The PPWR EU Declaration of Conformity

What the Declaration is

The EU Declaration of Conformity is the manufacturer's formal statement, issued under its sole responsibility, that a given packaging meets the requirements of the Packaging and Packaging Waste Regulation that apply to it. By drawing it up, the manufacturer assumes responsibility for the conformity of that packaging.

It is not issued by an authority, and it is not a certificate. No third party — including us — signs it for you.

What it typically contains

Following the model structure set out in Annex VIII, a Declaration generally identifies:

• the packaging, in a way that allows it to be traced and identified;
• the name and address of the manufacturer, and of the authorised representative if any;
• a statement that the Declaration is issued under the manufacturer's sole responsibility;
• the object of the Declaration and the relevant requirements it is declared to meet;
• references to any standards or technical specifications relied on;
• where relevant, the details of any conformity assessment carried out;
• the place and date of issue, and the signature and function of the signatory.

A single Declaration may cover more than one packaging item where those items are properly identified and the same requirements and evidence apply.

Who has to draw it up

The manufacturer. In practice, working out who the PPWR manufacturer is for a specific packaging is often the hardest step: a brand owner that has packaging made to its specification and places it on the market under its own name may carry manufacturer obligations even though it does not operate a converting line. An importer bringing packaged goods into the Union has its own set of obligations.

This is also distinct from being a producer for extended producer responsibility — see PPWR manufacturer vs producer.

The technical documentation comes first

A Declaration is a conclusion. The evidence for that conclusion lives in the technical documentation required by Annex VII: the packaging description, the design and material information, the assessment against each applicable requirement, and the test reports or supplier declarations relied on. Market surveillance authorities ask for that file, not just the one-page Declaration.

Signing a Declaration without a documented basis for it does not create conformity. It creates a documented assertion you may not be able to support.

Timing: what is actually in force

Regulation (EU) 2025/40 generally applies from 12 August 2026, but its substantive requirements are phased — the PFAS restriction for food-contact packaging from 12 August 2026, harmonised labelling and recycled-content obligations later, and design-for-recycling conformity dependent on delegated acts. The practical question is which requirements apply to your packaging, and when. See PPWR requirements in 2026.

Practical sequence

1. Define the packaging configuration precisely, including every component.
2. Establish your regulatory role for that packaging.
3. Identify the requirements that apply, and the date each applies from.
4. Collect the evidence: specifications, supplier declarations, test reports.
5. Assemble and index the Annex VII technical documentation.
6. Only then draw up and sign the Declaration.

This page is general information about Regulation (EU) 2025/40, not legal advice, and the Regulation itself is the authoritative source.