Who issues and who signs the PPWR declaration of conformity?
The PPWR declaration of conformity is drawn up by the manufacturer responsible for the given packaging type. The document is signed by a person acting on behalf of that manufacturer. Regulation (EU) 2025/40 does not specify that this must be the president of the management board, company owner, quality director or compliance officer. However, Annex VIII requires an indication of on whose behalf the declaration was signed, the place and date of issue, the full name and position of the signatory, as well as the signature itself.
It is therefore crucial to distinguish between two levels of responsibility. The formal entity drawing up the declaration is the manufacturer. The natural person providing the signature acts on behalf of that entity. Such a person should also not be confused with an ‘authorised representative’ under Article 17 of the PPWR, which is a separate formal regulatory role.
Who issues the PPWR declaration of conformity?
The entity responsible for drawing up the EU declaration of conformity is the manufacturer within the meaning of the PPWR.
This follows from the combined application of Articles 15, 38 and 39 of the Regulation. Before placing packaging on the market, the manufacturer carries out or has carried out the appropriate conformity assessment procedure, draws up the technical documentation and, after demonstrating conformity, draws up the EU declaration of conformity.
The process should therefore be as follows:
PPWR requirements → technical documentation → conformity assessment → decision on conformity → EU declaration of conformity → signature on behalf of the manufacturer.
You should not start by asking who should sign the PDF. First, it must be established which company is the relevant manufacturer of the given packaging type.
The manufacturer draws up the declaration, but a specific person signs it
The manufacturer is an economic operator, whereas the signature is always given by a natural person acting on its behalf.
Therefore, the declaration includes in parallel:
| Element | Who or what does it concern? |
|---|---|
| Manufacturer | Company responsible for the conformity of the given packaging type |
| ‘Signed on behalf of’ | Entity on whose behalf the signature is given |
| Full name | Natural person signing the document |
| Position | This person’s role in the organisation |
| Signature | Formal approval of the declaration on behalf of the entity |
What exactly does Annex VIII require regarding the signature?
Annex VIII contains a model structure for the EU declaration of conformity.
The final part of the document provides for elements making it possible to establish:
- on whose behalf the declaration was signed,
- the place and date of issue,
- the full name of the signatory,
- their position or function,
- the signature.
This means that a declaration signed anonymously or solely with a company stamp, without the possibility of identifying the responsible person, does not comply with the structure provided for in Annex VIII.
Must the PPWR declaration be signed by the president of the management board?
This does not follow from the PPWR.
The Regulation does not specify the signatory’s particular position. It does not contain a provision stating:
“the declaration is signed by the president”
or:
“the declaration is signed by a management board member”.
Annex VIII, however, requires the first and last name, position and signature of the person making the statement on behalf of the relevant entity.
In practice, the company should determine itself who, in accordance with its representation rules and internal procedure, is authorised to approve such declarations.
Can a PPWR declaration be signed by a quality director or another employee?
PPWR does not limit the signatory to management board members.
From the perspective of Annex VIII itself, what matters is that the document is signed on behalf of the relevant manufacturer and that the signatory is properly identified.
In practice, this may be, for example:
- a management board member,
- the business owner,
- a quality director,
- a quality manager,
- a compliance manager,
- a person responsible for regulatory affairs,
- another person acting on behalf of the company in accordance with its organisational rules.
However, the company should have an internal basis enabling it to demonstrate why that person was authorised to approve the document.
Must the signatory have written authorisation?
Annex VIII to PPWR itself does not establish a general requirement to attach a separate written authorisation for the employee signing the document to each declaration.
This is important because some guidance states that the absence of written authorisation automatically renders the declaration defective. Such a requirement should not be inferred directly from Annex VIII itself.
However, the company should ensure a clear internal rule specifying:
- who may approve declarations,
- the scope of their authorisation,
- who checks the technical documentation before signature,
- who is responsible for subsequent updates to the document.
The form of such authorisation may also depend on national law, the representation rules of the company concerned and its internal procedures. This is a matter broader than the text of PPWR itself.
The signatory and the authorised representative under Article 17 are not the same
An “authorised representative” under PPWR is a formally defined economic operator role.
Article 17 allows a manufacturer to appoint an authorised representative by written mandate and entrust it with specified tasks.
This does not mean, however, that every employee signing a declaration on behalf of their own company automatically becomes an “authorised representative” within the meaning of Article 17.
| Situation | Nature |
|---|---|
| A quality director signs their own company’s declaration | Person acting on behalf of the manufacturer |
| An external entity appointed in accordance with Article 17 | PPWR authorised representative |
These two situations should not be confused in company procedures.
Who is responsible for the content of the declaration after it is signed?
Article 39(4) states that, by drawing up the EU declaration of conformity, the manufacturer assumes responsibility for the compliance of the packaging with the PPWR requirements.
