PPWR certificate or declaration of conformity?

Is there an official ‘PPWR certificate’?

The PPWR does not establish a single official document called a ‘PPWR certificate’ that every company must obtain before placing packaging on the market.

Under the Regulation, the mechanism for demonstrating conformity is based primarily on:

• meeting the relevant packaging requirements,
• drawing up technical documentation,
• carrying out the conformity assessment procedure,
• ensuring that production conforms to the documentation,
• drawing up the EU declaration of conformity.

Private services, audits, reports or commercial documents referred to as a ‘PPWR certificate’ may, of course, be available on the market. However, their value should be assessed based on their scope and what they actually confirm.

The name ‘certificate’ alone does not give a document the status of the formal declaration of conformity required by the Regulation.

PPWR certificate vs EU declaration of conformity – the key difference

What does the correct PPWR compliance process look like?

The easiest way to understand the difference between a certificate and a declaration is to look at the sequence of actions.

requirements → technical data → evidence → technical documentation → conformity assessment → EU declaration of conformity.

The declaration therefore comes at the end of the process. It should not be its starting point.

A company should not first generate a declaration and then consider which documents can substantiate it. Conformity must first be demonstrated, and only then declared.

What is an EU declaration of conformity under PPWR?

An EU declaration of conformity is a formal document in which the manufacturer confirms that compliance with the relevant requirements of PPWR for the packaging concerned has been demonstrated.

Article 39 states that the declaration must include a statement that compliance with the applicable requirements laid down in or pursuant to Articles 5 to 12 has been demonstrated.

Its structure is set out in Annex VIII.

The declaration should enable unambiguous identification of the packaging to which it relates. A document referring generally to “all company packaging” may be problematic if the company cannot demonstrate exactly which types and versions were covered by the assessment.

Who issues a PPWR declaration of conformity?

The manufacturer within the meaning of PPWR has a key role.

In accordance with Article 15, before placing packaging on the market, the manufacturer carries out or has carried out the appropriate conformity assessment procedure and draws up the technical documentation.

After conformity has been demonstrated, the manufacturer draws up the EU declaration of conformity.

Therefore, the question:

“Who should issue the certificate?”

should be replaced with:

“Who is the manufacturer responsible for the assessment and declaration for this type of packaging?”

Signing the declaration means assuming responsibility for conformity

Article 39(4) is of particular practical importance.

By drawing up the EU declaration of conformity, the manufacturer assumes responsibility for the conformity of the packaging with the requirements of the Regulation.

This is precisely why the declaration should not be treated as an automatically generated administrative document.

The person signing on behalf of the organisation should have a basis for making such a statement, and the company should have documentation enabling it to demonstrate the validity of the declared conformity.

Technical documentation is the basis for the declaration, not an attachment “just in case”

Annex VII describes the technical documentation on which the conformity assessment is based.

Depending on the packaging, it may include, among other things:

• a description of the packaging and its intended use,
• conceptual design and drawings,
• component materials,
• descriptions needed to understand the design,
• a list of the standards and specifications applied,
• descriptions of the solutions applied to meet the requirements,
• calculation results,
• test reports,
• relevant assessments relating to PPWR requirements.

It can therefore be said that the declaration summarises the result, while the technical documentation shows why that result is justified.

PPWR conformity assessment – where does certification fit into this process?

Article 38 refers to the conformity assessment procedure set out in Annex VII.

The procedure is based on internal production control. The manufacturer prepares the technical documentation, takes measures to ensure that production conforms to the documentation, and draws up the declaration after conformity has been demonstrated.

For ordinary packaging, PPWR does not establish a general obligation to obtain a certificate from a notified body before drawing up the declaration of conformity.

This fundamentally distinguishes this model from certain product regulations, under which specific conformity assessment modules require the involvement of a third-party body.

Does a company need to hire a PPWR certification body?

The PPWR does not establish a general rule that every item of packaging must be certified by an external body before being placed on the market.

