PPWR Declaration of Conformity: What It Must Contain and Who Signs It

What is the PPWR declaration of conformity?

The PPWR declaration of conformity is the manufacturer's written statement that a packaging type meets the requirements of Articles 5 to 12 of the PPWR that apply to it: substances, recyclability, recycled content, compostability, minimisation, reusability and labelling. It follows the model structure in Annex VIII and must be supported by technical documentation under Annex VII.

Article 39 sets four rules worth knowing before you ask a supplier for anything:

• It states that fulfilment of the applicable requirements of Articles 5 to 12 "has been demonstrated", so it is a conclusion drawn from evidence, not a substitute for it.
• It must follow the Annex VIII model structure, contain the elements of the Annex VII module and be "continuously updated".
• It must be 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.
• By drawing it up, the manufacturer assumes responsibility for the packaging's compliance.

Where other EU acts also require an EU declaration of conformity for the same packaging or packaged product, a single declaration covering all of them should be drawn up where appropriate (Article 39(3)). Competent authorities are expected to check the accuracy of a share of declarations each year on a risk basis, so the document will be read.

Who draws up and signs the PPWR declaration of conformity?

The manufacturer as defined in Article 3(1), point (13) draws up and signs the declaration. For custom printed packaging, that is usually the business that has the packaging designed or manufactured under its own name or trademark, so a restaurant chain ordering branded cups or a retailer ordering branded mailer boxes is normally the manufacturer, even though a converter produces the item.

The definition covers anyone who manufactures packaging, but where a business has packaging designed or manufactured under its own name or trademark, that business is the manufacturer, "regardless of whether any other trademark is visible". The Commission's guidance notice C(2026) 3702 applies this to service and transport packaging: the converter is normally the manufacturer unless the packaging is clearly branded by its user, in which case the user is the manufacturer.

Three practical consequences follow:

• The micro-enterprise exception (fewer than 10 staff and turnover or balance sheet no more than EUR 2 million) shifts the role to the supplier only when the supplier is in the same Member State (Article 3) or, as Article 15(12) puts it, in the Union. A Turkish or Chinese converter cannot take over the role this way.
• The manufacturer may have the conformity assessment carried out on its behalf, for example by a laboratory or the supplier, and may mandate an authorised representative to keep the documentation. Legal responsibility stays with the manufacturer, whoever drafted the paperwork.
• National authorities are still settling how they apply the definition to empty printed service packaging handed out by food businesses. Confirm your status with the competent authority or your compliance scheme, especially where you operate in several Member States.

What the importer has to do

The importer is the EU-established business that places packaging from a third country on the EU market. Under Article 18, before placing it on the market, the importer must make sure that the manufacturer has carried out the conformity assessment and drawn up the Annex VII technical documentation, that the packaging is labelled in line with Article 12 and accompanied by the required documents, and that the manufacturer's identification and contact details are present (Article 15(5) and (6)).

The importer also adds its own name, trade name or trademark and postal address on the packaging, or via a data carrier or accompanying document where that is not possible; keeps a copy of the declaration for 5 or 10 years; ensures the technical documentation can be produced on request; and supplies documents to authorities within 10 days of a reasoned request. If the importer has reason to believe the packaging does not conform, it must not place it on the market. When a brand owner imports its own printed packaging, it often holds both the manufacturer and importer roles at once.

What goes into the Annex VII technical documentation?

The technical documentation is the evidence file behind the declaration. Annex VII (Module A, internal production control) requires it to make conformity assessable, include an analysis and assessment of the risks of non-conformity, and contain at least the elements below wherever applicable.

Annex VII also requires the manufacturer to control manufacturing so that series production matches the documentation, and Article 15(4) requires re-assessment when design, materials or the referenced standards change. A change of coating, ink system or board supplier is exactly the kind of change that should trigger a review of the file.

Two timing points from the Commission's guidance are useful. The PFAS limits in Article 5(5) apply to food-contact packaging from 12 August 2026, so PFAS evidence belongs in the file now. For recyclability, the guidance says manufacturers do not need to perform the PPWR conformity assessment until the design-for-recycling delegated acts under Article 6(4) enter into force; until then, the old Packaging Directive requirements and standards such as EN 13430 remain the reference. Grade mechanics are explained in our guide to PPWR recyclability grades.

How long must the declaration and technical documentation be kept?

The manufacturer must keep the technical documentation and the declaration for 5 years after single-use packaging is placed on the market and for 10 years after reusable packaging is placed on the market (Article 15(3) and Annex VII point 4). Importers keep a copy of the declaration for the same periods, and an authorised representative can hold the documentation under a written mandate.

Because the clock runs from placing on the market, a cup design reordered every quarter for three years generates a retention obligation that extends well beyond the last delivery. Link each declaration to an item code and version, archive superseded versions rather than overwriting them, and keep the supplier data that supported each version.

