Annex VIII to the PPWR – how to complete the declaration field by field

Annex VIII to the PPWR – what fields does the declaration contain?

The official structure of the declaration includes eight consecutive points, followed by a signature block.

Before completing Annex VIII, complete the conformity assessment

The declaration is the final stage of the process, not a form that starts the assessment.

In accordance with Articles 15, 38 and 39, the relevant process is as follows:

packaging identification → PPWR requirements → data and evidence → technical documentation → conformity assessment procedure → demonstration of conformity → EU declaration of conformity.

Before opening the Annex VIII model, you should therefore know at least:

• the relevant manufacturer,
• the precise type or range of packaging covered by the declaration,
• the current version of the packaging,
• the applicable requirements,
• the technical basis for the assessment,
• the standards or specifications actually used in the process.

Heading: “EU Declaration of Conformity No. …” – which number should you enter?

The heading of Annex VIII provides for the identification number of the declaration itself.

PPWR does not impose a single central numbering format on undertakings.

A company may therefore create its own system, for example:

• PPWR/2026/0042,
• DOC-PKG-0042-V1,
• EU-DOC/BOX400/2026/01.

These are organisational examples, not formats imposed by the Regulation.

A good declaration number should primarily make it possible to:

• locate the document unambiguously,
• distinguish it from other declarations,
• control its version,
• link it to the relevant technical documentation.

Point 1 of Annex VIII – unique identification of the packaging

Point 1 is worded in the structure of Annex VIII as a number for the purpose of uniquely identifying the packaging.

This is not the same field as the declaration number in the header.

Example:

The identifier may be the company’s packaging type code, provided that it genuinely makes it possible to establish unambiguously what the declaration concerns.

Must SKU, EAN or GTIN be entered in point 1?

Annex VIII does not specify SKU, EAN or GTIN as a mandatory format for point 1.

An existing company code may be used if it genuinely identifies unambiguously the packaging covered by the declaration.

However, care is needed in two situations:

• several SKUs may use exactly the same type of packaging,
• one SKU may consist of several different packaging components.

Therefore, an SKU should not automatically be treated as the unit of PPWR documentation.

Point 2 – name and address of the manufacturer

Point 2 must state the name and address of the manufacturer and, where applicable, of its authorised representative.

It is essential to use the correct role.

The following should not be entered here automatically:

• the EPR producer,
• the distributor,
• the wholesaler,
• the laboratory,
• the material supplier.

First, it must be established who is the manufacturer within the meaning of PPWR for that specific packaging.

Example:

Przykład Packaging Sp. z o.o.
ul. Przemysłowa 10
00-001 Warszawa
Poland

The data are fictitious and are used solely to show the structure.

When is an authorised representative entered in point 2?

An authorised representative is a formal role defined in Article 17 of PPWR.

You should not simply enter the name of the employee who signs the declaration here.

If the manufacturer has appointed a formal authorised representative by means of a written mandate and this applies in the given case, its details may be provided in accordance with the template.

If there is no such representative, one should not be created artificially merely to complete the field.

Point 3 – statement of the manufacturer’s sole responsibility

Point 3 establishes a very important principle: the declaration is issued under the sole responsibility of the manufacturer.

This is not a field for a freely drafted marketing statement.

The wording of the statement should correspond to the model in Annex VIII:

this declaration of conformity is issued under the sole responsibility of the manufacturer.

This is consistent with Article 39(4), according to which, by drawing up the declaration, the manufacturer assumes responsibility for the compliance of the packaging with the applicable requirements.

Point 4 – subject matter of the declaration and description of the packaging

Point 4 should describe the subject matter of the declaration in a way that enables its traceability.

The official model requires a description of the packaging.

A practical description may include, for example:

• type of packaging,
• technical name,
• company code,
• dimensions,
• main material,
• design version,
• other features needed to distinguish the variant.

Example:

Flap transport carton, corrugated board, 400 × 300 × 250 mm, code PKG-K400-V2.

However, there is no single mandatory set of characteristics such as “material + mass + dimensions” for every packaging item. The description should primarily enable the subject matter of the declaration to be identified.

Must point 4 include a batch or series number?

Annex VIII does not establish a universal obligation to enter the batch number of every product specifically in point 4.

A batch number, series number or other identifier may be very useful if it forms part of the traceability system for the packaging concerned.

