Foundations
PPWR conformity assessment
Last regulatory verification: 14 October 2026 · 1 official source
What the PPWR conformity assessment is, who carries it out, how it relates to the technical documentation and the Declaration, and where it usually goes wrong.
Key facts
- Under PPWR the manufacturer carries out the conformity assessment for packaging using internal production control, set out in Annex VII.(S01)
Short answer
The PPWR conformity assessment is the manufacturer's own check that a packaging meets every requirement that applies to it. It uses the internal production control procedure in Annex VII: no notified body is involved. The result is written down in the technical documentation, and the Declaration of Conformity states its conclusion.
Assessment, documentation, Declaration
These three are often used as if they were one thing. They are a sequence. The assessment is the reasoning: does this packaging meet this requirement, and on what evidence? The technical documentation is the record of that reasoning and its evidence. The Declaration is the one-page statement that the reasoning came out positive. If the assessment is weak, neither of the documents that follow can fix it.
Who carries it out
The manufacturer — the business that makes the packaging, or has it made, and places it on the market under its own name or brand. An importer must verify that the assessment was carried out; it does not repeat it, unless it becomes the manufacturer itself. A consultant can prepare the assessment, but the manufacturer remains responsible for it.
An assessment worksheet, row by row
The Regulation does not prescribe a format. The worksheet below is our own illustrative layout: one row per requirement, per packaging system. It is what turns a pile of supplier documents into a reasoned conclusion.
| Column | What goes in it | Example entry |
|---|---|---|
| Requirement | The obligation, with its article or annex | Substances of concern — Article 5 |
| Status | Applies now, from a later date, or depends on a further act | Applies now |
| Applies to this packaging? | Yes / no, with the reason | Yes — all components |
| Evidence | Document reference in the technical file | 05-supplier/closure-statement-v2 |
| Conclusion | Met / not met / open | Met |
| Gap and owner | What is missing and who holds it | Label ink statement — label supplier, requested 3 Oct |
The "Status" column matters because PPWR is phased. A requirement that depends on a delegated act not yet adopted cannot be assessed against a final method — record it as conditional, note what you already know, and revisit it when the act is published. See the secondary legislation tracker.
Where assessments usually go wrong
- Assessed at company level. "Our packaging is compliant" is not an assessment. Each packaging system needs its own rows.
- Components missing. Closures, labels, inks and adhesives are part of the packaging and often where the gaps are.
- Evidence that answers a different question. A food-contact declaration is not a PFAS statement; an EPR registration is not a conformity assessment.
- No re-assessment after change. A new supplier or coating can invalidate a row. Changes should trigger a review of the affected rows, not the whole file.
'Not met' is a valid result
We prepare assessments and the files behind them as part of our technical documentation service. For the full sequence around the assessment, see PPWR compliance, step by step.
This page is general information about Regulation (EU) 2025/40, not legal advice.
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
- Sources last verified
- 14 October 2026
- Content last updated
- 14 October 2026
- First published
- 14 October 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.