When must the PPWR declaration of conformity be updated?

Does a PPWR declaration of conformity have an expiry date?

PPWR does not establish a single calendar validity period for a declaration, such as 12 months, 3 years or 5 years.

A declaration does not expire automatically merely because a specified number of months has passed since it was signed.

Its validity depends primarily on whether:

• it still concerns the same packaging,
• its characteristics relevant to conformity have not changed,
• the technical basis for the assessment remains appropriate,
• applicable legislation has not changed the scope of the required assessment,
• the indicated standards and specifications remain appropriate.

This should not be confused with the document retention period.

5 years for single-use packaging and 10 years for reusable packaging are retention periods, not the expiry date of the declaration.

What is the main trigger for updating a PPWR declaration?

Article 15 of PPWR requires the manufacturer to maintain conformity of production and to duly take account of changes that may affect the previous assessment.

Of particular importance are changes to the design or characteristics of the packaging and changes to harmonised standards, common specifications and other technical specifications forming the basis for demonstrating conformity.

Therefore, it is best to adopt one control question:

After this change, can we still, on the basis of current evidence, demonstrate exactly the same as we declared previously?

If the answer is “no”, “we do not know” or “only partially”, a reassessment must be initiated.

Three levels of change – when should documentation be updated, and when the declaration?

Change of packaging material – when must the declaration be updated?

A change of material is one of the strongest triggers for reassessment.

It may affect, at the same time:

• substances present in the packaging – Article 5,
• recyclability – Article 6,
• recycled content – Article 7, where applicable,
• compostability,
• minimisation – Article 10,
• reuse – Article 11,
• material labelling – once the relevant provisions start to apply.

Switching from paper to plastic, from PET to PP, or from a mono-material to a multi-material structure may change not only an individual report, but the entire set of applicable requirements.

In such a case, the existing declaration should not simply be copied and one material name changed.

Does a change of supplier always require a new PPWR declaration?

PPWR contains no literal rule that “new supplier = always new declaration”.

However, a change of supplier is a very important change-control trigger, as it may alter:

• the material specification,
• the formulation,
• the source of raw materials,
• the type of additives,
• the recycled content level,
• the coating,
• inks or pigments,
• laboratory evidence.

Therefore, before approving a new supplier, its material must be compared with the material previously assessed.

New supplier but “the same material” – what needs to be done?

Assume:

• the previous supplier provided PET with code A,
• the new supplier offers PET with an identical declared specification,
• the mass, dimensions and construction of the packaging do not change.

The term “PET” alone is insufficient to consider both materials equivalent.

The following must be checked, among other things:

• material grade and parameters,
• composition and additives,
• recycled content,
• colourants,
• substance documentation,
• test reports,
• the impact on the previous assessment.

If equivalence is demonstrated reliably, it may be concluded that the result of the conformity assessment remains unchanged.

However, the technical documentation must be updated with the new data.

If the content of the declaration itself, the identification of the packaging, the standards applied and the scope of assessment remain correct, PPWR does not impose an automatic obligation to create a new document solely because of the supplier’s name.

However, the company’s internal procedure may provide for a new revision to ensure audit clarity.

Change of packaging grammage or mass

A change in mass may be particularly relevant to the minimisation assessment.

If the grammage of cardboard changes from 450 g/m² to 400 g/m², this may affect:

• strength,
• product protection,
• compression tests,
• transport,
• the assessment result under Article 10.

Conversely, an increase in grammage should be assessed as to whether the additional mass is functionally justified.

First, the technical data are updated and the previous minimisation justification is reviewed. If the result or description of the assessed type changes, the declaration is updated as well.

Change of packaging dimensions – does it affect the declaration?

It may.

A change in dimensions may affect volume, functionality, minimisation and – in relevant categories – empty space.

Example:

the carton was increased from 300 × 200 × 150 mm to 350 × 250 × 200 mm without changing the product.

Such a change should not be treated as a simple drawing revision.

The design rationale and the applicable requirements need to be reviewed.

Change of adhesive – small component, major impact on PPWR

Adhesive may affect both the assessment of substances and the recycling process.

A change of supplier or adhesive formulation should therefore trigger the following questions:

• has the composition changed,
• are other substances present,
• does the adhesive affect the separation of components,
• does the previous recyclability assessment remain representative,
• does the previous report still cover the new formulation.

If the answer to any of these questions may be negative, the relevant part of the technical documentation must be revisited.

Change of coating or barrier layer

This is often a high-risk change.

