Foundations

PPWR Declaration of Conformity template, field by field

Last regulatory verification: 12 August 2026 · 2 official sources

A field-by-field walkthrough of the Annex VIII declaration structure: what belongs in each entry, common mistakes, and the evidence each field implies.

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Short answer

A PPWR Declaration of Conformity follows the model structure in Annex VIII: identify the packaging, identify the manufacturer, state conformity under sole responsibility, reference the provisions and standards applied, then sign and date it. The template is the easy part — each field implies evidence sitting in the Annex VII technical documentation.

Field by field, with what usually goes wrong

Below is each element of the Declaration, a worked example of a good entry, and the failure mode we see most often when reviewing real documents. The failure modes matter more than the format: a well-formatted Declaration with an unsupported field is the more dangerous document, because it looks finished.

1

Declaration number and version

DoC-2026-014, revision 2, issued 3 September 2026

A unique reference that lets you tie the Declaration to a specific packaging specification revision.

Common failure: Reusing one number across a whole portfolio, so nobody can tell which version an inspector was shown.

2

Manufacturer identity

Legal entity name, registered address, and where relevant the authorised representative

The entity carrying the conformity obligation. Where packaging is sold under another company's brand, that company is often the one placing it on the market under its own name.

Common failure: Naming the brand owner when the converter is the manufacturer, or vice versa, without deciding who actually holds the obligation.

3

Statement of sole responsibility

"This Declaration of Conformity is issued under the sole responsibility of the manufacturer."

Fixed wording drawn from the Annex VIII model.

Common failure: Qualifying it — for example 'based on information supplied by our converter'. A qualified statement is not the statement the Regulation requires.

4

Object of the Declaration

500 ml PET bottle, 24 g, with HDPE closure and PP wrap-around label, specification SPEC-BTL-500-r4, plus a photograph

Identify the packaging so precisely that it cannot be confused with an adjacent configuration. Include components: closures, labels, coatings, inks and adhesives are part of the packaging.

Common failure: "PET bottles" as the object. It covers everything and therefore evidences nothing.

5

Conformity statement and provisions met

Conforms with the relevant provisions of Regulation (EU) 2025/40, listing the articles applicable to this configuration

List the requirements that actually apply to this configuration. Requirements that do not yet apply should not be claimed as met.

Common failure: Claiming conformity with articles that phase in later, which converts a future gap into a present misstatement.

6

Standards and specifications applied

Reference to any harmonised standard or common specification relied on, with its version

Only cite standards you genuinely applied. A standard confers a presumption of conformity only once cited in the Official Journal.

Common failure: Listing a standard because a supplier mentioned it, without holding the test evidence that shows it was met.

7

Additional information

Where relevant: notified body involvement, or restrictions on the scope of the Declaration

Use this to record anything that limits or explains the scope.

Common failure: Hiding a material limitation here rather than fixing it in the underlying assessment.

8

Signature block

Signed for and on behalf of the manufacturer, place, date, name and function

A named individual with the authority to bind the entity. Keep the signed original retrievable for at least five years.

Common failure: An unsigned PDF template circulated to customers as if it were a Declaration.

Why we don't publish a fill-in-the-blanks file

A blank template invites the exact failure the Regulation is designed to catch: a signed conformity statement produced before anyone assessed which requirements apply. The document takes an hour. The assessment behind it is the work — and it is what an authority will ask for second.

What to do before you populate it

Fix the configuration boundary first: one Declaration should describe one packaging specification, including all its components. Then confirm which requirements apply to that configuration on the date it is placed on the market, and confirm you hold evidence for each one. Only then is the template a formatting task.

Official sources for this page

Every statement above is written against these sources. Where a Commission document and the Regulation differ, the Regulation controls.

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.

Well-made packaging is not compliant packaging. Under Regulation (EU) 2025/40 the evidence file is part of the obligation, not paperwork about it.

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