PPWR: What is the declaration of conformity?

What must the declaration of conformity contain?

The PPWR specifies the information that the EU declaration of conformity must contain. Article 39 of the Regulation refers to the model in Annex VIII, which serves as a template. Mandatory information in the declaration includes:

• Identification of the packaging: A unique identification number or code for the packaging, along with a description defining the subject of the declaration for the purpose of packaging traceability.

• Responsible company: The name and address of the packaging manufacturer and, where applicable, its authorised representative. The manufacturer must also expressly declare that it assumes sole responsibility for issuing the declaration of conformity.

• Product and legal conformity: A declaration that the product described above complies with the applicable EU legislation, in particular the PPWR itself, including any further EU acts where relevant.

• Information on standards and specifications: A list of all harmonised standards or common specifications applied in the conformity assessment, as well as any other technical specifications on which the declaration of conformity is based.

• Notified body, if applicable: Where a notified body has been involved in the conformity assessment process, information on its name, address and identification number, as well as on certificates issued, including the date and any conditions of validity.
  Note: The PPWR primarily provides for internal conformity assessment. External testing bodies are generally not required for packaging.

• Date, place and signature: The date and place of issue, as well as the name, position and signature of the responsible person signing the declaration on behalf of the manufacturer.

This information ensures that the declaration contains all the details needed to trace and verify the packaging’s conformity. The EU declaration of conformity must also be kept continuously up to date if relevant requirements change.

Who must issue a declaration of conformity?

The packaging manufacturer is generally obliged to issue the declaration of conformity. This is the company that places packaging or a packaged product on the EU market for the first time. In practice, this is the manufacturer of the packaging or packaged product, or, where packaging comes from a third country, the importer.

Before packaging is placed on the market, the manufacturer must carry out the required conformity assessment procedure and prepare the technical documentation. If conformity is established, the manufacturer issues the EU declaration of conformity.

Importers also have obligations. They must ensure that the packaging they import complies with PPWR requirements and that an EU declaration of conformity issued by the manufacturer, together with the technical documentation, is available. Importers must retain a copy of the declaration of conformity and present it to market-surveillance authorities upon request. If no manufacturer is established in the EU, an importer or authorised representative may act as the manufacturer on behalf of the manufacturer.

In addition, any distributor that places packaging on the market under its own name or brand, or modifies packaging already placed on the market in a way that could affect its conformity, legally assumes the role of manufacturer. In such cases, the distributor must fulfil the manufacturer’s obligations, including issuing a declaration of conformity, and is responsible for the packaging’s conformity.

We advise you on all matters relating to the VerpackDG/PPWR:

PPWR consulting

Requirements for language, format and availability

Language

The EU declaration of conformity must be drafted in one or more languages required by the EU Member State in which the packaging is placed on the market. In practical terms, this means that packaging distributed in Germany requires a declaration available at least in German. In other countries, the respective official languages apply. If packaging is marketed in several countries, the declaration can be translated into several languages.

The information must be clear and understandable.

Format

In terms of both content and form, the declaration must follow a prescribed template. Annex VIII of the PPWR provides a sample format that defines the structure. The declaration must contain all required elements described in the corresponding modules of Annex VII of the Regulation.

Companies should therefore use the template provided by the EU, or create their own template that precisely follows these requirements. A uniform format ensures that authorities can quickly find all relevant information during an inspection. In addition, technical documentation for the packaging must be prepared according to defined standards under Annex VII, as it forms the basis for the declaration.

Availability and retention

The declaration of conformity must be available at all times, especially for market-surveillance authorities. Manufacturers are required to retain the declaration and technical documentation for an extended period.

Specifically, the PPWR requires documentation to be retained for at least five years after packaging is placed on the market in the case of single-use packaging, and for ten years in the case of reusable packaging. These documents may be stored electronically. If requested by national authorities, companies must be able to provide the conformity documents without delay, usually within ten days.

Importers are also required to cooperate: They must keep a copy of the EU declaration of conformity and grant authorities access to it upon request. Information must be submitted to supervisory authorities in a language they can understand and accept, which may require providing a translation.

