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 prompted by the PPWR, but what you owe in return depends on your role and on your customer's. Since 12 August 2026, with no transition period, the manufacturer must assess conformity, draw up the technical documentation and issue the declaration before placing packaging on the market (Article 15(2)); an importer checks this and keeps a copy of the declaration. Retailers and industrial buyers are therefore collecting paperwork from their suppliers: a manufacturer needs its suppliers' information under Article 16, an importer needs a copy of the non-EU manufacturer's declaration, and for a pure distributor the request is a contractual demand.

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. If your customer is the manufacturer and you are its supplier, that is what you owe: information and documentation, including the technical documentation, but no declaration of your own (Commission FAQ X.4). Whether you issue a declaration yourself depends only on whether you are the manufacturer; deadlines and forms in request letters are a contractual matter.

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: whoever makes packaging or packaged products, or has them designed or made, under their own name or brand (Article 3(1)(13)). For unbranded packaging, the manufacturer is whoever sets the design and places the order (Commission guidelines C/2026/3084), and there is only one manufacturer per supply chain. If you produce packaging under your own brand, that is you; if you produce or fill it for someone else's brand, the brand owner is the manufacturer. If you sell bought-in goods under your own brand, you are the manufacturer and must issue the declaration yourself; relying on your upstream supplier's paperwork is not enough. Exception: if the brand owner is a micro-enterprise and its packaging supplier is located in the same Member State, the supplier counts as the manufacturer. Placing packaged goods or packaging from a third country on the market makes you the importer, not the manufacturer. Before placing it on the market, the importer ensures that the non-EU manufacturer has assessed conformity, drawn up the technical documentation and issued the declaration, puts its own name and address on the packaging and keeps a copy of the declaration (Article 18(2), (3) and (7)). It becomes the manufacturer only if it places the packaging on the market under its own name or brand, modifies it in a way that could affect conformity (Article 21) or has it made to its own design. For unbranded imported packaging, the importer must secure the documentation itself (Commission FAQ X.11). An importer can prepare the declaration for the non-EU manufacturer; the manufacturer must sign it.

If, on the other hand, you are a pure distributor making an EU manufacturer's goods available unchanged under that manufacturer's brand, you issue no declaration and need not keep one on file. Before making packaging available, you check that the producer is registered in the register of producers, that the packaging is labelled under Article 12 and that the identification number and the name and address of the manufacturer and, where relevant, the importer are given (Article 19(2)); only the importer must keep a copy of the declaration (Article 18(7)). If your customer still wants the document, that is a contractual demand: you can ask the manufacturer for it, but Article 16 gives you no claim against the manufacturer.

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. As the manufacturer, you are not required to send it to customers; you keep it on file for market surveillance. If, however, your customer is the manufacturer and you are its supplier, Article 16 requires you to provide the information and documentation it needs, including the technical documentation. The declaration is the customer-facing document; the documentation is the dossier for an inspection.

Who is asking decides what you owe. If your customer is the manufacturer and you are its supplier, Article 16 requires you to provide all the information and documentation it needs to demonstrate conformity, including the technical documentation; you may not refuse, but you owe no declaration of your own (Commission FAQ X.4). If your customer imports your goods into the EU, it is the importer and must keep a copy of the declaration you issue as the non-EU manufacturer (Article 18(7)). If your customer is a distributor, Article 19 does not require it to hold a declaration, so the demand is contractual. If you are the manufacturer yourself, the declaration must exist anyway (Article 15(2)); the regulation does not require you to pass it on, but doing so is common.

Some request letters ask for a “supplier declaration”, yet the PPWR knows no document of that name. Usually the customer means either the Article 16 documents or the EU declaration of conformity, so ask which one is wanted. Do not confuse it with the supplier's declaration for preferential origin under customs law, which has nothing to do with packaging conformity.

Scope: the manufacturer draws up one declaration per packaging type (Annex VII point 4). According to Commission FAQ XV.10, which is not legally binding, sizes with the same characteristics and the same contents may be covered by one declaration. Either way, the declaration must identify the packaging it covers.

Several suppliers: if bottle, closure and label come from different suppliers, each supplier provides its information and documentation to the manufacturer (Article 16). The manufacturer then issues one declaration for the whole packaging unit (Commission FAQ XV.5); there is only one manufacturer per supply chain.

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 Germany, Section 62 of the VerpackDG — in force since 12 August 2026 — makes it explicit: a signed version in either German or English is sufficient, and a German translation is only due if the authority requests one. For supply chains beyond one country, a bilingual German and English document remains 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 structuring work: it asks for each mandatory point individually, pre-selects the typically applicable requirements of Articles 5 to 12 for your review 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.