crates and pallets. Since 12 August 2026, food-contact packaging has also had to meet PFAS limits: 25 ppb for each targeted PFAS, 250 ppb for their sum and 50 ppm for total PFAS. The Commission recommends starting with a total fluorine test, with compliance below 50 mg/kg, a method explained in our article on PFAS in food packaging.

Recyclability and reduction remain subject to the 1994 criteria

Since 12 August 2026, Article 6 has required all packaging to be recyclable, but its criteria depend on a delegated act expected by 1 January 2028 at the latest. Until then, the Commission asks for compliance with the 1994 Directive and EN 13430:2004, without a recyclability assessment under the PPWR. Weight and volume reduction continue to be assessed under the 1994 Directive and EN 13428 until 31 December 2029.

Each new deadline requires an update to the declaration, as Article 39 requires it to be kept continuously up to date; the PPWR timeline and our articles on recycled plastic content and packaging eco-design explain these stages.

4The technical documentation provides evidence of conformity

The technical documentation provides evidence for the claims in the declaration and is what the authority will request during an inspection.

The documents to collect

Annex VII specifies its minimum contents, where applicable:

• A general description of the packaging and its intended use.
• Conceptual design and manufacturing drawings and the materials used in each component.
• A list of the standards and specifications applied, or the alternative solutions adopted.
• A description of the assessments of recyclability, minimisation and reusability (Articles 6, 10 and 11), where required.
• Test reports and an analysis of the risks of non-compliance.

Preparation of the technical documentation cannot be entrusted to the authorised representative for conformity under Article 17; the manufacturer may appoint this optional representative in writing, and the representative must be established in the Union. The mandate authorises the representative, at a minimum, to keep the declaration and documentation available to the authorities, cooperate with them and provide the documents they request; drawing up the declaration itself remains the manufacturer's obligation (Article 15). This is distinct from the authorised representative for extended producer responsibility under Article 45, which is mandatory in each country where the producer sells directly without being established there. Any exemptions claimed must be justified in the documentation, which must include supplier drawings, with their confidentiality protected by the manufacturer.

Transport packaging is covered too

There is no exemption for transport packaging: pallets, pallet collars, stretch film and strapping each require their own assessment and declaration, drawn up by their manufacturer. A transport box must also display a type or batch number and the manufacturer's name and postal address, directly or through a QR code. An accompanying document is permitted only where this marking is impossible, or for stocks produced before 12 August 2026, which do not have to be destroyed or relabelled.

5The declaration must be kept and made available for inspection

The manufacturer keeps the declaration and documentation for 5 years after single-use packaging is placed on the market and 10 years for reusable packaging; the importer keeps a copy for the same period. Following a reasoned request from an authority, the documents must be provided within 10 days. The declaration is drawn up or translated into the language or languages required by each Member State where the packaging is made available (Article 39). According to the Commission FAQ, this means the languages of the delivery countries: French for France.

In France, the competent authority is the direction générale de la prévention des risques (DGPR), the French risk prevention directorate, according to French customs. Customs is not the market surveillance authority for packaging but may suspend the release of imported goods to refer the matter to the competent authority. A missing or incorrectly drawn-up declaration constitutes formal non-compliance (Article 62): the State first requires rectification and only prohibits sale or orders withdrawal if the non-compliance persists. National penalties must be set by 12 February 2027 at the latest.

6Key takeaways

• Since 12 August 2026, an EU declaration of conformity has been required for every packaging type, drawn up using Annex VIII before the packaging is placed on the market.
• Only the manufacturer signs: in principle the brand that fills the packaging, or the cardboard box manufacturer for a standard unbranded box.
• The importer keeps a copy and the distributor checks the details; either becomes the manufacturer if it sells under its own brand.
• The declaration currently mainly attests to substance requirements, covering heavy metals and PFAS; recyclability is still assessed against the 1994 criteria.