A coating may affect:

• material share,
• recyclability,
• restricted substances,
• PFAS in the case of food-contact packaging,
• functionality and minimisation,
• the classification of the design as single- or multi-material.

A change of barrier layer should therefore at least lead to a formal impact assessment and, often, also to an update of the relevant tests and declarations.

Change of colour, ink or pigment – is an update required?

Not every colour change automatically means a new declaration.

If only the visual variant changes, and:

• the ink composition remains within the same approved specification,
• substances relevant to Article 5 do not change,
• recyclability does not change,
• the design and legally required marking do not change,

the assessment result may remain the same.

However, if a new pigment means a different formulation, its impact must be assessed rather than treating the change as “marketing only”.

A label change may affect packaging recyclability

A label may be more significant than its mass suggests.

A change to:

• the label material,
• its surface area,
• the adhesive,
• the printing technology,
• the separation method,

may affect the subsequent Design for Recycling assessment.

If the previous dossier covered a specific label, replacing it with a new version should form part of the change-control procedure.

Change of cap, closure or dispenser

A closure is part of the packaging system and may affect the assessment of the whole solution.

The change may affect:

• material share,
• separability,
• sorting,
• recyclability,
• tightness,
• mass,
• minimisation.

Therefore, “a different cap, but the same product” does not automatically mean “the same PPWR assessment”.

Change in recycled content – when does the declaration require review?

For plastic packaging, the share of recycled material will be particularly significant once the requirements of Article 7 start to apply.

A change from 0% PCR to 30% PCR or from 30% to 20% is not merely procurement information.

It may affect:

• compliance with future thresholds under Article 7,
• technical properties,
• substance data,
• chain-of-custody documentation,
• other material tests.

When the relevant recycled content requirements apply, such a change should be assessed before the modified version is further placed on the market.

Change to the production process – can the process itself require an update?

Yes, if the process change may affect a property relevant to conformity.

Examples:

• a different process temperature affecting the material structure,
• a different lamination technology,
• a change in the coating application method,
• a change in the bonding process,
• a change in printing technology,
• a new production line resulting in a different weight or thickness.

Not every machine replacement means a new declaration. If the new machine produces exactly the same approved type within the same tolerances, the assessment result may remain unchanged.

Switching from paper to plastic – an example of a change that alters the scope of the PPWR

A change of material category may change the entire set of applicable requirements.

Example:

a company replaces cardboard packaging with plastic packaging having the same commercial function.

The new design may require a different analysis concerning:

• recyclability,
• PCR content,
• substances,
• minimisation,
• labelling.

This is therefore not a ‘revision of an old record’. In practice, it is a new technical status requiring a full reassessment of the relevant requirements.

New test report – does the declaration need to be changed?

Not automatically.

Assume that a company commissions periodic retesting of the same material specification and receives the same positive result.

In that case, the new report:

• strengthens the current evidence base,
• should be included in the dossier,
• does not in itself need to change the content of the declaration.

If the new report reveals a different result or calls an earlier assumption into question, a reassessment of conformity is required.

Change in test method or new technical knowledge

Sometimes the packaging itself does not change, but the way it is assessed does.

There may be:

• a new analytical method,
• a better limit of quantification,
• a new harmonised methodology,
• a Commission act specifying the assessment method.

If the existing evidence is no longer sufficient in the light of a new mandatory method, the documentation must be reassessed, even though the physical packaging has not changed.

Change to a harmonised standard or common specification

This is a case indicated directly by the Article 15 system.

The manufacturer should take account of changes to:

• harmonised standards,
• common specifications,
• other technical specifications,

to which the conformity assessment refers.

If point 6 of the declaration in Annex VIII indicates a specific standard and the company moves to a new version of that standard, it must be checked whether:

1. the assessment criteria have changed,
2. new calculations or tests are needed,
3. the existing result remains valid,
4. the reference in the declaration needs to be changed.

The entry into application of a further PPWR requirement may require an update of the declaration without a change to the packaging

This is very important, as the PPWR is implemented in stages.

For example, requirements concerning the following start to apply, or may start to apply, at a later stage:

• Design for Recycling,
• minimum recycled content levels,
• minimisation under the full regime of Article 10,
• harmonised labelling,
• recycling at scale.

The packaging may physically look the same as it did the day before, but the legal scope of the required assessment may already be different.

Before further placing on the market under the new regime, the additional requirement must then be assessed and the documentation and declaration updated accordingly.

Change of the manufacturer’s name or address

Annex VIII contains the manufacturer’s details.

If details contained directly in the declaration change, the current version of the document should contain the correct information.