This is a very important distinction.
The signature is provided by a specific person, but this does not automatically make the resulting responsibility under the declaration that employee’s personal responsibility for the entire product.
The declaration is made on behalf of the manufacturer.
Therefore, the organisation should ensure that the person signing has access to the approved outcome of the conformity assessment, rather than expecting the signatory to analyse hundreds of laboratory reports independently without an internal process.
When can the PPWR declaration of conformity be signed?
The declaration must be drawn up after conformity has been demonstrated, not before the assessment is completed.
The correct sequence is:
- identification of the packaging,
- determination of the applicable requirements,
- collection of data and documents,
- preparation of technical documentation,
- performance of the conformity assessment procedure,
- confirmation of the outcome,
- drawing up the declaration,
- signature by the person acting on behalf of the manufacturer.
A signature made while essential reports are still missing or the appropriate assessment has not been carried out does not remedy the lack of evidence.
Does the importer sign the PPWR declaration of conformity?
Being an importer alone does not automatically mean that the importer becomes the entity drawing up the declaration instead of the manufacturer.
Article 18 requires the importer to verify, before placing packaging on the market, whether the manufacturer has fulfilled the relevant obligations, including those relating to conformity assessment and documentation.
The importer should also keep an appropriate copy of the declaration of conformity and ensure that the documentation is available in accordance with the scope of its obligations.
The situation changes where Article 21 applies and the importer is treated as a manufacturer – for example, because it places packaging on the market under its own name or trademark or makes a substantial modification affecting conformity.
Can a distributor issue its own PPWR declaration?
Merely being a distributor does not create such an obligation.
The distributor acts within the obligations laid down in Article 19 and should, with due care, verify the relevant elements of conformity before making packaging available on the market.
However, if the distributor:
- places packaging on the market under its own name or trademark, or
- modifies packaging in a way that may affect conformity,
it may become subject to the manufacturer’s obligations under Article 21.
In that case, the question of signing the declaration must be considered from the perspective of its new role.
Who signs the declaration for own-brand and private-label products?
For private-label products, the manufacturer must first be identified. Only then can the signatory be determined.
Where a company commissions the manufacture of a product or packaging under its own name or trademark and is the manufacturer according to the PPWR definition, the declaration should be drawn up in its name.
The contract manufacturer may provide:
- specifications,
- laboratory reports,
- material documents,
- test results,
- information needed for the technical documentation.
This does not automatically mean that the declaration for the final packaging should be signed on behalf of the factory.
The specific PPWR rule for certain microenterprises must also be taken into account.
Contract manufacturing – does the brand or the factory sign the declaration?
The signatory cannot be determined solely on the basis of who physically operates the production line.
In contract manufacturing, it is necessary to verify:
- who commissions the design,
- who defines the specification,
- under whose name or trademark the product is manufactured,
- who is the manufacturer according to Article 3.
If the manufacturer is the brand owner, the declaration is drawn up in its name, even where most of the technical evidence comes from the contract factory.
Can the declaration be signed by a person based outside Poland?</h2>
PPWR is an EU Regulation, and the declaration is a document relating to the manufacturer, not to the location of the person signing it at a particular Polish branch. </p>
If the relevant manufacturer is located in another Member State, the declaration may be drawn up on its behalf by an appropriate person acting for that entity. </p>
However, the document must comply linguistically with the requirements applicable in the markets where the packaging is made available.
</p>
</section>
The signature does not have to be automatically assigned to each site separately.</strong>
</p>
The key is to determine the entity that is the manufacturer and the subject of the declaration.
</p>
If one legal entity is responsible for a given type of packaging produced at several locations, the company procedure may provide for central approval of declarations.
</p>
However, the technical documentation should include the information necessary to demonstrate that production at the sites concerned remains compliant with the approved type and documentation.
</p>
</section>
A laboratory does not become the manufacturer merely because it carried out testing.</strong>
</p>
A laboratory may prepare a test report constituting evidence in the technical documentation.
</p>
It may also support the undertaking in interpreting the results.
</p>
However, it is the manufacturer that draws up the declaration of conformity and assumes the responsibility provided for in Article 39(4).
</p>
</section>
An adviser may provide technical assistance in preparing a draft document, collecting data or verifying the completeness of the assessment.
</p>
However, this does not mean that the declaration becomes the adviser’s declaration.</strong>
</p>
The relevant manufacturer remains the formal entity.
</p>
If an external person or entity is to act formally on behalf of the manufacturer within a specified scope, the rules of representation and, where applicable, the formal role of the authorised representative under Article 17 must be considered.
</p>
</section>
Not merely by virtue of supplying the material.</strong>
</p>
Article 16 requires the supplier of packaging or packaging material to provide the information and documentation needed by the manufacturer to demonstrate compliance.
