·
15 minute read
The PPWR declaration of conformity sits at the end of a procedure: the manufacturer assesses a piece of packaging before placing it on the market and issues the declaration once it meets the applicable requirements. That has been mandatory for manufacturers since : if you are the manufacturer, you need one for every packaging type you place on the EU market. The legal basis is Article 15 in conjunction with Article 39 of Regulation (EU) 2025/40.
The template in Annex VIII is compact. The work is not in the form itself but in what it relies on: the technical documentation that has to back up every entry. That is where most companies come unstuck, because packaging data traditionally sits with procurement, in packaging development and in individual supplier emails.
This article sets out what Annex VIII of Regulation (EU) 2025/40 on EUR-Lex requires in the declaration, who has to draw it up, what the technical documentation behind it contains and how long you have to keep both.
What the PPWR declaration of conformity is
The PPWR declaration of conformity is a written document in which the manufacturer declares, under its own responsibility and in line with Article 15 in conjunction with Article 39 of the PPWR, that a piece of packaging meets the applicable requirements of Regulation (EU) 2025/40. Its formal name is the EU declaration of conformity. The binding template sits in Annex VIII.
The two articles do different jobs, and in practice they get conflated. Article 15 creates the obligation: before placing packaging on the market, the manufacturer has to carry out the conformity assessment, draw up the technical documentation and issue the declaration. Article 39 governs what the document looks like and what it does.
You know the principle from other areas of EU product law: whoever places a product on the market has to know how it is built and what it is made of, assesses it themselves and takes responsibility. For packaging, that assessment runs as internal production control under Annex VII. A notified body is not strictly required, so the economic operator can act independently and without third parties. And for now, no CE marking goes on the packaging.
The European Product Act is an announced Commission initiative. Its future impact on CE marking and digital product information is not yet settled and does not change the obligations described here.
The distinction that matters is between the declaration and the evidence. The declaration is the statement. The technical documentation is the proof. Fill in the form without the documentation behind it and you are declaring something you may not be able to substantiate.
Key point: The declaration is a self-assessment that carries liability. Without solid technical documentation behind it, it is worthless.
Who has to draw it up
The obligation sits with the manufacturer. Under Article 3(1)(13) of the regulation, that is whoever manufactures packaging themselves or has it designed or manufactured under their own name or trademark. What decides the question is not who operates the machine but who controls the design and the specification.
In practice: a furniture company that has its shipping cartons made to its own specification is the manufacturer. A fashion brand buying polybags printed with its own logo is too. Sticking an address label on a plain standard carton does not make you the manufacturer.
The European Commission guidance on the PPWR of confirms that reading and sharpens it in two places. For sales and grouped packaging the manufacturer is usually the filler, which is often the brand owner. And in any supply chain there is only ever one manufacturer for a given piece of packaging. The role cannot be split, and it cannot be contracted away to your packaging supplier.
The most common stumbling block is confusing this with the producer role under extended producer responsibility. The two sound similar, mean different things, and a company may hold both or only one. If you want to settle your role first, start with the question of who is affected by the PPWR.
| Role | What it covers | Relationship to the declaration |
|---|---|---|
| Manufacturer (Article 15) | Conformity of the packaging itself | Carries out the conformity assessment, draws up the technical documentation and issues the declaration |
| Producer under extended producer responsibility | Financial responsibility for waste management and registration | None, this is a separate obligation with its own registration |
| Supplier (Article 16) | Supplies packaging or packaging materials | Hands the manufacturer the information and documentation needed for the proof of conformity, on paper or electronically, in one or more languages the manufacturer can easily understand |
| Importer (Article 18) | Places packaging from a third country on the EU market | Checks that the assessment was done, keeps a copy of the declaration and makes sure the technical documentation can be made available |
| Distributor (Article 19) | Makes packaging available on the market | A graduated duty of care, in particular on labelling and identification details |
There is a special rule for small suppliers. Under Article 3(1)(13)(b) the own-brand company is not the manufacturer if it is a microenterprise and its packaging supplier is established in the same Member State; in that case the supplier is. Article 15(12) provides for a similar shift but attaches to establishment in the Union. If you are a small business commissioning packaging, or you supply microenterprises, check both provisions separately. In neither case does the obligation disappear. It changes hands.
Key point: The manufacturer is whoever controls the packaging specification. That role is not the same as the producer role under extended producer responsibility.
