Foundations
PPWR Annex VIII: the declaration structure
Last regulatory verification: 12 August 2026 · 2 official sources
Annex VIII sets the model structure of the EU Declaration of Conformity. How each element works, and how it connects to Article 39 and the Annex VII file.
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Annex VIII of Regulation (EU) 2025/40 sets the model structure of the EU Declaration of Conformity. Article 39 creates the obligation; Annex VIII says what the document has to contain; Annex VII holds the evidence that makes the statement true.
How the three pieces fit together
It helps to think of the Declaration as the shortest document in the set and the least interesting one to produce. It is a signed assertion. Everything that makes the assertion defensible sits in the technical documentation behind it. Authorities generally ask for the Declaration first and the technical file second — and it is the second request that exposes whether the first was justified.
The elements Annex VIII expects
Identification of the packaging
The packaging or packaged product must be identifiable from the Declaration alone — unambiguously enough that an inspector can match the document to the item in front of them. A product family name is rarely sufficient.
Usually held by: Manufacturer
Name and address of the manufacturer
And, where one is appointed, the authorised representative. This is the legal entity that carries the conformity obligations, not necessarily the brand on the pack.
Usually held by: Manufacturer
A statement that the Declaration is issued under the sole responsibility of the manufacturer
This is not boilerplate. It is the sentence that assigns liability for everything the document asserts.
Usually held by: Manufacturer
The object of the Declaration and its traceability
Typically a description plus an image or reference sufficient to trace the packaging configuration back to a specific specification.
Usually held by: Manufacturer
Reference to the Regulation and the requirements met
The relevant provisions of Regulation (EU) 2025/40 that the packaging conforms with. This is where a configuration-by-configuration assessment matters: listing requirements that do not apply is as much a defect as omitting ones that do.
Usually held by: Manufacturer
References to standards or specifications applied
Harmonised standards or common specifications used, where they were relied upon. A standard only creates a presumption of conformity once its reference is cited in the Official Journal.
Usually held by: Manufacturer
Place and date of issue, name and signature
A named individual signing on behalf of the manufacturer. An unsigned or undated Declaration is routinely rejected by buyers before an authority ever sees it.
Usually held by: Manufacturer
One Declaration per packaging, not per company
Language and availability
The Declaration has to be available in the language required by the Member State where the packaging is placed on the market, and it must be capable of being produced on request. In practice that means a maintained, versioned document, not a file recreated after each request.
Before you sign
A Declaration signed without the Annex VII file behind it is a documented statement that you met requirements you cannot evidence. That is a worse position than having nothing. Work through the field-by-field template guide first, and confirm that each field is supported by something you actually hold.
Official sources for this page
Every statement above is written against these sources. Where a Commission document and the Regulation differ, the Regulation controls.
- Regulation (EU) 2025/40 — EUR-LexBinding law
- Commission PPWR GuidanceCommission guidance
- Sources last verified
- 12 August 2026
- Content last updated
- 12 August 2026
- First published
- 12 August 2026
Written and maintained by the PPWRDeclaration.com editorial team. General information about Regulation (EU) 2025/40 — not legal advice.
Why this matters
What happens if the documentation isn't there
The packaging can be restricted
Packaging without valid technical documentation is treated as non-compliant. Market surveillance authorities can require corrective action, restrict sale, or withdraw it from the market.
Penalties apply per Member State
Each Member State sets its own penalties for non-compliance, and they apply where the packaging is placed on the market — not where your business sits.
Buyers block you first
Retailers, distributors and importers increasingly ask for the Declaration and supporting evidence before onboarding. No file usually means no listing.
Late evidence costs more
Supplier declarations and lab testing have long lead times. Discovering a gap close to a deadline forces rushed testing or packaging redesign.