Declaration of conformity of packaging with the PPWR – what does it contain, when does it come into force, and who is required to draw it up?

The PPWR Regulation introduces an obligation to draw up an EU declaration of conformity for all packaging intended for the EU market. We explain what information the declaration should contain, who is responsible for drawing it up, and when it should be updated.

What is an EU Declaration of Conformity?

The EU Declaration of Conformity is a formal document certifying that the packaging in question complies with the relevant requirements in accordance with the requirements of the PPWR Regulation in the areas of sustainability, safety and labelling. It contains key information and technical specifications concerning, amongst other things, the materials used, the content of potentially hazardous substances, and the recyclability of the packaging unit in question. EU Declaration of Conformity is drawn up for all types of packaging placed on the Community market, and then retains it, together with the full technical documentation, for a period of 5 years (for single-use packaging) or 10 years (for reusable packaging).

Before drawing up the declaration, a conformity assessment procedure must be carried out to verify that the packaging, including its integrated components, complies with the requirements set out in Articles 5–12 of the PPWR Regulation. Packaging that does not successfully pass the conformity assessment procedure or does not have a valid declaration may not be placed on the European Union market after 12 August 2026.

Who draws up the EU declaration of conformity?

The EU Declaration of Conformity is drawn up by the packaging manufacturer or its authorised representative based on the documentation and information provided by suppliers. Regardless of the involvement of other parties in the preparation of the documentation, the packaging manufacturer bears full responsibility for the packaging’s compliance with the requirements of Regulation (EU) 2025/40 (PPWR).

The manufacturer is responsible for:

• carrying out the conformity assessment procedure,
• the retention of declarations and full technical documentation for the required period
• providing copies of declarations and technical documentation upon request by the competent authorities. The documents provided should be drawn up in languages understood by those authorities and made available in electronic form, and, at the authority’s request, also in paper form, within 10 days of receipt of the request.

Find out about the role and key responsibilities of a manufacturer under the PPWR >>

If, following the preparation of the EU declaration of conformity, there is a change in the details of the manufacturer or its authorised representative, the manufacturer is obliged to update the document

What information does the EU declaration of conformity contain?

A correctly drawn up EU declaration of conformity should contain a finding that compliance with the requirements set out in Articles 5–12 of the PPWR Regulation has been demonstrated (or on the basis of those articles) and must include:

• a number enabling the package to be uniquely identified (e.g. serial number, batch number),
• the name and address of the manufacturer and their authorised representative (if applicable),
• description of the packaging,
• a declaration of conformity of the packaging with EU regulations,
• an indication of the legal standards and common specifications, or other technical specifications, on the basis of which the conformity of the packaging is declared,
• information on certificates issued by certification bodies, together with their date of issue and period of validity,
• the place and date of issue of the declaration, the issuer’s details and signature, and the details of the person signing the declaration, including:
  • the signature of the person authorised to act on behalf of the manufacturer,
  • the full name and position of the person signing the declaration.

In many cases, the technical compliance of the packaging is verified by a third party (e.g. a laboratory or a certification body), which provides additional assurance and credibility regarding the information contained in the declaration.

The EU Declaration of Conformity is drawn up for the packaging as a whole, i.e. taking into account all its integral components. If individual components of the packaging are placed on the market as stand-alone packaging or as packaged products, a separate conformity assessment must be carried out for them and a separate EU Declaration of Conformity must be drawn up.

When should the EU Declaration of Conformity be drawn up?

From 12 August 2026. Packaging manufacturers are required to carry out a conformity assessment and draw up an EU declaration of conformity for all packaging placed on the Community market for the first time. This applies both to new types of packaging placed on the market after that date and to subsequent batches of packaging already on the market which will be made available for the first time on 12 August 2026 or later. Packaging units already lawfully placed on the market before that date may continue to be made available on the market (e.g. until stocks are exhausted) without the need to draw up a new declaration.

Please note: The preparation of the EU declaration of conformity is the final stage of the conformity assessment procedure. Prior to this, the manufacturer draws up the technical documentation and confirms compliance with the requirements set out in the PPWR Regulation.

