PPWR Declaration of Conformity: Requirements, Template Structure & Deadline (Art. 39 & Annex VIII)

The EU declaration of conformity is the central compliance document of the PPWR. With it, the manufacturer of a packaging declares in writing — and with legal effect — that the packaging in question meets all relevant sustainability and labelling requirements of Regulation (EU) 2025/40. The obligation is laid down in Article 39 of the regulation; the required content and structure follow the model in Annex VIII.

The declaration is not an internal memo. It is a formal statement with which the manufacturer assumes responsibility for the conformity of the packaging. It stands at the end of the conformity assessment procedure and rests on the technical documentation drawn up under Annex VII. Without a valid declaration of conformity, packaging may not be placed on the Union market once the regulation applies.

Important: the declaration must be drawn up for each packaging or packaging type. It does not cover the company as a whole but refers to a specific object of the declaration, identified precisely enough to be traceable.

Annex VIII of the PPWR prescribes exactly which elements a declaration of conformity must contain. If one is missing, the declaration is incomplete and therefore not compliant. Point 1 is the declaration number together with the unique identification of the packaging — typically a model or article reference that unambiguously identifies what the declaration covers. Point 2 is the name and address of the manufacturer and, where applicable, the manufacturer's authorised representative.

Point 3 is the sole responsibility statement: the express declaration that the document is issued under the sole responsibility of the manufacturer. Point 4 is the object of the declaration — a description of the packaging precise enough to allow traceability, for example the packaging type and materials and, where helpful, a photograph.

Point 5 is the conformity statement itself: the object of the declaration is in conformity with the relevant Union harmonisation legislation — here Regulation (EU) 2025/40 — listing the applicable requirements of Articles 5 to 12, which cover among other things substances in packaging, recyclability, recycled content, compostability, packaging minimisation and reusability. Point 6 lists the references to the relevant harmonised standards or common specifications used, or to the other technical specifications in relation to which conformity is declared.

Point 7 concerns the notified body. Because packaging is assessed under internal production control (Module A), no notified body is involved, and this point is typically completed as not applicable. Point 8 closes the document with the place and date of issue plus the name, function and signature of the person signing for and on behalf of the manufacturer.

The PPWR applies from 12 August 2026. For the declaration of conformity there is no separate transition or grace period: packaging placed on the EU market for the first time from that date must already be covered by a complete declaration.

In practice this means the technical documentation, the conformity assessment and the declaration itself must all be finished before the deadline. Because the work requires material data, supplier input and a review of the standards applied, companies should start well before August 2026.

Unlike some product legislation, the PPWR contains no general grandfathering rule that postpones the obligation for existing packaging designs. What counts is the moment the packaging is placed on the market.

The declaration of conformity and the underlying technical documentation must be kept after the packaging is placed on the market, so that market surveillance authorities can inspect them on request.

For single-use packaging the retention period is five years from the placing on the market. For reusable packaging it is ten years, because reusable packaging circulates for considerably longer.

Practically, that means archiving declarations in a tamper-proof, retrievable way — ideally digitally, versioned and linked to the unique packaging identification, so the correct version can be produced quickly when an authority asks.

A common misconception: many companies assume that PPWR-compliant packaging must carry a CE marking, as many products do. It does not. The PPWR does not provide for CE marking on packaging.

Conformity is demonstrated instead through the declaration of conformity and the technical documentation, alongside the specific labelling requirements the regulation itself sets for packaging. The declaration is not printed on the packaging; it is kept on file and made available on request.

Article 39(2) adds two practical requirements that templates rarely mention. First, the declaration must be drawn up in, or translated into, the language or languages required by the member state in which the packaging is placed or made available on the market. If you sell into several EU countries, plan for the language versions from the start — a German-only document will not cover markets whose member states prescribe a different language, so check the requirements of each country you sell into.

Second, the declaration must be kept up to date. It is not a one-off exercise: if the packaging, the materials or the applicable requirements change, the document has to follow. By issuing the declaration, the manufacturer formally assumes responsibility for the packaging's compliance (Article 39(4)).

Where packaging is subject to more than one piece of EU legislation that each require an EU declaration of conformity, Article 39(3) provides for a single declaration covering all of those acts — which may take the form of a dossier of the individual declarations. Note what this does not say: it concerns several legal acts for the same packaging, not several different packaging types in one document.

The PPWR is EU law. What it binds is the placing of packaging on the Union market — defined as the first making available of packaging on the EU market. For a UK company the decisive question is therefore not whether the PPWR is part of UK law, but whether your products reach the EU market: the moment they do, the packaging around them must comply.

In practice the pressure arrives through the supply chain: the importer established in the EU may only place compliant packaging on the market and must verify before doing so that the manufacturer has carried out the conformity assessment, drawn up the technical documentation and met the labelling and identification duties (Article 18). An EU importer that cannot obtain these documents from a UK supplier will, sooner or later, stop buying.

UK businesses selling directly to EU end users should look even closer: under the PPWR's extended-producer-responsibility rules, a third-country seller can itself fall within the 'producer' definition (Article 3(1)(15)) and face registration obligations in the member states it sells into. For the declaration of conformity itself, the practical answer for UK exporters is simple — prepare the Annex VIII document and the Annex VII technical documentation as if you were an EU manufacturer, because your EU customers must demand them.

Several industry associations and chambers of commerce provide free blank templates for the PPWR declaration of conformity. They are a reasonable starting point, because they show the structure of Annex VIII. What they do not solve is the actual work: filling the template in correctly.

That is exactly where the errors happen. Which of Articles 5 to 12 apply to your packaging? How should the conformity statement be worded? What goes into the notified body field when internal production control under Module A applies? A template completed incorrectly or incompletely produces a document that fails as the mandatory declaration — and the manufacturer carries full liability for it.

A guided generator removes precisely this mapping work: it asks for each mandatory point individually, explains the background, assigns the applicable requirements and produces a fully structured document. ppwr-doc.com generates the declaration in minutes as a German and English PDF, with a full preview before payment.