What goes into it: Annex VIII in detail
Annex VIII sets the structure. There is no official fill-in template; what is binding is the model in that annex. It is short, but every numbered item has a job, and every one has to be right.
| Element | What matters |
|---|---|
| Header: number of the declaration | The declaration carries its own reference number. It is not the same as the packaging identification under item 1. |
| No. 1: Unique identification of the packaging | Has to identify the packaging traceably. An internal packaging ID works; the article number of the packed product often does not. |
| No. 2: Name and address of the manufacturer | Plus the authorised representative where applicable. Has to match what appears on the packaging. |
| No. 3: Statement of responsibility | The declaration is issued under the sole responsibility of the manufacturer. This is the sentence that carries the liability. |
| No. 4: Object of the declaration | Identification of the packaging allowing traceability, plus a description: construction, material, function. |
| No. 5: Reference to the Union acts applied | This is where the other relevant Union harmonisation legislation goes, not the PPWR itself. A common source of error. |
| No. 6: Standards and specifications | Harmonised standards under Article 36, common specifications under Article 37, or other technical specifications in relation to which conformity is declared. Only list what you actually applied. |
| No. 7: Notified body, where applicable | Part of the standard layout of an EU declaration of conformity. For the Annex VII route the field normally stays empty. |
| No. 8: Additional information | A free field for anything needed to place the declaration in context. |
| Signature block | Signed for and on behalf of, place and date of issue, name, function, signature. Record internally who has signing authority. |
A question that comes up in almost every project: one declaration per piece of packaging, or a collective one? Annex VII point 4 is unambiguous. The manufacturer draws one up for each packaging type, not for each individual item and not for each packed product. The declaration has to identify the packaging it was drawn up for, and a copy has to be made available to the relevant authorities on request. It becomes workable once you draw clean lines between your packaging types instead of working article number by article number. A company with 4,000 articles but 60 packaging types keeps 60 records, not 4,000.
Key point: The declaration stands or falls on clean packaging identification. Without a stable packaging ID the document does not scale.
The technical documentation under Annex VII
This is where the actual effort sits. The conformity assessment under Article 38 runs as internal production control, and you record the result in the technical documentation under Annex VII. The annex lists what has to be in it as a minimum: a general description of the packaging and its intended use, designs, manufacturing drawings and materials of components, the explanations needed to understand them, a list of the standards and specifications applied, a qualitative description of how the assessments under Articles 6, 10 and 11 were carried out, and the test reports. One element is easy to miss: the documentation has to contain an adequate analysis and assessment of the risks of non-conformity. The declaration itself is kept together with the technical documentation under Annex VII point 4, so both belong in the same record.
The operative word is "applicable". The requirements in Articles 5 to 12 phase in over the coming years, and several of them are only given shape by implementing or delegated acts. The substance restrictions under Article 5 have applied since the date of application; minimisation of weight and volume under Article 10 applies from . Recyclability and minimum recycled content name the same date but are tied to their respective acts, which makes that date the earliest possible one rather than a fixed one.
For companies this means the regulatory demands on data points grow with each act that follows. Every year you need to check which new requirements have to enter the technical documentation as data points, calculated values or performance grades, and then be assessed for conformity.
What we see with customers again and again: the data exists, just not in one place. Material details sit in the purchasing system, weights in a spreadsheet owned by packaging development, supplier confirmations in individual mailboxes. As long as that holds, every update to the declaration becomes a small project. The European Commission guidance clears up some definitional questions. It does not solve the data problem.
On top of that, packaging supply chains change regularly. Suppliers are swapped, they change their material compositions or their production sites. Data has to be adjusted continuously. A system that is rigid and cannot respond flexibly to change, while also being expected to carry a large volume of data, will not meet that challenge. The data has to flow into the technical documentation in a way that stays changeable and up to date.
Key point: The bottleneck is not the form but scattered packaging data. Consolidate it and the declaration falls out as a by-product.
Five steps to your PPWR declaration of conformity
The following order has proven itself. Start at step three and you will be reordering things later.
- Establish which packaging types make you the manufacturer. For each packaging type, check whether you manufacture it yourself or have it designed or manufactured under your own name or trademark. Only then does the obligation under Article 15 apply to you.
- Take an inventory of your packaging types. List every packaging type you place on the EU market and group them by construction and material rather than by article number.
- Bring the data together per packaging type. Collect components, materials, weights, supplier evidence and test reports for each packaging type in one place instead of in individual emails and spreadsheets.
- Carry out the conformity assessment and build the technical documentation. Assess the packaging against the requirements laid down in or pursuant to Articles 5 to 12 that apply in each case, and record the result under Annex VII of Regulation (EU) 2025/40.
