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A PPWR Declaration of Conformity is the document that makes packaging legal to place on the EU market. Every packaging type needs one from August 12, 2026, and the regulation is specific about who issues it, what it must say, and how long it needs to be kept.
This guide covers what the declaration actually is, how it differs from the technical documentation sitting behind it, what Annex VIII requires point by point, and what a completed one looks like in practice.
What Is the PPWR Declaration of Conformity?
The PPWR Declaration of Conformity is a written, self-issued statement in which the manufacturer confirms that a specific packaging type meets the applicable requirements of Regulation (EU) 2025/40. Its legal basis is Article 39, and its model structure is set out in Annex VIII.
The declaration covers conformity with Articles 5 to 12, the substantive requirements on substances of concern, recyclability, recycled content, minimization, and labeling, to the extent each one already applies on the date the packaging is placed on the market. Not every article under that range is binding yet, so the declaration states what is true today, not what will eventually be true once later deadlines land.
Who Issues the PPWR Declaration of Conformity?
The manufacturer issues the Declaration of Conformity, under its own sole responsibility, for each distinct packaging type it places on the EU market. You are the manufacturer if you make the packaging, or have it designed or made for you and place it on the market under your own name or trademark. Not sure which role applies to you? Our guide to PPWR role determination walks you through it.
There is one exception. If a brand owner is a microenterprise and its packaging supplier is established in the same Member State, the supplier is treated as the manufacturer and issues the declaration.
Issuing the declaration is not the same as holding it. Importers do not draw up the declaration, because that stays with the manufacturer. But an importer bringing packaging in from outside the EU must verify that a valid declaration exists, keep a copy, and produce it to a national authority within 10 days of a reasoned request. We cover this in full in our post on PPWR importer obligations.
PPWR Declaration of Conformity vs. Technical Documentation
| Declaration of Conformity | Technical Documentation | |
| What it is | A signed statement that packaging complies | The evidence file supporting that statement |
| Legal basis | Article 39, Annex VIII | Annex VII |
| Who signs it | The manufacturer | Not signed, it is compiled and retained |
| What it contains | A fixed structure: identification, responsibility statement, conformity statement, signature | Design drawings, material specifications, test reports, assessment considerations, references to regulations and standards |
| Who sees it | Retained internally, to be produced to authorities on request. Sometimes shared on voluntary basis down the supply chain | Retained internally, to be produced to authorities on request |
The declaration is the conclusion. The technical documentation is the evidence backing it up. A manufacturer cannot sign a valid declaration unless that documentation already exists.
What a PPWR DoC Must Contain: The Annex VIII Structure
Annex VIII sets out the model structure for the declaration in eight numbered points, followed by a signature block. In general terms, it requires the packaging’s unique identification, the manufacturer’s identity and address, the authorized representative, if applicable, a statement of sole responsibility, a description of the packaging precise enough for traceability, a statement of which parts of the regulation the packaging conforms to, a reference to any standards or specifications used, a note on notified body involvement, and space for additional relevant information. The entire DoC has to carry an identification number that allows for referencing the document.
Points 4 through 6 draw on the manufacturer’s technical documentation under Annex VII, which covers design, materials, and test results. For manufacturers who don’t produce their own materials, that documentation depends on data from suppliers under Article 16, which we cover in our post on PPWR supplier obligations.
PPWR Declaration of Conformity Template: A Worked Example
Here is what each of the eight points actually asks for, illustrated with a fictional company, Nordhaven Foods, declaring a plastic food container. The content below is for illustration only, not a real company or a real declaration, and the regulation’s own wording for point 3 should be used exactly rather than paraphrased.
- Unique identification of the packaging. A type, batch, or serial number, or another element that makes this specific packaging identifiable. Example: NH-PT-250ML-V2.
- Name and address of the manufacturer. The manufacturer’s name, registered trade name or trademark, and postal address, plus the authorized representative’s details where one has been appointed. Example: Nordhaven Foods GmbH, Hafenstraße 12, 20457 Hamburg, Germany.
- A statement of sole responsibility. A direct statement that the declaration is issued under the sole responsibility of the manufacturer. Example: “This declaration of conformity is issued under the sole responsibility of the manufacturer.”
- The object of the declaration. A description of the packaging precise enough to allow traceability: the packaging type, packaging level, components, and materials. Example: 250ml rigid PET food container with polypropylene lid, single-use.
- Conformity with the relevant Union harmonization legislation. The object of the declaration described in Point 4 is in conformity with the relevant Union harmonization legislation:
- Regulation (EU) 2025/40 on packaging and packaging waste
- Harmonized standards, common specifications, or technical specifications applied. As of today, no harmonised standards under Article 36 or common specifications under Article 37 have been published for these requirements. Until they are, this point could reference the analytical methods and internal assessments documented in the technical file rather than a published standard.
- The notified body, where applicable. PPWR uses Module A, internal production control, so no notified body is involved. This point typically reads “not applicable.”
- Additional information. Anything further relevant to the declaration: the signatory’s role, cross-references to related declarations, or notes on packaging components assessed separately.
Signature block. Place and date of issue, and the name, function, and signature of the person signing on the manufacturer’s behalf.
How Long to Keep a PPWR Declaration of Conformity
The Declaration of Conformity and the technical documentation behind it must be kept available for 5 years for single-use packaging and 10 years for reusable packaging, counted from the date that packaging was placed on the market.
The declaration is not a one-time document. If the packaging changes, or the requirements it was assessed against change, the conformity of the packaging must be reassessed. It must also be drawn up in, or translated into, the language(s) required by each Member State where the packaging is placed on the market, so a single English version will not cover every market.
Common PPWR Declaration of Conformity Mistakes
Treating a quality certificate as a substitute. An ISO 9001 certificate or a food-contact declaration does not replace a PPWR Declaration of Conformity. The declaration must explicitly reference Regulation (EU) 2025/40.
Issuing one declaration for your whole portfolio. Annex VIII requires each declaration to identify a specific packaging type. A general statement covering “all our packaging” does not meet that requirement.
Not updating the declaration when things change. A declaration that was correct when issued can become outdated if the packaging changes or the standards it references are updated. Nothing triggers a review automatically, so you need to track it yourself.
Signing in the wrong role. Responsibility shifts in defined situations. A microenterprise’s supplier becomes the manufacturer, and a distributor becomes one when it places packaging on the market under its own brand. If you get this wrong, the wrong party signs, or no one does. We cover what happens when documentation gaps like this surface in an audit in our post on PPWR non-compliance.
Frequently Asked Questions
What is a PPWR Declaration of Conformity?
A written, self-issued statement from the manufacturer confirming that a specific packaging type meets the applicable requirements of Regulation (EU) 2025/40, following the structure set out in Annex VIII.
What is the difference between the Declaration of Conformity and technical documentation?
The declaration is the signed conclusion. The technical documentation, required under Annex VII, is the evidence, design drawings, material specs, and test reports, that supports it.
Who signs the PPWR Declaration of Conformity?
The manufacturer, under its own sole responsibility.
How long do I need to keep a PPWR Declaration of Conformity?
5 years for single-use packaging, 10 years for reusable packaging, from the date the packaging was placed on the market.
Is there an official PPWR Declaration of Conformity template?
No downloadable form is published by the European Commission. Instead, Annex VIII of Regulation (EU) 2025/40 defines the mandatory 8-point structure directly.
How PAQR Can Help
PAQR helps you collect the data behind each point of the Annex VIII structure, check how ready your supporting technical documentation is, and generate the Declaration of Conformity. You can share the DoC with partners and download it in 24 official EU languages.
Click “Try now for free” to start a free trial:
