The PPWR declaration of conformity: contents, signatory and validity
The PPWR declaration of conformity is the document by which the manufacturer states that a packaging type meets the requirements of Articles 5 to 12 of Regulation (EU) 2025/40. Article 39(1) says exactly that, and nothing more elaborate. It becomes due on 12 August 2026, the date from which the Regulation applies under Article 71.
The route to it is short. Article 38 sends the conformity assessment to Annex VII, which contains a single module, Module A, internal production control. The manufacturer draws up the technical documentation, then the declaration, following the model structure of Annex VIII. No notified body takes part and no authority approves anything.
This page sets out what the declaration must contain point by point and who signs it. It also covers when a new version is due, what happens when the document is missing, and how the obligation works in Northern Ireland and in Great Britain. Passages that rest on Commission guidance rather than on the Regulation are marked as such.
What the PPWR declaration of conformity is, in the words of the Regulation
Article 39(1) requires the declaration to state that the fulfilment of the requirements of Articles 5 to 12 has been demonstrated. Article 39(2) then adds three things at once. The model structure of Annex VIII, the elements specified in the module set out in Annex VII, and continuous updating. The document is drawn up in, or translated into, the languages required by each Member State where the packaging is placed or made available.
Article 39(4) is the sentence that decides where responsibility lands. By drawing up the declaration, the manufacturer assumes responsibility for the compliance of the packaging with the requirements laid down in the Regulation. Point 3 of the Annex VIII model repeats the idea in fixed wording: the declaration is issued under the sole responsibility of the manufacturer.
Granularity comes from Annex VII. Point 4 of Module A requires a written declaration of conformity for each packaging type. It is kept together with the technical documentation at the disposal of the national authorities, and a copy of the declaration is made available to the relevant authorities upon request.
It is a self-declaration, not a certificate
Nothing in the Regulation creates a PPWR certificate, and there is no PPWR certification scheme to apply to. Article 38 routes the assessment to Annex VII, Annex VII contains Module A alone, and Module A involves no notified body. Annex VIII does carry a notified-body field at point 7, marked where applicable, and for packaging it stays empty.
Test reports, recyclability assessments and supplier certificates feed the technical documentation. None of them is the declaration, and none of them shifts the responsibility that Article 39(4) attaches to whoever draws the declaration up.
Where the reference to a 2019 regulation comes from
Searches for a 2019 packaging regulation usually land on Regulation (EU) 2019/1020 on market surveillance or on Directive (EU) 2019/904 on single-use plastics. The confusion has a real source. The full title of the PPWR is a regulation on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC. The declaration obligation itself comes from Regulation (EU) 2025/40 alone, through Articles 38 and 39.
Declaration of conformity, certificate of conformity (CoC), CE marking and declaration of compliance
| Instrument | Who issues it | What it does for packaging |
|---|---|---|
| EU declaration of conformity | The manufacturer, as a self-declaration | Due from 12 August 2026 for every packaging type, under Article 39 and Annex VIII. |
| Certificate of conformity | A third party, typically a certification body | Not provided for by the PPWR. Module A involves no notified body, so no certificate exists for this purpose. |
| CE marking | The manufacturer, under the Union acts that provide for it | Not provided for by the PPWR. Packaging is not CE marked on the basis of this Regulation. |
| Declaration of compliance, food contact | The business operator at each stage of the chain | A separate document under Regulation (EC) No 1935/2004 and Regulation (EU) No 10/2011. It neither replaces the PPWR declaration nor is replaced by it. |
Food packaging normally needs both documents. They answer to different acts and cover different risks, and they are requested together in supplier documentation reviews.
Article 39(3) covers packaging subject to more than one Union act requiring a declaration. A single declaration may cover all of them, provided it states the acts concerned and their publication references. The same paragraph allows a dossier of the individual declarations instead.