- Issue the declaration, version it and retain it. Draw up the declaration using the template in Annex VIII, record which data state it rests on, and keep it for five or ten years from the date the packaging was placed on the market.
Key point: Settle roles and packaging types first. Starting with the form means building on an unclear basis.
Deadlines, retention and what happens if it is missing
The regulation has applied since 12 August 2026. Declarations of conformity can only be issued from that date onwards, and they have to be: for packaging you place on the market from now on, there is no transition period for the document itself. Under Article 68, Member States must have laid down and implemented their rules on penalties by .
That is the part that is fixed. The substantive requirements you have to demonstrate compliance against phase in, and most of those dates are dynamic: they hang on an implementing or delegated act entering into force, and the later of the two dates applies. Harmonised labelling of material composition under Article 12(1) applies from 12 August 2028 or 24 months after the relevant implementing acts. For reusable packaging under Article 12(2) it is 12 February 2029 or 30 months after the act under paragraph 6, whichever is the latest. The full list of every fixed and dynamic date through to 2038 is in the PPWR timeline.
For your documentation that means you assess today against what applies today, and you set the record up so later stages can be added without starting over.
There is also a short response time, and it applies already: on a reasoned request from a national authority you have to provide all the information and documentation needed to demonstrate conformity, including the technical documentation, in one or more languages which can be easily understood by that authority. It is provided in electronic form and, on request, in paper form, and the relevant documents have to be made available within 10 days of receipt of the request (Article 15(10)). The technical documentation and the declaration themselves may be kept on paper.
The retention period is five years from the date the packaging was placed on the market, and ten years for reusable packaging. That is not a detail: packaging you delisted in 2026 can still come back to you in 2031. Documentation that only exists in one person's head or in a project folder rarely survives that long.
Where something is non-compliant, the market surveillance authorities step in. They can challenge the packaging, require corrections and restrict its availability on the market. The fines themselves are set by the Member States, which have to have those rules laid down and implemented by 12 February 2027.
Key point: The obligation applies now; Member States have to have their penalty rules in place by February 2027. Anyone still not assessing is already behind.
The PPWR declaration of conformity and the Digital Product Passport
One thing up front, because the question keeps coming: the PPWR does not require a Digital Product Passport for packaging. Anyone claiming otherwise is mixing up two legal acts.
The Digital Product Passport comes from the Ecodesign Regulation and concerns the product. The PPWR governs the packaging. There is one point where the two interlock, and it tends to get overlooked: where Union law requires information on the packaged product to be provided via a data carrier, Article 12(5) requires that a single data carrier be used for the information required for the packaged product and for the packaging, and that both be easily distinguishable. Recital 70 adds the reason and goes one step further: where the packaged product is covered by Regulation (EU) 2024/1781 or other Union law requiring a digital product passport, that passport should also be used for the information required under the PPWR. This is not a general obligation to produce a packaging passport but the consequence of one you already have: it bites as soon as your product needs a data carrier anyway. Product and packaging data then run through one data carrier, such as a QR code or another standardised, open digital data carrier.
There is also the language rule in Article 12(5): the information in the labels and in the QR code or other standardised, open digital data carrier is made available in one or more languages which can be easily understood by end users, as determined by the Member State in which the packaging is to be made available on the market. Ship into eight countries and you settle that question eight times.
Article 12(2) adds a requirement for reusable packaging. It has to bear a label informing users that the packaging is reusable, and further information on reusability is made available through a QR code or another standardised, open digital data carrier. Open circular systems without a system operator under Annex VI are exempt under paragraph 3. The timing is dynamic: 12 February 2029 or 30 months after the implementing act under Article 12(6) enters into force, whichever is the latest.
For companies placing physical products on the EU market the practical upshot is that two sets of rules draw on the same data basis. Material composition, weights, supplier evidence, version states. Run your PPWR documentation and your product passport as two separate projects and you maintain the same data twice, then explain at the first discrepancy which version is right. Our overview of the EU Packaging Regulation PPWR puts this in context.
Key point: There is no packaging passport. If your product needs a data carrier, Article 12(5) requires product and packaging data to run through the same one.