The following should be treated differently:

• a simple address change of the same entity,
• an organisational transformation,
• the transfer of activities to another legal person,
• a change of the entity acting as the manufacturer.

In the latter case, this is not merely an administrative change. Regulatory responsibility must be reassessed.

Does the departure of the signatory require all old declarations to be updated?

There is no reason for a historical declaration to become invalid solely because the person who validly signed it later left the company.

The document remains a record of the status and responsibility at the time it was issued.

At the next revision or for a new declaration, the current person duly acting on behalf of the manufacturer must of course be used.

However, the entire archive should not be rewritten en masse merely because of an employee change.

Typo or administrative error – does the packaging need to be reassessed?

Correcting a typo is not the same as making a technical change.

For example, if:

• the street number was entered incorrectly,
• there is a typo in the packaging name,
• an internal number was recorded incorrectly,

the document can be corrected without repeating the entire technical assessment from the beginning.

However, the company should retain:

• the revision number,
• the correction date,
• the reason for the change,
• the earlier version in the archive.

An importer or distributor modifies packaging – Article 21 may change not only the declaration, but the company’s role

A change may have consequences greater than updating a single document.

Article 21 provides that an importer or distributor may become subject to the obligations of the manufacturer if it:

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

If a distributor changes the material, adds a coating or redesigns the construction, it should not automatically continue to rely on the previous manufacturer’s old declaration.

The new role and responsibility must first be determined.

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

Non-compliance is not remedied by changing the text of the declaration.

It must first be determined:

• what the non-compliance consists of,
• which versions or batches it concerns,
• whether the packaging has already been placed on the market,
• what corrective action is needed,
• whether further making available must be suspended,
• whether the competent authorities must be informed.

Only after the issue has been resolved and compliance has been demonstrated again can the formal part of the documentation be updated.

Does an old PPWR declaration become ‘invalid’ after a packaging change?

It is better to say that it ceases to be the appropriate declaration for the new version of the packaging.

If the declaration was valid for version V1 placed on the market in 2026, the subsequent creation of version V2 does not alter the historical fact that V1 was assessed on the basis of that technical documentation.

Therefore, the system should retain:

• DoC V1 – archived,
• TD V1 – archived,
• V1 production period,
• date of change,
• DoC V2 – current for the new version,
• TD V2 – current.

Removing V1 from the archive would later make it more difficult to demonstrate the conformity of packaging that had previously been placed on the market.

What about old stocks after a material change?

A design change alone does not automatically mean that every unit of the old variant becomes non-compliant.

A distinction must be made between:

• version V1 that still complies with the applicable requirements,
• version V1 that can no longer be placed on the market due to a new requirement,
• version V1 already placed on the market earlier,
• version V1 still held by the manufacturer before its first placing on the market.

The time of production is not always the same as the time of placing on the market.

Changes resulting from the date of application of a new legal requirement require particular caution.

How should a PPWR declaration be versioned after changes?

A well-designed system may look as follows:

Each revision should indicate:

• date of entry into force,
• scope of the change,
• outcome of the impact assessment,
• documents replaced by new ones,
• the approving person.

What should the PPWR change control procedure look like?

The best system does not allow the purchasing or production department to change a material packaging characteristic without triggering a conformity assessment.

The procedure may have six stages:

1. Notification of the planned change.
2. Identification of the packaging affected.
3. Assessment of the impact on PPWR requirements.
4. Identification of documents and tests requiring updating.
5. Reassessment of the relevant requirements.
6. Decision: no change to the declaration / amendment / new revision.

Only after the process has been completed should the modified variant be released for serial production and placing on the market.

Packaging change and PPWR declaration – practical decision matrix

The matrix is intended as a practical guide. The final decision depends on the specific type of packaging and the scope of its previous assessment.

Example: changing the film supplier for existing packaging

The company has packaging with:

• code PKG-041,
• PE film,
• supplier A,
• material report RA-2026-14,
• declaration DoC-041-R1.

Procurement proposes supplier B.

The correct procedure is not to issue DoC-041-R2 immediately.

First, the company:

1. compares specifications A and B,
2. checks composition and additives,
3. compares recycled content,
4. checks substance reports,
5. assesses the impact on functional properties,
6. determines whether previous reports remain representative.

If material B is genuinely equivalent, the dossier is updated and the assessment outcome may remain the same.

If, however, the new film:

• has 30% PCR instead of 0%,
• contains a different pigment,
• has a different thickness,

the change is technical and the relevant requirements must be reassessed before the new version is approved.

The supplier should report changes before they affect the declaration

The worst change is one that the manufacturer learns about several months after it has been implemented.

