PPWR declaration of conformity – a complete guide for businesses

What is a PPWR declaration of conformity?

The EU declaration of conformity is the final formal document of the packaging conformity assessment procedure.

Article 39 of the PPWR states that the declaration shall state that compliance with the relevant requirements laid down in or pursuant to Articles 5 to 12 has been demonstrated.

This does not mean, however, that every declaration is identical.

Its actual basis depends, among other things, on:

• the type of packaging,
• its materials,
• its intended use,
• the design version,
• the requirements applicable at the relevant time,
• the evidence used to demonstrate conformity.

From when is a PPWR declaration of conformity required?

Regulation (EU) 2025/40 entered into force on 11 February 2025 and generally applies from 12 August 2026

From the latter date, the system of obligations for economic operators set out, among other things, in Articles 15 to 22, as well as the conformity assessment procedure under Articles 38 to 39, becomes relevant.

This does not mean, however, that all detailed technical requirements of the PPWR became applicable on the same day.

Some obligations – including detailed design for recycling criteria, minimum recycled content levels, certain minimisation requirements and harmonised labelling – have been phased in over later years or made dependent on the adoption of delegated or implementing acts.

A PPWR declaration should cover the requirements actually applicable

The declaration should not be treated as a statement that “the packaging complies with everything the PPWR will require until 2040”.

The scope of the assessment should correspond to:

• the specific type of packaging,
• its use,
• the current design version,
• the requirements applicable at the time of assessment and placing on the market.

For example, packaging should not be assigned a final recyclability performance grade in 2026 under a methodology that is only to apply after the relevant criteria have been published.

The declaration and technical documentation should subsequently be updated in line with the PPWR timetable.

Who draws up the PPWR declaration of conformity?

The primary responsibility lies with the manufacturer within the meaning of the PPWR.

Article 15 requires the manufacturer to carry out or have carried out the appropriate conformity assessment procedure, draw up technical documentation and, once conformity has been demonstrated, draw up the EU declaration of conformity.

Therefore, a company’s first question should not be:

“Who will complete the form for us?”

but:

“Who is the manufacturer of this specific type of packaging?”

Manufacturer and PPWR producer – a key distinction

The Polish version of the PPWR uses two different terms which should not be treated as synonyms.

The European Commission, in its 2026 guidance, expressly confirms that the roles were created for different purposes.

One company may perform both roles at the same time, but this does not mean that the terms mean the same thing.

Private label and own brand – who prepares the PPWR declaration?

A company does not need to physically manufacture packaging to become its manufacturer.

If it commissions the design or manufacture of packaging or a packaged product under its own name or trade mark, it may be considered the manufacturer in accordance with Article 3.

In practice, you need to check:

• who orders the design,
• who sets the specification,
• under whose brand the packaging or product is manufactured,
• whether the special rule for microenterprises applies.

Documentation from the contract manufacturer may be a very important source of evidence, but outsourcing physical manufacture does not automatically mean outsourcing the role of manufacturer.

Microenterprise exception for own brands

The PPWR provides for a special rule where the entity ordering packaging under its own name or trade mark is a microenterprise and the packaging supplier is located in the same Member State.

Where the conditions are met, the packaging supplier may then be the manufacturer.

However, this is not a general exemption for every small company.

Microenterprise status and the other conditions must be verified for the specific case.

Does an importer issue a PPWR declaration of conformity?

Not solely by virtue of being an importer.

Article 18 requires that, before placing packaging from a third country on the market, the importer verifies, among other things, whether the manufacturer has:

• carried out the appropriate conformity assessment procedure,
• drawn up the technical documentation,
• drawn up the EU declaration of conformity,
• fulfilled the relevant identification obligations.

The importer therefore has its own regulatory responsibility, but this does not automatically mean replacing the manufacturer in the declaration.

Does a distributor need its own PPWR declaration?

Not solely by virtue of further selling the packaging.

Article 19 requires the distributor to act with due care.

Before making packaging available, it should verify the relevant elements of compliance and should not continue to make the product available if it has reason to believe that it is non-compliant.

However, a distributor may assume another role if it starts modifying the packaging or placing it on the market under its own name.

When does an importer or distributor assume the manufacturer’s obligations?

Article 21 is particularly important for importers, own brands and retail chains.

An importer or distributor may be treated as the manufacturer if it:

• places packaging on the market under its own name or trade mark, or
• modifies packaging already placed on the market in a way that may affect its compliance.

The declaration analysis must then be carried out from the perspective of the manufacturer’s obligations.

PPWR certificate and EU declaration of conformity

The PPWR does not establish a single mandatory ‘PPWR certificate’ that every company must obtain from an external body.

The basic model is:

technical documentation → internal production control → conformity assessment → EU declaration of conformity.

External certificates, reports and certificates may constitute evidence in the technical documentation.

However, they should not automatically be treated as a substitute for the formal declaration under Article 39.

How to prepare a PPWR declaration of conformity step by step?

