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What is the PPWR Declaration of Conformity?

Regulation (EU) 2025/40 — the Packaging and Packaging Waste Regulation, or PPWR — entered into force on 11 February 2025 and applies from 12 August 2026. Under Article 15(1), manufacturers may only place packaging on the market where it conforms to the requirements laid down in or pursuant to Articles 5 to 12.

Article 15(2) sets the order of operations. Before placing packaging on the market, the manufacturer carries out the conformity assessment procedure referred to in Article 38, or has it carried out on their behalf, and draws up the technical documentation referred to in Annex VII. Where compliance has been demonstrated by that procedure, the manufacturer then draws up an EU Declaration of Conformity in accordance with Article 39. By drawing it up, Article 39(4) states, the manufacturer assumes responsibility for the packaging’s compliance.

What Annex VIII requires: the eight points

Article 39(2) requires the declaration to follow the model structure set out in Annex VIII to the Regulation. That model has eight numbered points, followed by an unnumbered signature block and a footnote carrying the declaration’s own identification number.

1. The unique identification of the packaging.
2. The name and address of the manufacturer and, where applicable, of the manufacturer’s authorised representative.
3. A statement that the declaration is issued under the sole responsibility of the manufacturer.
4. The object of the declaration — identification of the packaging allowing traceability, and a description of it.
5. A statement that the object of the declaration referred to in point 4 is in conformity with the relevant Union harmonisation legislation, with a reference to the other Union acts applied.
6. References to the relevant harmonised standards or common specifications used, or to the other technical specifications in relation to which conformity is declared.
7. Where applicable, the notified body — its name, address and number — the intervention it performed, and the certificates it issued.
8. Additional information.

A point that does not apply to your packaging is not simply dropped: the numbering of the model is what a market surveillance authority reads against. This generator renders all eight points, marking those that do not apply as such.

Who assesses conformity? Module A, Annex VII

Article 38 refers conformity assessment to the procedure set out in Annex VII, which is Module A — internal production control. Under Module A the manufacturer ensures and declares conformity on their sole responsibility; no notified body intervenes. That is why point 7 of the declaration normally reads “not applicable” for packaging.

Module A also requires the manufacturer to establish technical documentation allowing conformity to be assessed, including an analysis and assessment of the risks of non-conformity. It must contain, wherever applicable, at least: a general description of the packaging and its intended use; the conceptual design, manufacturing drawings and materials of components; the descriptions and explanations needed to understand them; a list of the harmonised standards and common specifications applied in full or in part, and of other technical specifications used; a qualitative description of how the assessments under Articles 6, 10 and 11 were carried out; and test reports.

The declaration is the visible artefact. The technical documentation is what stands behind it.

How long must you keep it?

Article 15(3) sets two retention periods, running from the date the packaging was placed on the market. The manufacturer keeps both the technical documentation of Annex VII and the EU Declaration of Conformity for:

• 5 years in the case of single-use packaging;
• 10 years in the case of reusable packaging.

Three things that are easy to miss

The declaration must be kept up to date. Article 39(2) requires it to be continuously updated. Article 15(4) adds that where a change in packaging design or characteristics, or in the standards or specifications by reference to which conformity is declared, could affect conformity, the manufacturer must carry out a re-assessment.

It must be in the right language. Article 39(2) requires the declaration to be drawn up in, or translated into, one or more languages required by the Member State in which the packaging is placed or made available on the market.

One declaration can cover several Union acts. Where packaging or the packaged product falls under more than one Union act requiring an EU declaration of conformity, Article 39(3) provides that a single declaration shall, where appropriate, be drawn up for all of them, stating the acts concerned and their publication references. It may take the form of a dossier of the individual declarations. Use the Other Union acts applied field above to list them; they appear at point 5.

Article 39(5) is worth knowing too: competent authorities shall endeavour to control the accuracy of at least part of the declarations each year, on a risk-based approach, and may withdraw non-compliant products from the market.

Background reading: our guide to the PPWR Declaration of Conformity and Annex VIII, and the PPWR overview.

Sources: Regulation (EU) 2025/40, Articles 15, 38 and 39, Annex VII and Annex VIII. DPP-Tool provides document tooling to help you draft your self-declaration; it is not a conformity assessment body and does not provide legal advice. Responsibility for the declaration’s content rests with the declarant.