Who draws up the PPWR declaration of conformity
The manufacturer does, for each packaging type it places on the market. Article 3(1), point (13), decides who that is. The first limb points to whoever manufactures the packaging or the packaged product. Point (a) then displaces the role onto whoever has the packaging designed or manufactured under its own name or trademark. Another trademark on the pack changes nothing.
| Situation | Who draws up the declaration | Legal basis |
|---|---|---|
| A converter produces and sells packaging as its own product | The converter | Art. 3(1)(13) |
| A brand owner has packaging made under its own name or trademark | The brand owner | Art. 3(1)(13)(a) |
| The brand owner is a micro-enterprise and the supplier is in the same Member State | The supplier of the packaging | Art. 3(1)(13)(b) |
| The brand owner is a micro-enterprise and the supplier is anywhere in the Union | The supplier, for the purposes of Article 15 only | Art. 15(12) |
| An importer or distributor sells packaging under its own name or trademark, or modifies it in a way that could affect compliance | That importer or distributor, as manufacturer | Art. 21, first paragraph |
| That importer or distributor is a micro-enterprise and its supplier is in the Union | The supplier, for the purposes of Article 15 | Art. 21, second paragraph |
The micro-enterprise thresholds, and how the two routes differ
A micro-enterprise employs fewer than 10 people and has an annual turnover or balance sheet total of at most EUR 2 million. The reference is Recommendation 2003/361/EC as applicable on 11 February 2025. The two routes differ in one more respect that is easy to miss. Article 3(1)(13)(b) speaks of the packaging or the packaged product; Article 15(12) speaks of the packaging only.
The importer verifies the declaration of conformity, and keeps a copy
An importer that does not fall under Article 21 draws up no declaration of its own. Article 18(2) sets four checks before placing packaging on the market. That the manufacturer carried out the Article 38 assessment and drew up the Annex VII documentation. That the packaging is labelled under Article 12. That the required documents accompany it. That Article 15(5) and (6) have been complied with.
Two further paragraphs are often merged into one and should not be. Article 18(3) requires the importer to indicate its own name, registered trade name or trademark and postal address on the packaging. Article 18(7) is a separate duty. The importer keeps a copy of the EU declaration of conformity at the disposal of the market surveillance authorities, and ensures the technical documentation can be made available on request. The periods are 5 years for single-use packaging and 10 for reusable.
What the distributor checks
Article 19(2) puts three checks on the distributor before it makes packaging available. That the producer subject to extended producer responsibility is registered under Article 44. That the packaging is labelled under Article 12. That the manufacturer and the importer have complied with Article 15(5) and (6) and Article 18(3). Article 19(4) adds a limit worth knowing. Information disclosed by the producer may not be used for any purpose other than verifying compliance, and its use for commercial purposes is prohibited.
Two authorised representatives, and only one of them touches the declaration
Article 17 allows a manufacturer to appoint an authorised representative by written mandate. The appointment is optional. Article 17(2) sets five tasks that the mandate has to allow, at a minimum:
- keep the declaration and the technical documentation at the disposal of the market surveillance authorities, for 5 or 10 years;
- cooperate with the competent national authorities on measures taken against non-compliant packaging covered by the mandate;
- upon a reasoned request, provide the authority with the information and technical documentation demonstrating conformity;
- upon a request, make relevant documents available within 10 days of receipt;
- terminate the mandate if the manufacturer acts contrary to its obligations under the Regulation.
The last subparagraph of Article 17(2) carves two things out of any mandate. The Article 15(1) obligation and the drawing up of the Annex VII technical documentation both stay with the manufacturer. The assessment can be carried out on the manufacturer’s behalf under Article 15(2); the documentation cannot be delegated at all.
The other authorised representative, under Article 45(3)
The Regulation uses the same words for a second, unrelated role. The authorised representative for the extended producer responsibility is defined in Article 3(1), point (20), and appointed under Article 45(3). It handles registration and contributions in a Member State where the producer is not established. That appointment is an obligation for producers falling under Article 3(1), point (15)(c) and (d), not an option. One mandate covers nothing of the other.
Proposal, not law. The Commission has tabled COM(2025) 982, a proposal for a regulation suspending the rules on the appointment of an authorised representative for the extended producer responsibility. It covers batteries and packaging. It has not been adopted, so it changes nothing today. It does not touch the Article 17 representative or any declaration of conformity obligation.
