Customer Requests a PPWR Declaration of Conformity? How Suppliers Respond — providing the EU declaration of conformity for packaging under Art. 39 & Annex VIII: who must issue it, what the document contains and how to deliver it fast

Your customer's request is not a special demand — it is a legal obligation being passed down the supply chain. Anyone first making packaging available on the EU market must be able to document its conformity from 12 August 2026, with no transition period. Retailers and industrial buyers are therefore collecting the paperwork from their suppliers before the deadline arrives.

The regulation itself supports the request: under Article 16, suppliers of packaging and packaging materials must provide the manufacturer with all the information and documentation needed for the conformity evidence. A customer asking for the declaration of conformity or the underlying packaging data is asking for what the PPWR already provides for.

In practice these requests now arrive as standardised letters from large buyers — with deadlines, sometimes with the buyer's own form, sometimes with a note that the listing is at risk without the document. A prepared supplier answers such a letter in minutes, not weeks.

The EU declaration of conformity is issued by the manufacturer of the packaging — the party under whose name the packaging is placed on the market. If you produce it yourself, that is you. If you sell bought-in goods under your own brand, or import packaged products from outside the EU, you legally step into the manufacturer's role and must issue the declaration yourself; relying on your upstream supplier's paperwork is not enough.

If, on the other hand, you are a pure distributor selling an EU manufacturer's goods unchanged under that manufacturer's brand, you do not issue your own declaration: you keep the manufacturer's declaration on file and pass it on when asked. In that case, the right answer to your customer's letter is to request the document from the manufacturer — Article 16 helps there too.

Unsure which role applies to you? The guided assistant at ppwr-doc.com asks the role question as its first step and derives from it whether you must issue the document yourself. The details of every field are covered in our PPWR declaration of conformity guide.

The EU declaration of conformity follows the model in Annex VIII and contains eight mandatory points: the unique identification of the packaging, the manufacturer's name and address, the responsibility statement, the object of the declaration with a description, the conformity statement covering the requirements of Articles 5 to 12, the standards or specifications used, the notified body entry, and place, date, name, function and signature.

Important for your reply: one declaration covers one packaging type — not one customer and not one delivery. A correctly issued document therefore serves every request concerning that packaging type; you send the same declaration to each buyer who asks. You can see what the finished document looks like in our completed Annex VIII sample.

Behind the declaration sits the technical documentation under Annex VII, which substantiates the statements. You do not send it to the customer — you keep it on file for market surveillance. The declaration is the customer-facing document; the documentation is the dossier for an inspection.

Language: international buyers usually expect the declaration in English. The regulation requires the language or languages of the member state where the packaging is placed on the market — for supply chains beyond one country, a bilingual German and English document is the practical answer.

Customer forms: some buyers attach their own template to the request. Check whether it reflects the Annex VIII structure — the regulation prescribes the content and model of the declaration, and a document containing all eight mandatory points meets the requirement regardless of whose letterhead the request came on.

Your own upstream suppliers: if you lack material data for the conformity statement, pass the request down the chain under Article 16 — your suppliers are obliged to cooperate. Allow time for this; deadlines in customer letters are often shorter than response times in the supply chain.

When a customer request with a deadline is on the table, speed matters. A guided generator removes the mapping work: it asks for each mandatory point individually, assigns the applicable requirements of Articles 5 to 12 automatically and produces the declaration as a German and English PDF — with field wording that follows the model published in the Official Journal verbatim.

You see the finished document as a preview before paying, and you can pass it straight on to your customer. With several packaging types, you reuse an existing declaration as a template and change only the packaging data — answering a procurement department's bulk request in one sitting.