1. Determine whether the product is packaging within the meaning of the PPWR.
2. Identify the specific type and version of the packaging.
3. Determine the relevant manufacturer.
4. Identify the PPWR requirements applicable at the relevant time.
5. Collect information on materials and components.
6. Collect documents from suppliers.
7. Carry out an analysis of the risk of non-compliance.
8. Determine the evidence and any testing required.
9. Prepare the technical documentation.
10. Carry out the appropriate conformity assessment procedure.
11. Ensure that series production complies with the documentation.
12. Once conformity has been demonstrated, prepare Annex VIII.
13. Approve and sign the declaration.
14. Link it to the relevant version of the documentation.
15. Monitor subsequent legal and technical changes.

PPWR technical documentation – Annex VII

The declaration should have a technical basis in documentation prepared in accordance with Annex VII.

The documentation should enable conformity assessment and include an analysis and assessment of the risk of non-compliance.

Depending on the packaging, it includes, among other things:

• a general description of the packaging and its intended use,
• design and drawings,
• materials of individual components,
• explanations required to understand the construction,
• a list of the standards and specifications applied,
• a description of the solutions applied to demonstrate conformity,
• the relevant assessments provided for in Annex VII,
• test reports.

A detailed checklist of individual elements is best maintained separately as a technical dossier for the packaging type.

What documents should a packaging supplier provide?

Article 16 requires suppliers of packaging or packaging materials to provide the manufacturer with the information and documentation needed to demonstrate conformity.

Depending on the material, these may include:

• technical specifications,
• material composition,
• layer structure,
• data on coatings, adhesives and closures,
• test reports,
• data concerning substances,
• information on recycled content,
• other evidence necessary for the appropriate assessment.

A general statement that ‘the product complies with the PPWR’ may be insufficient if it is not clear what exactly it demonstrates.

Are laboratory tests required for a PPWR declaration?

There is no single mandatory package of laboratory tests for every type of packaging.

The scope should result from:

• the applicable requirements,
• the material and construction,
• the intended use,
• the risk of non-compliance,
• the quality of available supplier data.

A report may be necessary, for example, where a specific parameter relating to substances needs to be reliably confirmed.

In other cases, calculations, specifications, design assessment or other appropriate evidence may serve as the basis.

Is it necessary to test every batch before issuing a declaration?

PPWR does not establish a general obligation to laboratory test every batch of every packaging.

However, the manufacturer must ensure that series production remains in conformity with the technical documentation and the assessed type.

The frequency of checks or tests may depend on:

• risk,
• process stability,
• material variability,
• requirements of the applicable standard,
• other product-related legislation.

PPWR conformity assessment – what happens before the declaration?

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

This is an internal production control model.

The manufacturer should:

• draw up technical documentation,
• assess the relevant requirements,
• ensure conformity of the production process,
• retain appropriate evidence,
• draw up the declaration after demonstrating conformity.

A signature on the form alone does not replace this process.

What must a declaration of conformity contain – PPWR Annex VIII

Annex VIII sets out the harmonised structure of the EU declaration of conformity.

In brief, it includes:

It is worth considering the detailed completion of each field separately, as errors include confusing the declaration number with the packaging identifier.

How should packaging be identified precisely in the declaration?

The scope of the declaration must be capable of being determined unambiguously.

The system may use, among other things:

• type code,
• model,
• index,
• batch,
• series,
• other marking ensuring traceability.

The aim is not necessarily to number every individual carton or piece of film.

The aim is to enable a given packaging item to be linked to the relevant version of the documentation and declaration.

Can one PPWR declaration cover several packaging items?

PPWR does not establish a simple rule of “one file for every individual item”.

It is possible to define a scope covering several variants if:

• they are clearly identified,
• they fall within the scope of the assessment carried out,
• the technical documentation covers their characteristics relevant to conformity,
• the differences between them do not result in an uncontrolled extension of the assessment conclusions.

Grouping should result from technical equivalence, rather than solely from the desire to reduce the number of documents.

PPWR declaration and SKU – does every product need a separate one?

There is no automatic rule of “one SKU = one declaration”.

Several SKUs may use the same packaging type.

Conversely, one SKU may include several different elements:

• a bottle,
• a cap,
• a label,
• a carton,
• transport packaging.

Therefore, a better data model is:

SKU → packaging types → versions → documentation → declarations.

Who signs the PPWR declaration of conformity?

The declaration is drawn up in the name of the relevant manufacturer, while it is signed by a specific person acting on behalf of that entity.

The PPWR does not specify a single mandatory role, such as:

• chief executive officer,
• member of the management board,
• quality director,
• compliance manager.

However, Annex VIII requires the identification of the signatory, their function, the place and date, and the signature.

The company should establish internal rules for approving documents.

What does signing a PPWR declaration mean?

Article 39(4) is of fundamental importance:

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

Therefore, the declaration should not be treated as a marketing document or an automatically generated statement without a technical basis.

The signatory should be informed that the assessment procedure has been completed and that the relevant evidence has been approved.

Authorised representative and the PPWR declaration of conformity

Article 17 allows the manufacturer to appoint a formal authorised representative on the basis of a written mandate.