Our PPWR guide places the declaration within the wider Regulation, while our article on the companies affected helps you check whether it applies to you; our PPWR support covers the packaging inventory and preparation of the documentation.

Further resources

Frequently asked questions

1Do I need a PPWR declaration of conformity for every package?

You need one per packaging type, meaning per format or manufacturing batch. Packaging of different sizes containing the same product may share a declaration if the size difference does not affect conformity. The declaration covers the complete unit, for example the bottle, cap and label, and each distinct item of transport packaging, whether a pallet, film or strapping, has its own declaration.

2Must my packaging supplier provide a declaration of conformity?

Only if it is itself the manufacturer under the PPWR, for example for a standard unbranded cardboard box, or if you are a micro-enterprise and it is located in the same country as you (Article 3), or simply within the Union under Article 15(12). In other cases, you sign, but your supplier must provide all the necessary information and documentation (Article 16) and cannot refuse to do so.

3Do I need to submit the declaration to a public authority?

No: the PPWR requires neither filing nor prior registration of the declaration, and the manufacturer does not have to notify the authorities that it sells packaging in their territory, as registration in the producer register falls under EPR. The manufacturer keeps the declaration and technical documentation available for 5 or 10 years and provides them within 10 days following a reasoned request. In France, the competent authority is the DGPR within the Ministry of Ecological Transition.

4Is there an official PPWR declaration of conformity template?

The only official model is the text of Annex VIII to Regulation (EU) 2025/40: a declaration number, 8 headings and a signature block. Neither the Commission guidance of 10 June 2026 nor its August 2026 FAQ provides a form to complete. Templates available online reproduce the structure, and the manufacturer must check that no heading has been omitted.

5What should I do with packaging stocks manufactured before 12 August 2026?

They do not have to be destroyed, reworked or relabelled: the identification number and manufacturer's contact details may appear in an accompanying document, according to the Commission FAQ. Packaging already placed on the market before that date may remain there. There is a significant exception: food packaging placed on the market after 12 August 2026 must meet the PFAS limits, without a period for selling through existing stock.

6Does Article 5 on substances apply only to food packaging?

No. The 100 mg/kg limit for the sum of lead, cadmium, mercury and hexavalent chromium (Article 5, paragraph 4) applies to all packaging. The reference to food-contact materials in that paragraph preserves the specific food-contact rules without restricting its scope. Only the PFAS limits (Article 5, paragraph 5) apply exclusively to food-contact packaging. Industrial or medical packaging must therefore demonstrate compliance with the heavy metal limit in its technical documentation.

7Can I leave out technical documentation items listed in Annex VII if they do not apply?

You cannot remove them wholesale. Annex VII lists the documents to be provided where applicable: if an item does not apply, you must justify this in the documentation, explaining why the requirement does not apply and citing the exemption, rather than deleting it. The list of standards and specifications applied (point d) and test reports (point f), for example on the heavy metal limit, are still required in principle for all packaging. The description of recyclability, minimisation and reusability assessments (point e) is less extensive for packaging exempted from Article 6, but the exemption must be stated explicitly and the other assessments must still be described where they apply.

8Is packaging for medicines or medical devices exempt from the declaration of conformity?

No. Specific exemptions apply to this packaging: the recyclability requirement applies neither to the immediate packaging of medicinal products nor to contact-sensitive packaging for medical devices and in vitro diagnostic devices (Article 6, paragraph 11, points a, b and c), and the same plastic packaging is exempt from minimum recycled content (Article 7, paragraph 4). Compliance with the minimisation requirement (Article 10) is required only from 1 January 2030, for all packaging. However, the EU declaration of conformity and technical documentation have been required since 12 August 2026, covering the heavy metal limit in Article 5, paragraph 4, and then labelling when it becomes applicable. An exemption must be documented; it does not remove the documentation requirement.

Ask Sébastien your questionA personal reply within 24 working hours

Send my questionor: [email protected]