Each The manufacturer is also obliged to update the declarations it has drawn up in situations where there is a change to the technical specifications of the packaging that affects compliance with the obligations under the PPWR Regulation, and in the event that changes to the legislation and the entry into force of further requirements under the PPWR Regulation. Failure to provide a valid declaration confirming compliance with all applicable requirements means that the packaging cannot be placed on the EU market.

Check the timetable for the implementation of the PPWR Regulation >>

The conformity assessment procedure – what is it and how does it work?

The conformity assessment procedure is internal checks carried out by the packaging manufacturer, the aim of which is verification of a given package’s compliance with the obligations laid down in Articles 5–12 of the PPWR Regulation. It consists of several main stages: the preparation of technical documentation for the packaging (description of the packaging, conceptual design, technical drawings, materials used and technical specifications), ensuring the reproducibility of the packaging manufacturing process, and the drafting of an EU declaration of conformity.

Conformity assessment procedure may be carried out by the manufacturer or another entity acting on the manufacturer’s behalf (e.g. a laboratory or a body operating within a certification scheme). As part of the conformity assessment, compliance with the applicable requirements is verified, including those relating to:

• the maximum levels of PFAS and hazardous substances (heavy metals),
• recyclability,
• minimum recycled content (for plastic packaging only),
• suitability for industrial composting (for packaging labelled as compostable),
• minimising packaging,
• reduction of the void ratio,
• reuse,
• labelling of packaging.

Regardless of the involvement of external parties, the manufacturer bears full responsibility for demonstrating that the packaging complies with the requirements of the PPWR.

How do you draw up an EU declaration of conformity?

If the conformity assessment procedure shows that the packaging in question meets all the applicable legal requirements, the manufacturer or their authorised representative shall draw up an EU declaration of conformity based on the formula set out in Annex VIII to the PPWR Regulation.

The ‘Check for Recycling’ digital tool enables users to quickly and conveniently create declarations of conformity and all technical documentation based on data provided by the manufacturer. Thanks to its user-friendly navigation and Polish-language prompts, the tool guides the user step by step through the entire process – from importing data from source files, tables and documents, through the analysis of the packaging’s composition, to the generation of a complete declaration of conformity meeting the requirements of the PPWR Regulation.

Important: The EU declaration of conformity must be drawn up in the language or languages required by the Member States in which the packaging in question is made available.

Ready The EU declaration of conformity must be signed by a person authorised to act on behalf of the manufacturer. By signing this document, the signatory confirms that they accept responsibility for the declaration made, namely that the packaging complies with the applicable requirements of the PPWR Regulation.

A packaging manufacturer must bear in mind that The EU declaration of conformity and technical documentation are drawn up for the specific type or model of packaging covered by the conformity assessment.

The ‘Check for Recycling’ tool makes it easier to manage a wide range of packaging and group it by product category, country and other parameters. This enables users to manage all their resources and data in an organised and structured manner, as well as to quickly and conveniently generate, modify and analyse individual EU declarations of conformity. Furthermore, Check for Recycling automatically assesses the recyclability of each packaging item, assigns it to one of the recycling performance classes – A, B or C – and determines the recycled content in accordance with the German ZSVR minimum standard.

Discover all the features of the Check for Recycling tool >>

Can several identical packages have a single EU declaration of conformity?

A single declaration may cover multiple production batches of a given type of packaging, provided that the packaging type in question meets the requirements of the PPWR.  This means that if several or a dozen or so products use exactly the same packaging (with the same design, materials and technical parameters), it is sufficient to prepare a single declaration of conformity for that type of packaging.

A declaration may therefore cover a group of identical packages, provided that they are manufactured to the same specification. They may be grouped, for example, by type, material, function or supplier, provided that each package can be uniquely identified.

It should be borne in mind, however, that appropriate technical documentation must be available for each type of packaging to confirm compliance with the PPWR requirements. Even if a single declaration covers several identical items of packaging, the technical documentation must make it possible to demonstrate the compliance of each one.