The Commission guidelines of 2026 indicate that the declaration may be drawn up by the manufacturer or by a duly authorised representative, within the scope provided for in the mandate.

However, this does not transfer the primary regulatory responsibility for packaging conformity from the manufacturer to the representative.

Nor should a formal authorised representative be confused with an employee of the quality department signing a document of their own company.

In which language must the PPWR declaration of conformity be drawn up?

Article 39 requires the declaration to be translated into the language or languages required by the Member State in which the packaging is made available on the market.

When selling in several EU countries, language versions must therefore also be controlled.

A well-organised system should retain:

• one approved substantive version,
• related language versions,
• a list of the markets for which they are intended,
• a revision number common to all translations.

Can one declaration cover the PPWR and other EU acts?

Yes, Article 39 provides for the possibility of drawing up a single EU declaration of conformity where the product is subject to several Union acts requiring such a declaration.

The document should then make it possible to identify all applicable acts.

However, this does not mean that every regulation concerning the product should automatically be added to the form.

First, its actual scope and declaration obligation must be established.

Must the PPWR declaration be included with every delivery?

The PPWR does not establish a general rule that a paper copy of the declaration must physically be included in every package, roll or pallet.

The document must be correctly drawn up and made available in accordance with the obligations of the individual operators.

In practice, business partners may require the declaration to be provided:

• during supplier qualification,
• via a procurement portal,
• with the first delivery,
• following a version change,
• under a contract.

Such business arrangements must be distinguished from a universal statutory obligation to attach a paper document to every consignment.

Should the customer receive the full technical documentation?

The PPWR does not establish a general obligation to automatically provide every customer with the entire technical documentation dossier set out in Annex VII.

Full documentation may include, among other things:

• confidential specifications,
• drawings,
• supplier data,
• reports,
• calculations,
• risk analyses.

However, the customer may need the declaration, technical data sheet or specific information if these are necessary to fulfil its own obligations.

Article 16 concerning the flow of information from supplier to manufacturer is particularly relevant here.

What must an importer do with a declaration from a foreign manufacturer?

The importer should keep a copy of the EU declaration of conformity and ensure that the relevant technical documentation can be made available to the competent authorities.

In practice, before commencing imports, it should verify:

• who the manufacturer is,
• whether the declaration covers exactly the imported variant,
• whether it is up to date,
• whether there is a technical basis for issuing it,
• whether the documents will be available in the event of an inspection.

A one-page file entitled “PPWR Certificate” without the possibility of verifying its basis should not automatically conclude the import process.

How long should a PPWR declaration of conformity be retained?

The PPWR distinguishes between two periods depending on the nature of the packaging.

The period should be applied in accordance with the rules relating to the placing of the relevant packaging on the market.

Five or ten years is a retention period, not a period of guaranteed “validity” of the declaration.

When must a PPWR declaration of conformity be updated?

The declaration should remain up to date in relation to the packaging and the basis for its assessment.

Changes requiring review may include:

• new material,
• new supplier,
• change in composition,
• different coating or adhesive,
• change of colourant,
• change in recycled content,
• new closure,
• design modification,
• change in the standard or specification forming the basis for the assessment,
• start of application of a further PPWR requirement.

Not every cosmetic change automatically requires a new declaration.

However, it should be assessed whether it may affect conformity, the scope of the document or its identification.

How should PPWR declarations be versioned?

A good system should make it possible to trace:

packaging → design version → documentation version → declaration version → period of application.

Old versions should not be overwritten if they concern packaging previously placed on the market and are still subject to retention.

The PPWR declaration will change with subsequent stages of the Regulation

PPWR is a regulation implemented in stages.

For a company, this means the need to monitor, among other things:

• new delegated acts,
• implementing acts,
• harmonised standards,
• common specifications,
• Design for Recycling deadlines,
• recycled content levels,
• minimisation requirements,
• labelling,
• reuse.

Therefore, a declaration correctly drawn up in 2026 should not automatically be considered an unchanging document until 2040.

What must be shown during a PPWR inspection?

The authority may need not only the final declaration, but also the basis enabling its correctness to be verified.

The company should be able to reconstruct:

• the specific packaging type and version,
• the relevant manufacturer,
• the requirements covered by the assessment,
• the technical documentation,
• supplier reports and data,
• the result of the conformity assessment,
• the relevant version of the declaration,
• the history of subsequent changes.

A PDF file alone, without the ability to explain the basis on which it was signed, is not a well-designed conformity system.

What should be done if non-compliance is detected after the declaration has been issued?

Non-compliance should not be ‘remedied’ solely by editing the content of the declaration.

It is first necessary to assess:

• what the issue concerns,
• which versions and batches may be affected,
• whether the packaging has already been placed on the market,
• which corrective actions are necessary,
• whether further making available needs to be restricted,
• whether the relevant authorities need to be informed.

Only after the issue has been resolved should the technical and formal parts of the system be updated accordingly.

How should the PPWR declaration process be organised within a company?</h2>

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