However, it should not be presented as a mandatory element of every form, regardless of how the packaging type is managed.

The key objective is:

the authority or business partner should be able to determine which packaging the document concerns.

Point 5 – with which Union legislation do you declare compliance?

Point 5 states that the subject matter described in point 4 complies with the relevant Union harmonisation legislation, together with references to other Union acts applied.

The primary reference for a PPWR declaration will be Regulation (EU) 2025/40.

Example structure:

Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste – with regard to the requirements applicable to the subject matter of this declaration.

If the packaging is subject to other Union acts requiring an EU declaration of conformity, Article 39 allows a single declaration to be drawn up covering all such acts.

Can a PPWR declaration cover other EU legal acts?

Yes – if the packaging is subject to several Union acts requiring an EU declaration of conformity, Article 39 provides for the possibility of drawing up a single declaration.

Such a document should enable the relevant acts and their publications to be identified.

However, this does not mean that every regulation with any connection to the product must automatically be added to point 5.

First, it should be established:

• whether the act concerned applies,
• whether it requires an EU declaration of conformity,
• whether the company actually includes it in the joint declaration.

Point 6 – harmonised standards and technical specifications

Point 6 is used to indicate harmonised standards, common specifications or other technical specifications against which conformity has been declared.

This is not the place for a list of all standards found on the internet for a given material.

The entry should correspond to what was actually used in the technical documentation and the assessment procedure.

Example structure:

[number and title of the standard/specification] – applied in relation to [indicate scope].

If the relevant Commission acts, harmonised standards or common specifications are updated later, the impact of the change on the documentation and the declaration must be checked.

What should not be entered in point 6?

The most common mistake is creating an ‘impressive’ list of standards that the company has not actually applied.

Do not automatically include:

• standards merely because they concern packaging,
• laboratory methods that have not been used,
• supplier certificates unrelated to the requirement being assessed,
• future specifications that do not apply to the scope concerned.

If a standard is indicated in the declaration, the technical documentation should show how it was actually used.

Point 7 – notified body. Does it need to be included in the declaration of conformity under the PPWR?

Point 7 begins with the condition: ‘where applicable’.

If a notified body was involved in the relevant procedure, indicate:

• its name,
• address,
• number,
• a description of the intervention performed,
• information on the certificate issued,
• the date of the certificate,
• where applicable, the period and conditions of its validity.

The basic PPWR procedure in Annex VII is based on internal production control and does not create a general obligation to involve a notified body for every ordinary package.

Therefore, in a typical case, this field may not be applicable.

From a practical perspective, you can retain the numbering and enter:

‘Not applicable’.

This is good practice for readability, not additional wording required by the PPWR.

Point 8 – additional information

Point 8 is not merely a signature field. Officially, it is intended for additional information.

If the company has information that helps to understand the scope of the declaration, it may include it here.

A practical example may be a reference to the internal version of the technical documentation:

Technical documentation: TD-PKG-K400, rev. 2.

Such a reference may be very useful for organisational purposes, but it is not a separate mandatory field in Annex VIII.

If the company has no additional information, it can clearly indicate that the field is not applicable.

Signature block – what comes after point 8?

After point 8, Annex VIII provides for a separate signature block.

It includes:

• ‘Signed for and on behalf of’ – identification of the relevant entity,
• place of issue,
• date of issue,
• name and surname,
• the function or position of the signatory,
• signature.

The PPWR does not specify that the signatory must be the managing director.

However, the company should ensure that the declaration is signed by a person properly acting on behalf of the manufacturer in accordance with the adopted representation rules and the organisation’s procedure.

Who signs the declaration of conformity in Annex VIII?

The declaration is the manufacturer’s declaration, but it is signed by a specific natural person acting on its behalf.

Depending on the organisation and representation rules, this may be, for example:

• member of the management board,
• business owner,
• quality director,
• quality manager,
• compliance manager,
• another duly authorised person.

Annex VIII does not assign the signature to one specific position.

What does Annex VIII not require as a separate mandatory field?

Many items of information may be relevant to the PPWR, but this does not mean that each of them must appear on the first page of the declaration.

Annex VIII does not establish separate mandatory fields entitled:

• BDO number,
• EPR registration number,
• SKU,
• GTIN or EAN,
• recycled content percentage,
• recyclability grade,
• PFAS result,
• heavy metal test result,
• number of each laboratory report,
• full material composition,
• list of all suppliers.