Which language must the declaration be in?

The declaration must be drawn up in, or translated into, one or more languages required by the Member State where the packaging is placed on, or made available on, the market (Article 39(2)). A chain supplying Germany, Austria and the Netherlands should expect to need German and Dutch versions, plus English if that is its working language.

For documents requested by authorities, Article 15(10) asks for a language "easily understood by that authority", supplied electronically and, on request, on paper, within 10 days. Supplier information under Article 16 must be in a language the manufacturer easily understands, which in practice is often English for a Turkish or Asian supplier.

What should you request from a non-EU packaging supplier?

Ask for the information you need to complete the technical documentation and sign the declaration yourself. Article 16 obliges suppliers of packaging or packaging materials to give the manufacturer "all the information and documentation necessary" to demonstrate conformity, including Annex VII documentation, in paper or electronic form.

A practical request list for each printed item:

• Materials and construction: board or paper grade and grammage, fibre type (virgin or recycled), coating or lining type and coat weight, film structure for laminates and windows, inks and varnishes (type, not formulation), adhesives, and component weights per unit.
• Substances: a statement on the sum of lead, cadmium, mercury and hexavalent chromium (limit 100 mg/kg under Article 5(4)); for food-contact items, PFAS evidence against Article 5(5): targeted analysis results or a total fluorine screen, and the material supplier's proof of fluorine source where total fluorine exceeds 50 mg/kg. Test methods are covered in our PFAS-free food packaging guide.
• Recyclability information: the predominant material and Annex II category the item falls into, separability of components (windows, liners, handles), and any repulpability or recyclability test or mill statement available today. Coating choices are compared in our guide to barrier coatings for paper packaging.
• Recycled content: for plastic components (bags, pouches, lids), the recycled share and its documentation, ahead of the Article 7 targets from 2030 at the earliest. Not applicable to paper.
• Minimisation evidence: why the weight and volume are needed for function (strength, stacking, grease or heat resistance, print area), with the dieline and any test results. Article 10 applies from 2030, but the reasoning is easier to build when the item is specified.
• Identification: the batch or lot reference printed or attached, and confirmation that your name and address (and the importer's) can be placed on the packaging or a data carrier.
• Change notification: a commitment to tell you before changing any material, coating, ink system or mill.

At 9 Packaging, the documentation set for each item is agreed during quotation and technical review, because it depends on materials, construction and the countries where you will place the packaging on the market. You can include the list above in your packaging request for quotation.

How is it different from the food-contact Declaration of Compliance?

They are separate documents with different legal bases. The PPWR declaration of conformity covers packaging sustainability and labelling requirements (Articles 5 to 12 of Regulation (EU) 2025/40) and is signed by the PPWR manufacturer. The food-contact Declaration of Compliance covers safety of materials in contact with food under Regulation (EC) 1935/2004 and, for plastic layers, Regulation (EU) 10/2011, and is issued along the supply chain by each business placing the material or article on the market.

A PFAS test report may support both. Neither document replaces the other. For the food-contact side, see food-contact packaging compliance in the EU, UK and US.

Outline of a PPWR declaration of conformity

The outline below follows the order of Annex VIII and adds the practical detail buyers tend to need. It is a structured outline for discussion with your compliance adviser, not a legal template; check the current wording of Annex VIII and any Commission guidance or national requirements before issuing a declaration.

1. Declaration number: a unique identification of the packaging (for example item code plus version).
2. Name and address of the manufacturer and, where applicable, the authorised representative.
3. Statement that the declaration is issued under the sole responsibility of the manufacturer.
4. Object of the declaration: identification allowing traceability and a description of the packaging (format, dimensions, materials and components, single-use or reusable, food contact yes/no). A photo or drawing reference helps.
5. Statement that the object is in conformity with the relevant Union harmonisation legislation: Regulation (EU) 2025/40, naming the applicable requirements of Articles 5 to 12, plus references to other Union acts applied.
6. References to the harmonised standards, common specifications or other technical specifications against which conformity is declared.
7. Where applicable, notified body details (normally not applicable to packaging assessed under Module A).
8. Additional information: for example the technical documentation reference, the batch or lot identification method, and the version history.
9. Signature block: signed for and on behalf of, place and date of issue, name and function, signature.

Keep the declaration with the technical documentation and update it whenever the item changes. Annex VIII uses the identification number of the declaration as a footnote reference, so keep that number stable across language versions.

Next step: build the file before the next reorder

Pick your highest-volume branded items first. For each, record the manufacturer and importer for each country of supply, then send the supplier request list above with your next order or specification change. If you are specifying new printed packaging for EU markets, send the item list, target countries and food-contact use through our contact page for technical review. Labelling plans for the same items are covered in our guide to PPWR labelling requirements.