REACH Declaration of Conformity: What REACH Actually Requires for Packaging — and Which EU Laws Do Demand a Declaration (PPWR, Food Contact)

The REACH Regulation (EC) No 1907/2006 contains no obligation to issue a declaration of conformity — the term does not occur anywhere in the regulation, nor does “declaration of compliance” or “certificate of conformity”.

What circulates in supply chains as a “REACH declaration”, “REACH statement” or “REACH certificate” is an industry practice: a voluntary written format suppliers use to answer their customers’ substance enquiries. Useful — but not a conformity document prescribed by REACH, and not to be confused with the declarations other EU laws genuinely require.

For articles — and packaging is treated as an article — the relevant REACH duty is informational. Any supplier of an article containing a Candidate List substance of very high concern (SVHC) in a concentration above 0.1 % weight by weight must provide the recipient with sufficient information, available to the supplier, to allow safe use of the article — as a minimum, the name of that substance (Article 33(1)).

Consumers have rights too: on request, the supplier must provide the same information free of charge within 45 days (Article 33(2)). The European Chemicals Agency describes these duties as communication in the supply chain — information flows, not formal conformity declarations.

In practice, that is exactly what a well-made supplier “REACH declaration” does: it documents whether SVHCs above the threshold are present and passes the Article 33 information down the chain. Asking for it is reasonable — just know that its legal basis is an information duty, not a declaration requirement.

With the Packaging and Packaging Waste Regulation (EU) 2025/40, packaging as such becomes subject to a true declaration of conformity. From 12 August 2026, manufacturers must carry out — or have carried out on their behalf — the conformity assessment under Article 38 before placing packaging on the market, and draw up an EU declaration of conformity in accordance with Article 39.

That declaration states that the fulfilment of the requirements of Articles 5 to 12 has been demonstrated, follows the model structure of Annex VIII, is issued under the sole responsibility of the manufacturer and must be kept continuously updated. How the eight mandatory points work in detail is covered in our PPWR declaration of conformity guide.

A second genuine declaration duty applies to packaging that touches food. The framework Regulation (EC) No 1935/2004 requires, for material groups covered by a specific measure, a written declaration stating compliance with the applicable rules (Article 16).

For plastics, that specific measure exists: under Regulation (EU) No 10/2011, a written declaration of compliance must be available for plastic food-contact materials and articles at all marketing stages other than retail (Article 15). Its content is fixed in Annex IV — from the identity of issuer and manufacturer to confirmation of compliance and usage specifications — and it must be renewed when substantial changes in composition or production alter migration, or when new scientific data emerges.

Mind the terminology: food-contact law speaks of a declaration of compliance, the PPWR of an EU declaration of conformity. They are different instruments with different content — one packaging can require both.

Where packaging or the packaged product is subject to more than one Union act requiring an EU declaration of conformity, a single EU declaration covering all those acts is, where appropriate, drawn up — and it may consist of a dossier made up of the relevant individual declarations (Article 39(3) PPWR).

The practical takeaway for packaging companies: organise three layers cleanly — the PPWR declaration of conformity from August 2026, the food-contact declaration of compliance where applicable, and the Article 33 substance information from your suppliers. The first layer is exactly what a guided generator can produce in minutes.