Some of this information may be needed in the technical documentation, may assist identification or may become relevant for other obligations. However, it should not be presented as additional fixed Annex VIII fields.

Must laboratory report numbers be included in the PPWR declaration?

Annex VIII does not create a separate mandatory field for a list of all laboratory reports.

Reports primarily constitute evidence in the technical documentation under Annex VII.

The company may, of course, decide to provide an additional reference if it improves the clarity of the system, but the declaration should not turn into a multi-page register of tests.

A better relationship is:

declaration → technical documentation → requirement → report.

Annex VII and Annex VIII – what not to confuse?

A declaration without a technical basis is a problem. Conversely, technical documentation alone does not replace the final declaration required by Article 39.

Can one declaration cover several packaging variants?

The PPWR requires the subject of the declaration to be identifiable and traceable.

This does not automatically result in a “one SKU = one declaration” rule.

If several variants genuinely fall within one clearly defined assessment scope and can be identified unambiguously in the declaration, the scope of the document may be defined accordingly.

However, the company should ensure that grouping does not lead to a situation where:

• different materials are treated as identical,
• different designs have different assessment results,
• it cannot be determined whether a specific variant was actually covered by the technical documentation.

Traceability of the scope is key, not minimising the number of PDFs at all costs.

In which language should a PPWR declaration of conformity be drawn up?</h2>

Article 39 provides that the EU declaration of conformity should be translated into the language or languages required by the Member State in which the packaging is made available on the market. </p>

When selling in several EU countries, you should not therefore automatically assume that one Polish version will be suitable everywhere. </p>

In the documentation system, it is advisable to distinguish between: </p>

• the substantive version of the declaration,
• language versions,
• the markets for which a given version is used.
</ul> </section>

How should a declaration of conformity under Annex VIII be versioned?</h2>

The declaration should remain up to date. </p>

Therefore, a good system records: </p>

• the declaration number,
• the version number,
• the issue date,
• the packaging identifier,
• the version of the technical documentation,
• the reason for the change,
• the approving person,
• the withdrawal date of the previous version.
</ul>

An old document should not be overwritten with a new PDF bearing the same name without retaining the history. </p> </section>

A declaration from 2026 should not purport to be a declaration from 2030</h2>

The PPWR introduces requirements in stages. </p>

This means that the scope of the technical assessment and the basis for the declaration may change as further requirements start to apply, such as: </p>

• harmonised labelling,
• Design for Recycling,
• minimum recycled content,
• further criteria resulting from delegated and implementing acts.
</ul>

You should not state: </p>

“the packaging meets all PPWR requirements until 2040.” </p>

if future criteria, methods or obligations have not yet been assessed under the applicable regime. </p>

The declaration should be a document updated together with the compliance system. </p> </section>

Example of completing Annex VIII to the PPWR</h2>

The following example shows the document structure for a fictional transport carton. It is not a ready-made conformity assessment for a specific product and does not replace technical documentation. </p>

How to check the declaration before signing?

Before finalising, it is worth carrying out a simple formal check.

Check	Question
Declaration number	Does the document have a unique identifier?
Point 1	Does the identifier indicate the correct packaging?
Point 2	Has the correct manufacturer been identified?
Point 3	Has the statement of responsibility been retained?
Point 4	Can the item be clearly identified?
Point 5	Have the relevant EU acts been indicated?
Point 6	Have the stated standards actually been applied?
Point 7	Did a notified body actually participate?
Point 8	Is the additional information up to date?
Signature	Is the appropriate person signing on behalf of the manufacturer?

Most common mistakes when completing Annex VIII to the PPWR

• confusing the declaration number with the packaging identifier in point 1;
• entering the EPR producer instead of the actual manufacturer;
• automatically entering the importer as the manufacturer;
• an overly general description such as “cardboard packaging” in point 4;
• regarding an SKU as a mandatory identification format;
• treating the batch number as a mandatory Annex VIII field in every case;
• adding all possible EU acts without analysing their scope;
• citing standards that have not been applied;
• entering an arbitrary laboratory as a notified body;
• regarding point 8 as merely a signature block;
• entering the results of all tests unnecessarily;
• adding a BDO or EPR number as a mandatory element of the template;
• drawing up the declaration before the technical documentation is complete;
• no version control for the declaration;
• leaving an old version active after a change affecting compliance.

