Free is allowed — what counts is the Annex VIII structure
The PPWR does not prescribe any particular tool. Whether you draw up your EU declaration of conformity with a free Word template, a no-cost generator or a paid product is irrelevant to the regulation — as long as the result is right. Article 39(2) requires the declaration to have “the model structure set out in Annex VIII”; Article 39(1) defines what it states: fulfilment of the requirements laid down in or pursuant to Articles 5 to 12.
Why this formality matters: in an authority check or a customer audit, your document is held against the official model. A document that is substantively correct but structured differently remains formally open to challenge — and the responsibility sits with you as the manufacturer. Providers of free templates almost always exclude their own liability explicitly.
Good starting points do exist, such as the model documents published by industry associations and chambers. But wherever a template comes from: vet it once, systematically, before first use. The checklist below takes about five minutes.
The 8-point checklist
First, the header: the document must be titled “EU declaration of conformity No …” and carry an identification number of the declaration. Point 1 requires the unique identification of the packaging (for example a model or article number). Point 2 names the manufacturer with name and address — and expressly provides a field for the authorised representative where one has been appointed. Point 3 is the verbatim responsibility statement: the declaration is issued “under the sole responsibility of the manufacturer”. If that sentence is missing, a mandatory element is missing. Point 4 describes the object of the declaration in a way that allows traceability.
Point 5 carries the actual conformity statement — limited to the relevant Union harmonisation legislation, i.e. the requirements of Articles 5 to 12, with a proper citation of the regulation. Point 6 lists the harmonised standards or other technical specifications relied on. Point 7 concerns the notified body: since packaging follows the internal production control procedure (Module A), the correct entry here is normally “not applicable” — a template that omits this point entirely is incomplete. Point 8 closes with additional information and the signature block: “Signed for and on behalf of”, place and date of issue, name, function, signature.
Finally, check the form itself: exactly eight numbered points in the official order, field labels close to the Official Journal wording, no invented structure of the template author’s own. To see what a complete declaration looks like, put your template next to our filled-in Annex VIII example.
The five most common gaps in free templates
Gap one is a home-made structure: instead of the official points 1 to 8, some templates organise the content freely into “product information”, “material properties” and “legal information”. It reads tidily, but it is not the structure Article 39(2) requires. Gaps two and three usually follow from it: the verbatim sole-responsibility sentence is missing, and the notified-body line has been dropped altogether.
Gap four is over-declaration: templates that have you sign blanket conformity “with Regulation (EU) 2025/40” instead of limiting the statement to Articles 5 to 12 — whoever signs for more is liable for more. Gap five is a missing or outdated citation: a clean declaration cites the regulation with its Official Journal reference. These and further error patterns are dissected in detail in our guide to the mandatory Annex VIII fields.
Beyond the legal points, watch for practical nuisances that are not errors of law but matter in B2B use: some free tools place their own advertising permanently inside the finished document, require an e-mail address and transmit your packaging data before the download, or offer no way to save — any change means re-entering everything. Decide consciously whether you can live with that, because this document goes to your customers.
Languages: when one version is not enough
The declaration must be available in the language or languages required by the Member State in which the packaging is placed or made available on the market. For Germany, Section 62 of the VerpackDG has clarified since 12 August 2026 that a signed version in either German or English suffices, with a German translation only due on request of the authority.
If you supply several Member States, you need the corresponding language versions. This is where many free templates end: they exist in one or two languages only, and translating the official Annex VIII wording yourself is a genuine source of error — the EU language versions differ in wording more than you would expect. So vet not just one language version of your template, but every version you actually issue.
When a free template is enough — and when it is not
The honest answer: for a single, simple sales packaging a good free template can be perfectly sufficient — if you take the time to check every point against Annex VIII, to limit the conformity statement correctly and to keep the declaration up to date whenever something changes. The checklist above is your tool for that.
It looks different when several packaging types need documenting, when customers in different countries expect language versions, or when you need a clean receipt for audits and bookkeeping. Then the guided route pays off: a generator asks for every mandatory field step by step, keeps the official structure automatically and outputs a neutral document without third-party advertising — at PPWR-DOC as a PDF, in up to eight EU languages, with an invoice for your records.