What the Annex VII technical documentation must contain
The declaration rests on a file, and the file has its own required contents. Point 2 of Module A requires the manufacturer to establish the technical documentation. It has to make the packaging’s conformity assessable, and to include an adequate analysis and assessment of the risks of non-conformity.
It then lists what the documentation shall contain, wherever applicable, as a minimum:
- a general description of the packaging and its intended use;
- conceptual design, manufacturing drawings and materials of components;
- the descriptions and explanations necessary to understand those drawings and the operation of the packaging;
- a list of the harmonised standards referred to in Article 36 and the common specifications referred to in Article 37, applied in full or in part. The list also covers the other technical specifications used for measurement or calculation, and the parts applied where a standard was applied only in part. Where none was applied, the file describes the solutions adopted instead;
- a qualitative description of how the assessments provided for in Articles 6, 10 and 11 have been carried out;
- test reports.
Who the Annex VII file is for, and who never sees it
The Annex VII file is internal. The declaration is what circulates. Two things follow from that, and they are worth settling before a customer asks.
Test reports sit at point 2(f) of Module A, inside the manufacturer’s own file, and the chapeau qualifies the whole list with wherever applicable: where conformity rests on calculation or on supplier documentation rather than on testing, there are no test reports to hold. The file goes to a national authority on a reasoned request, within 10 days, under Article 15(10). Point 4 sends only a copy of the declaration to the relevant authorities upon request.
Nothing in the Regulation obliges a manufacturer to hand its technical documentation to a customer. The one horizontal duty runs the other way: under Article 16 a supplier owes its manufacturer-customer the information and documentation that customer needs for its own file. A customer asking for test reports is asking on a contractual basis, not on a PPWR one.
Production control, and the requirements that route their evidence here
Point 3 adds the production side. The manufacturer takes all measures necessary so that the manufacturing process and its monitoring keep the packaging in line with the documentation. Point 5 lets the authorised representative keep the documentation on the manufacturer’s behalf, where the mandate says so, but not draw it up.
Several requirements route their evidence here explicitly. Article 5(6) for the substance limits, Article 7(6) for recycled content and Article 9(4) for compostable packaging all send the evidence to Annex VII. So do Article 10(4) for minimisation and Article 11(3) for reusable packaging. The file is therefore the single place where the whole of Articles 5 to 12 is evidenced.
What the declaration must contain, point by point
Annex VIII sets the model in eight numbered points followed by a signature block. The heading itself carries the declaration number.
| Point | What Annex VIII asks for | What goes in it |
|---|---|---|
| 1 | Unique identification of the packaging | The internal code of the packaging type. The declaration also carries its own identification number, in the heading. |
| 2 | Name and address of the manufacturer and, where applicable, of the authorised representative | Full legal name, registered office, country. The Article 17 representative goes here, where one is appointed. |
| 3 | Sole responsibility statement | Fixed wording, nothing to complete: this declaration of conformity is issued under the sole responsibility of the manufacturer. |
| 4 | Object of the declaration, allowing traceability | Description of the packaging type: format, material structure, dimensions, intended use, precise enough to reach the technical file. |
| 5 | Conformity with the relevant Union harmonisation legislation | Regulation (EU) 2025/40 and the applicable requirements of Articles 5 to 12, plus any other Union act applied, with its publication reference. |
| 6 | References to harmonised standards or common specifications | The harmonised standards, common specifications or other technical specifications against which conformity is declared. |
| 7 | Notified body, where applicable | Not applicable for packaging. Module A involves no notified body. |
| 8 | Additional information | Technical file reference, version number, date of the last update, and any declared classification once the Article 6(4) delegated acts apply. |
The signature block, and what the Regulation does not prescribe
The signature block closes the document. It reads: signed for and on behalf of the manufacturer, place and date of issue, name and function of the signatory, signature. The Regulation prescribes no signature format, so an electronic signature is a matter of national law and internal policy rather than of the PPWR. What the model does require is a named signatory with a stated function.