A company may, of course, use the assistance of:

• laboratories,
• testing bodies,
• consultants,
• auditors,
• external technical experts.

Their reports may increase the credibility of the evidence or help carry out a specific assessment.

However, this does not change who is responsible under the PPWR for the declaration and conformity of the final packaging type.

When can a certificate or attestation be useful?

The word ‘certificate’ alone does not mean that a document is useless.

On the contrary, a document issued by a competent body may be a valuable part of the evidence if it confirms a specific characteristic.

This may include, for example:

• a certificate concerning the origin of recycled material,
• an attestation concerning a specific raw material,
• a report on material composition,
• a laboratory report concerning a specific substance,
• a technical test result,
• an assessment of recyclability according to a specific method,
• a document confirming requirements arising from other EU legal acts.

The key question is not:

‘Is the document called a certificate?’

but:

‘What characteristic does it confirm, for which product, according to which method, and does that characteristic correspond to the PPWR requirement we want to demonstrate?’

Test report, certificate and declaration – they are not interchangeable

One document may therefore form part of another process, but they should not be treated as equivalent.

A customer asks for a ‘PPWR certificate’ – what should you tell them?

It is not advisable to automatically reply that ‘such a certificate does not exist’ and end the conversation. In a B2B relationship, the customer probably simply wants evidence that the packaging complies with the PPWR.

It is best to establish whether they need:

• an EU declaration of conformity for the finished packaging type,
• a report from a specific test,
• confirmation of material composition,
• data on recycled content,
• confirmation concerning PFAS or heavy metals,
• information needed for their own technical documentation.

This means that, instead of sending a random document bearing the word ‘certificate’, you can provide exactly what the other party needs.

How should you respond to a business partner requesting a PPWR certificate?

A business response may explain that the formal compliance document provided for by the PPWR is the EU declaration of conformity, while the documentation and reports confirming individual properties are retained as the basis for the assessment.

If you are a component supplier, the situation may be different – your business partner may primarily need technical data from you, to use in its assessment of the final packaging.

This is precisely why the response should depend on the roles of both parties in the supply chain.

Does a supplier’s declaration or certificate exempt you from carrying out your own assessment?

Not automatically.

If the supplier is the manufacturer of a finished packaging type and provides a valid EU declaration of conformity for precisely that variant, the document may be highly significant.

However, if the supplier sells only:

• raw material,
• film,
• label,
• closure,
• adhesive,
• coating,
• another component,

its documentation may be only part of the material needed to assess the final packaging.

This is why Article 16 of the PPWR requires suppliers of packaging or packaging materials to provide the manufacturer with the information and documentation necessary to demonstrate conformity.

How do you check whether a supplier’s “certificate” actually confirms anything?

For each such document, it is worth going through the same set of questions.

Importer outside the EU – a “PPWR Certificate” from a manufacturer in China may not be sufficient

The importer has its own obligations set out in Article 18.

Before placing packaging on the market, the importer should check, among other things, whether the manufacturer has carried out the appropriate conformity assessment procedure and drawn up technical documentation.

Receiving a one-page document from the supplier entitled “PPWR Compliance Certificate” should therefore not end the verification process.

The importer should check:

• who is indicated as the manufacturer,
• whether an EU declaration of conformity exists,
• whether the declaration identifies the correct packaging,
• whether technical documentation has been drawn up,
• whether the documents are up to date,
• whether the manufacturer will be able to provide the necessary evidence.

Private label – a factory certificate does not always settle the matter

In the case of packaging placed on the market under its own name or trademark, the company’s role must be determined with particular care.

If, on the basis of the PPWR definition, the company becomes the manufacturer, it cannot simply transfer responsibility to the factory by obtaining a “certificate” from it.

Factory documents may be very important evidence, but it must be determined:

• who is responsible for the final packaging type,
• who carries out the conformity assessment,
• who draws up the technical documentation,
• who draws up the EU declaration of conformity.

Is a laboratory report a PPWR certificate?

No. A laboratory report usually confirms the result of a specific test, not the overall conformity of the packaging with the PPWR.