The PPWR declaration of conformity in numbers
12 Aug 2026
The PPWR has applied since this date, and with it the duty to issue an EU declaration of conformity (Regulation (EU) 2025/40)
Art. 15 + 39
Article 15 creates the obligation, Article 39 governs the document (Regulation (EU) 2025/40)
Annex VIII
Contains the binding template for the EU declaration of conformity (Regulation (EU) 2025/40)
5 / 10 years
Retention period from placing on the market, single-use and reusable packaging respectively
12 Feb 2027
By this date Member States must have laid down and implemented rules on penalties (Art. 68 PPWR)
10 days
Time to provide authorities with the documents electronically on a reasoned request (Art. 15(10) PPWR)
Key point: The obligation has been running since August 2026, and you have to be able to produce the evidence for up to ten years.
Implementing this with Narravero
Narravero runs an end-to-end DPP platform. More than 200 business customers across 12 industries use it. It handles 300m DPP requests per month, EU-hosted and GDPR compliant.
For the PPWR that means one versioned record per packaging type, holding the declaration of conformity, the technical documentation and supplier evidence together with a traceable change history. The data arrives through open interfaces from the systems where it is created anyway, instead of being maintained in a separate spreadsheet. Our PPWR software shows what that looks like.
Thomas L. Rödding, founder and CEO of Narravero, is personally involved as Co-Chair of CEN-CENELEC JTC 24 and as Vice Chairman in German standardisation at DIN and DKE, the bodies shaping the technical framework for the Digital Product Passport in Europe. That involvement gives him a precise sense of how product and packaging data have to be structured to serve several sets of rules at once.
Key point: One record per packaging type with a version history turns the declaration into something repeatable rather than a one-off project.
Frequently asked questions about the PPWR declaration of conformity
What is the PPWR declaration of conformity?
The PPWR declaration of conformity is a written document in which the manufacturer declares, under Article 15 in conjunction with Article 39 of Regulation (EU) 2025/40 and under its own responsibility, that a piece of packaging meets the applicable requirements of the regulation.
Since when has the PPWR declaration of conformity been mandatory?
Since 12 August 2026 the manufacturer has had to carry out a conformity assessment before placing packaging on the market and issue the declaration where the packaging meets the applicable requirements; there is no transition period for the document itself.
Who has to issue the PPWR declaration of conformity?
It has to be issued by the manufacturer within the meaning of Article 3(1)(13), which is whoever manufactures the packaging or has it designed or manufactured under their own name or trademark; the obligation itself sits in Article 15.
Do I need a separate declaration for every piece of packaging?
Under Annex VII point 4 the manufacturer draws up the declaration for each packaging type, not for each individual item and not for each packed product; the declaration has to identify the packaging it was drawn up for.
Does the PPWR declaration of conformity need a notified body?
The conformity assessment procedure under Annex VII does not generally provide for a notified body; the template in Annex VIII does include a field for one, where such a body is relevant in a given case.
Does a CE marking go on the packaging?
No, the PPWR does not provide for CE marking on packaging, even though it follows the familiar pattern of EU product law with a conformity assessment and an EU declaration of conformity.
How long do I have to retain the PPWR declaration of conformity?
The declaration and the technical documentation have to be retained for five years after the packaging has been placed on the market, and ten years in the case of reusable packaging.
What belongs in the technical documentation under Annex VII?
It includes a general description of the packaging and its intended use, designs, manufacturing drawings and materials of components, a list of the standards and specifications applied, a qualitative description of the assessments under Articles 6, 10 and 11, the test reports, and an analysis and assessment of the risks of non-conformity.
What happens if the declaration is missing or wrong?
The market surveillance authorities can challenge the packaging, require corrections and restrict its availability on the market; under Article 68 the Member States must have laid down and implemented their rules on penalties by 12 February 2027.
Does the PPWR require a Digital Product Passport for packaging?
No, the PPWR does not require a Digital Product Passport for packaging; where Union law requires a data carrier for the packed product, Article 12(5) requires a single data carrier to be used for the product and the packaging information, such as a QR code or another standardised, open digital data carrier, with both sets of information easily distinguishable.
Does the obligation apply to importers and distributors as well?
Importers do not issue the declaration themselves but have to check under Article 18 that the manufacturer carried out the conformity assessment, keep a copy of the EU declaration of conformity and make sure the technical documentation can be made available on a reasoned request; distributors have a graduated duty of care under Article 19.
Are there exemptions for small companies?
Under Article 3(1)(13)(b) the packaging supplier rather than the own-brand company counts as the manufacturer where that company is a microenterprise and the supplier is established in the same Member State; Article 15(12) provides for a similar shift attaching to establishment in the Union, and in neither case does the obligation disappear, it changes hands.