How long the declaration of conformity stays valid, and when a new version is due
The Regulation sets no expiry date. Article 39(2) requires the declaration to be continuously updated instead, which turns validity into a question of change control rather than of dates.
Article 15(4) names the triggers. The manufacturer keeps procedures in place so that series production remains in conformity. It also takes into account changes in packaging design or characteristics. The same applies to changes in the harmonised standards or technical specifications by reference to which conformity is declared. Where conformity could be affected, the Article 38 assessment is carried out again.
A new film supplier, a changed adhesive, a revised structure or an updated standard each produce a new version. A new print artwork on the same structure does not, unless it touches the Article 12 label or obscures the Article 15(6) information.
Under Article 15(3), the declaration and the Annex VII documentation are kept for 5 years for single-use packaging and 10 years for reusable packaging. The period runs from the date the packaging was placed on the market. Superseded versions stay on file for the same period: they are what shows which declaration covered which production run.
One declaration per packaging type, not per SKU and not per batch
Annex VII point 4 fixes the unit: a written declaration of conformity for each packaging type. Point 1 of Annex VIII identifies that type. Point 4 describes it precisely enough to trace every pack in the family back to the same technical documentation.
What defines a type is what conformity depends on. That means the material composition and structure, the requirements that apply, and the assessments behind them. Two pouches sharing a laminate structure and differing only in print belong to the same type. The same pouch in a different structure, or with a different barrier layer, is a different type with its own declaration.
The arithmetic usually works in the manufacturer’s favour. A portfolio of, say, 180 bag and pouch references often collapses to a low double-digit number of packaging types once grouped by structure. A few monomaterial PP families, a few monomaterial PE families, the PET/PE barrier duplexes and a handful of specials. The figures are illustrative, the direction is not. The grouping work is done once, and the declaration count follows structures rather than article numbers.
Batch identification stays in production records and, where relevant, in the technical documentation. The declaration is versioned on change, not reissued per batch.
What happens when the declaration of conformity is missing or wrong
Article 62 is the article to read, and it is the one most summaries skip. It lists fourteen circumstances, points (a) to (n). Paragraph 1 attaches the same first step to all of them: the Member State requires the operator to put an end to the non-compliance.
| Article 62(1) | Circumstance |
|---|---|
| (a) | The EU declaration of conformity has not been drawn up. |
| (b) | The EU declaration of conformity has not been drawn up correctly. |
| (d) | The technical documentation of Annex VII is not available, is not complete or contains errors. |
| (e) | The Article 15(6) or Article 18(3) information is absent, false or incomplete. |
| (f) | Any other administrative requirement of Article 15 or Article 18 is not fulfilled. |
Where non-compliance of that kind persists, Article 62(2) applies. The Member State takes all appropriate measures to prohibit the packaging from being made available, or to ensure it is recalled or withdrawn. For the substantive points (g) to (n), Article 62(3) routes the matter to the national penalties instead.
National penalties, and the two duties that run alongside
Those penalties are laid down nationally. Article 68(1) requires Member States to adopt them by 12 February 2027, effective, proportionate and dissuasive. Article 68(3) sets the same date for notifying the Commission. Article 68(2) requires that the penalties for Articles 24 to 29 include administrative fines.
Two duties run alongside. Article 15(8) applies to a manufacturer that has reason to believe packaging it placed on the market is not in conformity. It brings the packaging into conformity, withdraws it or recalls it, and informs the market surveillance authority. Article 15(9) exempts reusable packaging placed on the market before 11 February 2025. Article 39(5) works from the other side. Competent authorities are to endeavour to control the accuracy of at least part of the declarations each year, on a risk-based approach.
Northern Ireland and Great Britain
The PPWR applies in Northern Ireland and not in Great Britain. The mechanism is the Windsor Framework. The Commission set it out in a dedicated notice, Commission Notice C/2025/946 of 4 February 2025, on the application of Regulation (EU) 2025/40 to and in the United Kingdom in respect of Northern Ireland.