</p>
The supplier may therefore provide:
</p>
This does not automatically mean that the supplier must sign the declaration for the final packaging type.
</p>
</section>
Annex VIII provides for the identification of the signatory by their details and function.
</p>
This information should correspond to the version of the document stored in the system and capable of being presented to the market surveillance authority.
In Annex VIII, the PPWR does not contain detailed technical rules specifying a single mandatory type of electronic signature for the declaration.
However, it requires a signature as an element of the declaration.
If the company uses a digital workflow, it should ensure that the following can be reliably established:
The choice of a specific electronic signature mechanism should also take account of other applicable rules concerning documents and representation.
The signature should be the final controlled stage of the process, not an action performed automatically after the PDF has been generated.
In a larger organisation, a formal approval matrix is a practical solution.
This means that the person signing receives an approved process outcome rather than having to reconstruct all technical analyses independently.
Automatically generating a document alone is relatively straightforward. It is more difficult to check whether the document is ready for approval.
The system should distinguish between the status “draft generated” and the status “assessment completed and declaration approved”.
For each declaration, it is worth retaining:
The EU declaration of conformity is drawn up by the manufacturer. It is signed by a person acting on its behalf.
The PPWR does not require this to be a specific role, such as chief executive officer, management board member or quality director. However, Annex VIII requires the signatory to be identified by name, position and signature, as well as the place and date of issue and the entity on whose behalf the declaration was signed.
The primary responsibility remains with the manufacturer. Article 39(4) states that, by drawing up the declaration, the manufacturer assumes responsibility for the compliance of the packaging.
Therefore, the correct process is not:
“Someone has to sign the PDF”.
It should be:
manufacturer → technical documentation → conformity assessment → approved declaration → person signing on behalf of the manufacturer.
The EU declaration of conformity is drawn up by the manufacturer responsible for the relevant packaging type after carrying out the appropriate conformity assessment procedure and demonstrating compliance with the applicable PPWR requirements.
The document is signed by a person acting on behalf of the relevant manufacturer. The PPWR does not specify a particular required position. Annex VIII requires, among other things, the name, function or position and signature to be provided.
This does not follow from the PPWR. The Regulation does not reserve the signature for the chief executive officer or a management board member. However, the organisation should ensure that the signatory is duly authorised to act on its behalf.
Annex VIII does not in itself introduce a general obligation to attach separate written authorisation to each declaration. However, the rules governing the signatory’s authority should follow from the organisation’s representation rules and procedures. A separate institution is the authorised representative under Article 17 of the PPWR, who acts on the basis of a written mandate.
Being an importer alone does not automatically entail taking over from the manufacturer the obligation to draw up the declaration. The importer has its own verification obligations. However, it may assume the manufacturer’s obligations in the cases specified in Article 21, for example where it places packaging on the market under its own name or trademark.
Legal basis:
Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste – EUR-Lex
The article uses, in particular:Who signs the declaration when a company has several production sites?</h2>
Can a laboratory sign a PPWR declaration of conformity?</h2>
Can an adviser prepare or sign a PPWR declaration?</h2>
Can a material supplier issue a declaration on behalf of the manufacturer?</h2>
What details of the signatory should be included in the declaration?</h2>
Field
What should be entered?
Signed on behalf of
Name of the relevant entity
Place of issue
Place where the document was drawn up
Date of issue
Date on which the relevant version of the declaration was approved
First and last name
Natural person providing the signature
Position / function
The person’s role in the organisation
Signature
Signature approving the declaration
Can the PPWR declaration be signed electronically?
What should the procedure for signing PPWR declarations in a company look like?
It is worth creating a matrix of persons authorised to sign
Stage
Example of internal responsibility
Material data
Packaging / Procurement
Reports and tests
Quality
Interpretation of requirements
Compliance / Legal / Regulatory
Conformity assessment
Technical process owner
Final signature
Person acting on behalf of the manufacturer in accordance with the established rules
Most common mistakes when signing the PPWR declaration of conformity
Who signs the PPWR declaration – checklist before approval
How can you automate signing PPWR declarations without losing control?
Who draws up and who signs the PPWR declaration – key conclusions
FAQ – who draws up and signs the PPWR declaration of conformity?
Who draws up the PPWR declaration of conformity?
Who signs the PPWR declaration of conformity?
Must the PPWR declaration be signed by the chief executive officer?
Must an employee have written authorisation to sign the PPWR declaration?
Can an importer sign the PPWR declaration?
Sources
This article is for information purposes and does not constitute individual legal advice.
The representation rules of a specific company, the scope of employees’ authority and the form
of signature may also require assessment under provisions other than the PPWR and
the internal rules applicable within the organisation concerned.
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