Therefore, purchasing terms should require advance notification of changes concerning:

• raw material,
• raw material supplier,
• formulation,
• coating,
• adhesive,
• colourant,
• recycled material content,
• basis weight,
• design,
• a production process that may affect properties.

This makes change control a preventive process rather than an action taken after a problem is detected.

Most common errors when updating the PPWR declaration of conformity

• assuming that the declaration is “valid for 5 years”, so nothing needs to be checked for five years;
• automatically issuing a new declaration after every supplier change without assessing the impact;
• the opposite error – no verification whatsoever of the new supplier;
• treating the material name “PET” or “paper” as sufficient evidence of equivalence;
• failing to take account of a change in adhesive, label or coating;
• failing to reassess after a change in recycled content;
• changing basis weight without reviewing minimisation;
• copying an old declaration after a change in material category;
• failing to review after a change in a harmonised standard;
• failing to update when the next PPWR stage becomes applicable;
• overwriting an old PDF with a new file bearing the same name;
• deleting the historical declaration for the old version;
• changing the declaration alone without updating the technical basis;
• attempting to “remedy” non-compliance by editing the statement;
• no formal change-control procedure between purchasing, R&D and quality.

Updating the PPWR declaration of conformity – checklist after every change

1. Record exactly what is changing.
2. Specify the planned implementation date.
3. Identify all packaging using the changed element.
4. Check whether the material is changing.
5. Check whether the supplier is changing.
6. Check whether the composition or formulation is changing.
7. Check whether the mass, basis weight or dimension is changing.
8. Check the impact on Article 5.
9. Check the impact on Article 6.
10. Check the impact on Article 7, if applicable.
11. Check the impact on Article 10.
12. Check the impact on Article 11, if applicable.
13. Verify that test reports are up to date.
14. Verify that supplier data are up to date.
15. Check the standards and specifications forming the basis of the assessment.
16. Determine whether new testing is required.
17. Determine whether a new calculation is required.
18. Update the technical documentation.
19. Carry out the appropriate reassessment of conformity.
20. Check whether the content of the existing declaration is still correct.
21. If not, issue a new revision of the declaration.
22. Keep the previous version in the archive.
23. Assign an effective date to the new version.
24. Inform the relevant departments and recipients, if necessary.
25. Only then approve the change for production or purchasing.

How can you automate change control for PPWR declarations?

With a large number of packaging items, the most difficult issue is finding all documents affected by a single change.

Example:

a company changes one adhesive used in:

• 18 labels,
• 34 packaging items,
• 72 SKUs,
• 11 declarations.

In a folder-based system, each dependency must be found manually.

A relational system, by contrast, should automatically trace:

adhesive → specification → requirements → reports → packaging types → dossier → declarations.

After changing one component, it is then possible to automatically create a list of declarations requiring review.

When must a PPWR declaration of conformity be updated? Summary

A PPWR declaration has no single calendar expiry date. However, it must remain consistent with the actual packaging and the current basis for its conformity assessment.

Any change to the design, properties, material, standard or another element that may affect conformity should be subject to formal change control.

Not every change automatically requires a new declaration.

First, you need to answer:

has a characteristic relevant to conformity changed, has the evidence base changed, and does the existing declaration still correctly describe the assessed packaging?

If yes, the documentation may remain unchanged or require only supplementation.

If not, the appropriate reassessment must be carried out and an updated revision of the declaration issued.

The safest process is:

change → impact assessment → evidence update → reassessment → DoC decision → versioning → archiving of the previous version.

FAQ – updating the PPWR declaration of conformity

Sources</h2>

PPWR Regulation: Regulation (EU) 2025/40 of the European Parliament and of the Council – EUR-Lex

Final European Commission guidelines: Commission Notice C(2026) 3702 – Guidelines on Regulation (EU) 2025/40

European Commission FAQ: Packaging and Packaging Waste Regulation – Frequently Asked Questions

The article uses, in particular:

• Article 15 – obligations of the manufacturer, production conformity and consideration of changes affecting the assessment,
• Article 16 – information and documentation from suppliers,
• Article 18 – obligations of the importer,
• Article 19 – obligations of the distributor,
• Article 21 – modifications that may result in the importer or distributor being subject to the obligations of the manufacturer,
• Articles 35–37 – assessment methods, harmonised standards and common specifications,
• Article 38 – conformity assessment procedure,
• Article 39 – EU declaration of conformity and responsibility of the manufacturer,
• Annex VII – technical documentation and internal production control,
• Annex VIII – structure of the EU declaration of conformity.