For packaging placed on the market in Northern Ireland, the conformity obligations run as they do in any Member State. That means the Article 38 assessment, the Annex VII documentation and the Article 39 declaration. The provisions the notice excludes concern system obligations rather than product conformity. Northern Ireland stays inside the United Kingdom’s own packaging producer responsibility scheme.
In England, Scotland and Wales the Regulation is not domestic law, and packaging sold only there needs no EU declaration. The obligation attaches the moment packaging is placed on the Union market. Either the EU importer has to be able to produce the manufacturer’s declaration under Article 18(7). Or the British company itself counts as the manufacturer under Article 3(1), point (13), and draws the declaration up.
Frequently asked questions
Is a declaration of conformity a legal requirement for packaging?
Yes, from 12 August 2026. Article 39 of Regulation (EU) 2025/40 requires an EU declaration of conformity for every packaging type placed on the Union market. It is not filed with any authority and nobody approves it, but the manufacturer has to produce it when a market surveillance authority asks. Article 62(1)(a) treats a missing declaration as non-compliance in its own right.
Who signs the PPWR declaration of conformity?
A person with authority to bind the manufacturer. The Regulation names no role. Annex VIII requires the declaration to be signed for and on behalf of the manufacturer. The place and date of issue and the name and function of the signatory go with it. In practice that is a legal representative or an empowered technical or quality function.
How do I obtain a PPWR declaration of conformity?
You do not obtain it, you draw it up. The manufacturer carries out internal production control under Article 38 and Annex VII, compiles the technical documentation and issues the declaration itself. No notified body takes part, no fee is due and no approval is issued. Suppliers owe the input information under Article 16.
Does the declaration expire?
No. The Regulation sets no expiry date and requires continuous updating instead, under Article 39(2). A change in the packaging design, in its characteristics or in the standards it references triggers a fresh assessment. Article 15(4) is the basis. Superseded versions stay on file for the 5 or 10 year period of Article 15(3).
What is the difference between a declaration of conformity and a declaration of compliance?
Different acts, different risks. The declaration of conformity covers the packaging requirements of Articles 5 to 12 of the PPWR. The declaration of compliance covers food-contact safety, under Regulation (EC) No 1935/2004 and, for plastics, Regulation (EU) No 10/2011. Food packaging normally needs both, and neither replaces the other.
Do importers need a declaration of their own?
No. Article 18(2) requires the importer to verify that the manufacturer carried out the assessment and drew up the documentation. Article 18(7) requires it to keep a copy of the manufacturer’s declaration at the disposal of the authorities. The exception is Article 21. An importer or distributor placing packaging on the market under its own name or trademark becomes the manufacturer and draws the declaration up itself.
Is a declaration required for transport packaging?
Yes. Article 2(1) applies the Regulation to all packaging and Article 15(1) makes no distinction. Pallet wrap, stretch film and shipping bags each need a declaration, on the same per-type logic. The exclusion of transport packaging in Article 12(1) concerns the harmonised label, not the declaration.
Can one declaration cover several regulations?
Yes. Article 39(3) allows a single EU declaration of conformity where more than one Union act requires one. The declaration has to state the acts concerned and their publication references. It may also take the form of a dossier of the individual declarations.
Sources
Regulation (EU) 2025/40, Articles 2, 3, 12, 15, 16, 17, 18, 19, 21, 36, 37, 38, 39, 44, 45, 62, 68 and 71. Annexes VII and VIII. Text as published in the Official Journal L of 22 January 2025. Commission Notice on the guidance document for Regulation (EU) 2025/40, Official Journal C, 2026/3084 of 10 June 2026. Commission Notice C/2025/946 of 4 February 2025, on Northern Ireland. COM(2025) 982, a Commission proposal that has not been adopted.
Recommendation 2003/361/EC, Annex, Article 2(3), for the micro-enterprise definition. Regulation (EC) No 1935/2004 and Regulation (EU) No 10/2011 for food-contact materials. Neither the guidance document nor the Commission FAQ is legally binding. Every article and paragraph reference on this page was checked against the Official Journal text rather than against secondary sources. This page explains a legal obligation and is not legal advice.
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Content reviewed by Laura Ionescu · 17.08.2026