Annex VIII to the PPWR – checklist before issuing the declaration

1. Establish the correct manufacturer.
2. Identify the exact subject of the declaration.
3. Check the current version of the packaging.
4. Complete the technical documentation in Annex VII.
5. Carry out the appropriate conformity assessment procedure.
6. Confirm that conformity has been demonstrated.
7. Assign a declaration identifier.
8. Enter the packaging identification in point 1.
9. Enter the correct manufacturer in point 2.
10. Verify whether there is an authorised representative.
11. Retain the statement in point 3.
12. Describe the subject of the declaration precisely in point 4.
13. In point 5, indicate the EU acts that actually apply.
14. In point 6, enter only the standards and specifications applied.
15. Verify whether point 7 applies.
16. Complete the additional information in point 8, if needed.
17. Check the place and date.
18. Indicate the signatory’s first name, surname and function.
19. Sign the document on behalf of the correct manufacturer.
20. Link the declaration to the version of the technical documentation.
21. Archive the signed version and control subsequent changes.

How can declarations of conformity under Annex VIII be automated?

For a few documents, the form can be completed manually.

For several hundred packages, controlling the data source becomes a greater challenge than generating the PDF itself.

Each declaration field should come from a controlled record, rather than being copied manually from a previous document.

The system can store:

• declaration number,
• packaging identifier,
• manufacturer,
• subject description,
• applicable legal acts,
• standards and specifications,
• technical documentation version,
• approving person,
• date of issue,
• version history.

When the material or assessment basis changes, the system should indicate which declarations require review again.

How do you complete Annex VIII to the PPWR correctly?

The key is to retain the logic of the official template and not transfer random data from the technical documentation into it.

The heading identifies the declaration. Point 1 identifies the packaging. Point 2 indicates the manufacturer. Point 3 establishes its sole responsibility. Point 4 describes the subject of the declaration. Points 5 and 6 indicate the legal and technical basis. Point 7 is used if the relevant notified body actually participated in the procedure. Point 8 is for additional information.

Only then does the signature block appear.

The overall logic should be:

packaging → technical documentation → conformity assessment → Annex VIII → signature → versioning and updating.

FAQ – Annex VIII to the PPWR and the declaration of conformity

What must a PPWR declaration of conformity contain?

The declaration should follow the structure of Annex VIII: it should contain the identification of the declaration and packaging, manufacturer details, a statement of responsibility, a description of the subject, applicable EU acts, standards or specifications applied, information on the notified body – where applicable – additional information and a signature block.

What should be entered in point 1 of Annex VIII?

Point 1 is for the unique identification of the packaging. This may be a company type code or another identifier that makes it possible to link the declaration unambiguously to the packaging. It should not be confused with the number of the declaration itself in the heading.

Must the PPWR declaration include an SKU or batch number?

Annex VIII does not establish an SKU or batch number as a universally mandatory format. They may be used as an element of traceability if they genuinely help to identify the subject matter of the declaration unambiguously.

Must point 7 on the notified body always be completed?

Point 7 applies conditionally. The basic PPWR procedure under Annex VII is based on internal production control, and the PPWR does not establish a general obligation for a notified body to be involved for every ordinary packaging item.

Who signs the declaration of conformity under Annex VIII?

The declaration is signed by a person acting on behalf of the relevant manufacturer. Annex VIII requires the name, function and signature, as well as the place and date of issue. The PPWR does not specify a single mandatory position, such as the president of the management board.

Sources

Legal basis: Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste – EUR-Lex

European Commission guidelines: Commission Notice C/2026/3084 – Guidelines on Regulation (EU) 2025/40

The article draws in particular on:

• Article 15 – obligations of the manufacturer,
• Article 17 – authorised representative,
• Article 38 – conformity assessment procedure,
• Article 39 – EU declaration of conformity, its updating, language and the manufacturer’s responsibility,
• Annex VII – technical documentation and internal production control,
• Annex VIII – model EU declaration of conformity.

This article is for information purposes and does not constitute individual legal advice. Example numbers, company names and field descriptions are illustrative. The declaration for a specific packaging item should correspond to its actual technical documentation, applicable requirements and the current state of the law.