In practice, these documents are requested during market-surveillance inspections to verify that packaging placed on the market complies with the legal requirements. Companies should therefore ensure that declarations of conformity are always up to date and readily accessible, for example digitally through a company portal or document-management system.

Difference from previous documentation and information obligations

The introduction of the EU declaration of conformity for packaging is a new PPWR requirement. It differs significantly from the previous requirements under the former EU Packaging Directive (94/62/EC) and the German Packaging Act (Verpackungsgesetz, VerpackG).

Essential packaging requirements already existed. Packaging had to be designed to use the minimum material necessary, be recyclable and comply with certain substance limits, such as limits on heavy metals. However, there was no obligation to issue a formal declaration of conformity for each package or to prepare detailed technical documentation according to a prescribed scheme. In other words, there was no standardised “conformity document” for packaging that had to be carried or filed. Compliance was generally verified implicitly or in individual cases.

The German Packaging Act, in particular, focused on registration and system participation obligations, including the LUCID Register and licensing through dual systems, as well as labelling and notification obligations relating to extended producer responsibility. A product-specific conformity assessment procedure, such as those used in electrical and electronic equipment law or machinery law, had not previously been established for packaging.

Companies were required to provide evidence when needed, such as laboratory tests proving compliance with limits like the 100 ppm total heavy-metal concentration. However, a comprehensive EU declaration of conformity as a separate document was not part of the former legal framework.

The PPWR fundamentally changes this situation: For the first time, it introduces a conformity assessment procedure with mandatory documentation for packaging. Manufacturers must now proactively ensure and document that their packaging complies with the new requirements before it is placed on the market. This documentation obligation resembles those under other product regulations, such as CE marking, with one important difference: No CE mark may be applied to packaging.

The EU declaration of conformity under the PPWR is therefore a new instrument intended to increase the transparency and verifiability of packaging conformity. For companies, this means additional work involving testing, documentation and administration, but it also provides clear evidence that can be presented during inspections.

We advise you on all matters relating to the VerpackDG/PPWR:

PPWR consulting

Transitional periods and exemptions

Transitional periods

The PPWR is still in its implementation phase. Although the Regulation formally entered into force on 11 February 2025, many requirements do not apply immediately. A general transition period of 18 months has been granted. From 12 August 2026, the Regulation will be fully applicable and replace the former EU Packaging Directive.

Until then, companies have time to prepare for the new requirements, including the preparation of declarations of conformity. During this transition period, Member States must also establish the necessary structures, such as packaging manufacturer registers under Article 44 PPWR.

Different deadlines also apply to individual regulatory areas. Certain sustainability requirements will be introduced gradually by 2030. For example, by 2030 all packaging must be recyclable, and minimum recycled-content quotas for plastic packaging will also apply.

These phased deadlines give industry time to adapt. However, they also mean that, depending on the period concerned, the declaration of conformity may need to cover different requirements.

Exemptions

The PPWR provides for exemptions or special rules in certain situations. For example, exemptions for heavy-metal limits that already existed under the former Packaging Directive (94/62/EC) continue to apply. These covered exceptions to concentration limits for lead, cadmium, mercury and hexavalent chromium in packaging, for example for certain recycled materials.

Further exemptions from new requirements may apply in particular circumstances. For example, certain contact-sensitive plastic packaging – packaging in which recycled material is difficult to use for safety or hygiene reasons, such as in medical or food applications – may be exempted by the European Commission from mandatory minimum recycled-content requirements.

This means that such packaging may be exempt from the obligation to contain a specified proportion of recycled plastic where this is justified. The Regulation contains a list of such exemptions and empowers the Commission to adjust or expand it.

Finally, transitional or exemption rules may apply at Member State level in individual areas. For example, Member States that already achieve very high collection rates for certain types of packaging by 2026 may, under certain circumstances, be exempt from introducing mandatory deposit and return systems.

Overall, however, exemptions are narrowly defined. The general rule is that all packaging placed on the market must comply with PPWR requirements and be supported by a declaration of conformity. Companies should therefore focus primarily on meeting the requirements and preparing their conformity documentation on time.