For example, a laboratory may test:

• the content of specified substances,
• material parameters,
• strength,
• specific properties relevant to recycling,
• other parameters needed for a specific assessment.

The report may then constitute one of the items of evidence in the technical documentation.

The manufacturer combines the individual items of evidence into a full conformity assessment of the final packaging type.

Does every package need a separate PPWR certificate?

This question already contains an incorrect assumption, as the PPWR does not establish a universal certificate for every package.

The right question is:

for which packaging type must a conformity assessment be carried out and documented, and how broadly can the subject of a single declaration be defined?

The declaration should clearly identify its subject. Several SKUs may use the same packaging type, and one product may consist of several packaging components.

Therefore, the number of declarations does not necessarily have to equal the number of SKUs.

What should a company keep instead of a single “PPWR certificate”?

A well-prepared system should make it possible to quickly retrieve the entire chain of evidence.

For a specific packaging type, it is worth having access to:

• the current EU declaration of conformity,
• technical documentation,
• material specifications,
• drawings and design information,
• laboratory reports,
• material certificates or inspection certificates, where applicable,
• supplier documents,
• information on the standards and methods used,
• the history of design changes,
• the version of documentation applicable to the given product version.

Does voluntary PPWR certification make sense?

It may make business sense if its scope is clearly defined.

An external assessment may help to:

• verify the completeness of the process,
• identify documentation gaps,
• check a specific technical property,
• increase the confidence of business partners,
• prepare the company for an inspection.

However, the scope of such a service must be checked very precisely.

A document confirming an audit of the company’s procedure is not automatically a declaration of conformity for a specific bottle, carton or film.

Most common mistakes relating to a “PPWR certificate”

• searching for a single certificate instead of establishing a conformity assessment process;
• regarding a report from one test as confirmation of all PPWR requirements;
• confusing a supplier declaration with your own declaration of conformity;
• having a document without identification of the specific packaging;
• lacking technical documentation supporting the declaration;
• using an outdated report after a material change;
• assuming that an external certificate transfers responsibility to the body that issued it;
• confusing documents required under other EU legislation with a PPWR declaration;
• accepting a document entitled “PPWR Certificate” without checking its scope;
• issuing a declaration before collecting the evidence.

PPWR certificate or declaration – checklist for your company

1. Identify the specific packaging type.
2. Determine who is its manufacturer within the meaning of the PPWR.
3. Determine the applicable requirements.
4. Collect information from suppliers.
5. Review reports, certificates and specifications.
6. Determine exactly what each document confirms.
7. Link each piece of evidence to the relevant packaging type and version.
8. Prepare technical documentation.
9. Carry out the appropriate conformity assessment procedure.
10. Ensure production conforms to the documentation.
11. Once conformity has been demonstrated, draw up the EU declaration of conformity.
12. Do not replace the declaration with an arbitrary “PPWR certificate”.
13. Monitor changes in materials, design and suppliers.

When is it worth automating PPWR declarations and documentation?

For a few packaging types, files can be managed manually. The problem begins with a larger number of variants, suppliers, tests and design changes.

The key is not simply the ability to generate a declaration, but maintaining the link between the declaration and the documents that support it.

The system should enable the following flow:

packaging → version → requirement → supplier document → report → assessment → technical documentation → declaration of conformity.

PPWR certificate or declaration of conformity – what is actually needed?

The formal document completing the conformity assessment process provided for by the PPWR is the EU declaration of conformity, not a universal “PPWR certificate”.

However, the declaration does not stand on its own. It must be based on technical documentation and evidence demonstrating compliance with the applicable requirements.

Certificates, inspection certificates and reports can be highly valuable, but their significance depends on their scope. A document concerning recycled content confirms recycled content. A PFAS report confirms the result of a specific analysis. A material certificate may confirm a specific property of the material.

None of them should automatically be regarded as a substitute for the entire conformity assessment of the final packaging.

FAQ – PPWR certificate and declaration of conformity