The PPWR Declaration of Conformity: What It Is, What It Contains, Who Has to Sign It, and What to Do Now

An earlier version of this article was published on Packaging Europe. This version was reviewed and updated on 8 September 2026.

The Packaging and Packaging Waste Regulation (PPWR) has generally applied since 12 August 2026. For packaging placed on the EU market, the declaration of conformity is now part of the manufacturer’s compliance work. The practical questions are which legal entity is responsible, which requirements already apply to the packaging, and what evidence supports the declaration.

What is the PPWR declaration of conformity?

The EU declaration of conformity is the manufacturer’s statement that compliance with the applicable packaging requirements has been demonstrated. Article 39 of Regulation (EU) 2025/40 sets out the obligation. Annex VIII provides the model, while Annex VII describes the conformity assessment and supporting technical documentation.

The assessment concerns the requirements in Articles 5 to 12 that apply to the packaging. Their application dates differ. The general start date does not bring every later recyclability, recycled-content, minimisation or labelling requirement into effect at once. The file should identify both the packaging and the requirements relevant at the time it is placed on the market.

Who is responsible, and who signs?

The responsible manufacturer is not always the converter that physically makes the empty pack. Packaging type, who commissions its design or manufacture, branding and the supply-chain arrangement all matter. There is also a specific micro-enterprise exception. Establish the role for the actual packaging and legal entities rather than assuming that a logo alone settles the question.

The manufacturer holds responsibility for conformity and the declaration. Annex VIII includes the name, function and signature of the person signing for and on behalf of that entity. An authorised representative can perform tasks covered by its written mandate. Supplier reports, consultants or laboratories can support the work; they do not automatically take over the manufacturer’s responsibility.

The producer is a separate PPWR role associated with extended producer responsibility, including registration, reporting and fees in the relevant market. A company may hold both roles, but they must be assessed separately.

What must the declaration contain?

Use the Annex VIII model and complete the applicable fields:

• Identification of the declaration and the packaging concerned.
• The manufacturer’s name and address, and the authorised representative’s details where applicable.
• A statement that the manufacturer issues the declaration under its own responsibility.
• A packaging description that allows traceability.
• The relevant Union legislation and the standards, common specifications or other technical specifications used.
• Notified-body information where applicable, and any additional information needed.
• The entity on whose behalf it is signed, the place and date, and the signatory’s name, function and signature.

Annex VII requires a declaration for each packaging type. Define those types and their evidence coverage explicitly; an SKU count is not automatically a declaration count. Article 39 also requires the declaration to be kept updated and drawn up in, or translated into, the language or languages required by the Member State where the packaging is placed or made available on the market.

What evidence belongs behind it?

The technical documentation must support an assessment of conformity and the risks of non-conformity. Depending on the packaging and applicable requirements, it includes:

• A description of the packaging, intended use, design and component materials.
• Relevant drawings, specifications and explanations.
• The standards or technical specifications used, and how requirements are met where those are not applied.
• Relevant assessments, calculations and test reports.

Supplier evidence must match the packaging and components covered by the declaration. A generic certificate is not a substitute for checking its scope. For example, the PPWR PFAS limits concern food-contact packaging; an evidence request should distinguish that scope from other substance requirements. See our explanation of the PPWR PFAS limits.

What should packaging teams do now?

1. Confirm the manufacturer and other relevant roles for each supply-chain arrangement.
2. Identify packaging types and map the requirements and application dates that concern them.
3. Review existing specifications, supplier information and reports. Record gaps and assign owners.
4. Complete the conformity assessment, technical file and declaration, with an authorised approval and signing process.
5. Maintain version control and reassess changes that could affect conformity.
6. Keep the declaration and technical documentation for five years after single-use packaging is placed on the market, or ten years for reusable packaging.

If responsibility or evidence is unclear, PSL’s PPWR advisory and declaration of conformity support helps teams establish roles, structure technical files and prepare supplier requests. Where the assessment calls for packaging changes, we connect it to portfolio strategy and development and implementation.

This article provides general information, not legal advice. Assess the requirements against the packaging, supply chain and law applicable to your situation.