From 12 August 2026, every packaging item placed on the EU market under Regulation (EU) 2025/40 needs an EU Declaration of Conformity signed by the manufacturer. The document is short, often a single page, but it sits on top of a technical file that can run to dozens of pages per SKU. Get the structure wrong and the declaration is legally invalid, the packaging cannot be marketed, and the manufacturer carries the liability. This guide breaks down what goes into the DoC, what backs it up in the technical file, and how to scale the workflow across thousands of references.
What is a PPWR Declaration of Conformity?
The PPWR Declaration of Conformity (DoC) is a written self-declaration where the manufacturer states that a specific packaging type meets the sustainability requirements of Articles 5 to 12 of Regulation (EU) 2025/40. It follows the template in Annex VIII and references the technical documentation compiled under Annex VII, Module A. The DoC is mandatory from 12 August 2026 with no grandfathering window.
Who Signs the Declaration?
The "manufacturer" in PPWR terms is the legal person who makes the packaging or has it made and markets it under their name or trademark (Article 3). For private-label situations this is often the brand owner, not the converter. Importers who place packaging on the EU market under their own brand are also treated as manufacturers under Article 21. Distributors who repackage or substantially modify packaging step into the manufacturer's shoes too.
This matters because the signature on the DoC carries personal liability for the legal entity, not the individual. Authorised representatives appointed under Article 22 can sign on behalf of non-EU manufacturers, but the underlying technical file still has to exist and be available to market surveillance authorities within reasonable time.
Annex VIII: Mandatory Content of the DoC
The declaration template under Annex VIII is prescriptive. Missing any field renders the DoC invalid, which is treated under PPWR as if no declaration existed at all. The minimum content set:
| Field | Source / Notes |
|---|---|
| Unique identification of the packaging | Internal SKU, type, model, version |
| Name and address of the manufacturer (or authorised representative) | Legal entity, not trading name |
| Statement that the DoC is issued under the sole responsibility of the manufacturer | Verbatim Annex VIII wording |
| Identification of the packaging allowing traceability | Photo or technical drawing reference |
| Reference to Regulation (EU) 2025/40 and applicable articles | Articles 5 to 12 typically |
| References to harmonised standards used | EN standards once published |
| References to common specifications used | Where harmonised standards do not exist |
| Place and date of issue | Each revision triggers a new DoC |
| Signature, name and function of signatory | Authorised person within the legal entity |
The Technical File Behind the DoC
The DoC is the visible tip. The iceberg is the technical documentation under Annex VII, which the manufacturer must keep current and produce on request. Module A (internal production control) is the standard conformity assessment route, meaning no third-party notified body is involved. The manufacturer assesses internally, signs internally, and is auditable externally.
Annex VII technical documentation includes:
- A general description of the packaging type, intended use, and identification details.
- Drawings, schematics, and material composition (layer by layer for multi-material packaging).
- Supplier declarations covering each raw material, especially regarding substances of concern.
- Conformity assessments demonstrating compliance with recyclability, minimisation, and reusability obligations.
- For food-contact packaging: PFAS test reports from ISO/IEC 17025 accredited laboratories, per the thresholds described in the PFAS ban explainer.
- List of harmonised standards applied and, where standards do not cover a requirement, the alternative solutions adopted.
- Results of design verification, calculations, simulations, and any third-party tests used as evidence.
How Long to Keep the Documentation
Retention periods are fixed by PPWR and longer than under the previous directive. For single-use packaging, manufacturers must keep the DoC and technical file for at least five years after the last unit is placed on the market. For reusable packaging, the period extends to ten years. The clock starts not from manufacturing date but from the last placement on the market, which means active product families need rolling documentation upkeep, not a one-off file.
Operationalising the DoC Across Thousands of SKUs
Most manufacturers do not have one packaging type. A mid-sized FMCG brand can have hundreds of primary SKUs, each with its own primary, secondary and transport packaging, and each combination needs its own DoC. The August 2026 deadline forces a scalable workflow. Common pitfalls and how to handle them:
| Pitfall | Mitigation |
|---|---|
| Treating DoC as a template-fill exercise | Build the underlying technical file first; DoC is a downstream artefact |
| Missing supplier data on multi-layer films | Issue PPWR supplier questionnaires immediately, with contractual deadlines tied to August 2026 |
| One DoC for a packaging family across variants | Each unique material specification needs its own DoC; SKU-level granularity |
| No version control | DoCs are dated documents; any change to recyclability grade, recycled content, or PFAS supplier triggers reissuance |
| PDF-only storage with no search | Use a structured database; market surveillance audits are time-bound |
Importers and Distributors: Verification Duties
Importers cannot rely on the supplier's word alone. Before placing packaging on the EU market they must verify that the manufacturer has performed the conformity assessment, that the DoC is drawn up, and that the technical documentation exists. Distributors have a lighter due-diligence duty: check the DoC accompanies the packaging where required, and check labelling. Both can become "manufacturers" under Article 21 if they modify the packaging in a way that affects compliance, or sell it under their own brand.
Penalties for Non-Compliance
PPWR delegates the penalty regime to Member States, requiring "effective, proportionate and dissuasive" sanctions. National implementing measures will land between now and August 2026. Practical exposure includes administrative fines proportional to turnover, mandatory recall of non-compliant stock, exclusion from public procurement, and reputational disclosure. Several Member States are signalling fines tied to placed-on-market volume, not flat amounts.
How the DoC Integrates with the Digital Product Passport
The DoC is text-based today but PPWR allows electronic formats. A natural evolution is to host the DoC behind the QR code data carrier that becomes mandatory from August 2028. Brands already building a DPP for packaging can attach the DoC as a structured field, giving market surveillance authorities, recyclers and consumers a single scan path. The same approach is being used for batteries under Regulation (EU) 2023/1542, see the battery passport guide for the precedent.
Frequently Asked Questions
Can one Declaration of Conformity cover multiple packaging SKUs?
Only if the SKUs share the exact same material composition, structure and supplier chain. Different ink coverage, different label adhesives, or a different barrier-layer supplier means a different DoC. Most manufacturers will end up with one DoC per unique packaging specification.
Does the DoC need to be physically with the packaging?
Not on the unit itself. The DoC must be made available to market surveillance authorities on request, and accompany the packaging through the supply chain in a way that distributors and importers can access it. Electronic delivery is acceptable.
Who is liable if the supplier provides false data?
The manufacturer signing the DoC carries primary liability towards authorities. Contractual recourse against the supplier is a separate civil matter. This is why PPWR-grade supplier agreements typically include audit rights, indemnification clauses, and termination triggers tied to non-compliance.
Do reusable packaging systems need a DoC per cycle?
No. The DoC is issued when the packaging is first placed on the market. Reusable systems need a DoC covering the design and intended reuse cycles, plus documentation of the reuse system itself under Article 11. Retention runs ten years.