From 12 August 2026, every type of packaging placed on the EU market must have a valid PPWR Declaration of Conformity (DoC). Without this declaration, companies risk fines, barriers to market entry, and supply chain disruptions.

This guide gives you a practical step-by-step tutorial on how to create a PPWR Declaration of Conformity for your packaging - including:

  • Overview of PPWR 2026 and the key PPWR requirements
  • How it differs from the Packaging Act and the former Packaging Directive
  • A list of the mandatory data and evidence you need for every DoC
  • The structure of a Declaration of Conformity sample (template layout)
  • Typical mistakes and troubleshooting tips from real-world projects
  • How to scale the entire process with digital packaging management and the Packa software

Note: This article is for guidance only and does not constitute legal advice. Always review specific cases with your legal department or external specialist lawyers.

Why the PPWR Declaration of Conformity will be business-critical from 2026

The EU Packaging and Packaging Waste Regulation (PPWR) gradually replaces the previous Packaging Directive and reshapes packaging law in Europe. As an EU regulation, the PPWR applies directly in all member states. Unlike the previous Packaging Directive, the PPWR as an EU regulation is directly binding and leaves member states very little discretion in its implementation.

Key milestones:

  • The PPWR entered into force on 11 February 2025
  • From 12 August 2026, packaging without a valid PPWR Declaration of Conformity may no longer be placed on the EU market
  • You need a separate declaration for every distinct type of packaging (including relevant variants).

The national Packaging Act remains relevant, among other things, for EPR obligations and registrations. In Germany, violations of the Packaging Act can be penalised with fines of up to €200,000 per offence. The PPWR adds to the existing requirements - it does not replace them.

Terminology check: Packaging Act, Packaging Directive, PPWR 2026

A quick overview of the three core legal frameworks makes it easier to get started:

  • Packaging Directive: Previous EU framework legislation that was transposed into national law, such as the German Packaging Act.
  • Packaging Act: German law governing registration, participation in compliance schemes and EPR fees. It will remain relevant.
  • PPWR 2026: Directly applicable EU regulation with detailed PPWR requirements for recyclability, material use, substance restrictions, recycled content quotas, labelling and documentation - including the PPWR Declaration of Conformity and technical documentation.

In day-to-day operations this means: you must consider Packaging Act + PPWR together - especially for EPR reporting and when assessing whether a packaging is still allowed to be placed on the market.

Prerequisites: What you should clarify before you start

Before you start filling out a PPWR Declaration of Conformity, you should have the following basics in place:

  • A complete list of all sales, inner, transport and e-commerce packaging
  • Clearly defined roles and responsibilities (manufacturer, brand owner, importer, distributor) along the supply chain
  • Access to material specifications, drawings, bills of materials and supplier declarations
  • An overview of recyclability, recycled content, reusability and critical substances (e.g. PFAS)
  • A central storage location for packaging data and certificates (ideally digital packaging management instead of individual spreadsheets)

Once you meet these points, you can start the process of creating Declarations of Conformity in a systematic way.

7 steps to your PPWR Declaration of Conformity (DoC)

Step 1: Clarify roles and responsibilities

The PPWR assigns clear obligations to the different actors in the supply chain:

  • Manufacturers / converters / private-label producers
    • Carry out the conformity assessment
    • Prepare and sign the DoC
    • Maintain technical documentation
  • Importers
    • Check whether a valid DoC and technical documentation exist for imported packaging
  • Distributors / retailers
    • Ensure that valid Declarations of Conformity are available for the entire portfolio
  • Brand owners / fillers
    • Are responsible for ensuring that all packaging they use is documented as PPWR-compliant, even if suppliers formally issue the DoC

Tip: Assign a clear owner role for PPWR data and Declarations of Conformity per product category (e.g. packaging engineering, quality or regulatory). This prevents gaps and duplicated work.

Step 2: Create a complete inventory of your packaging portfolio

A DoC applies to a clearly defined type of packaging. A complete inventory is therefore essential:

  1. List all relevant packaging:
    • Primary packaging
    • Secondary / outer packaging
    • Transport and pallet packaging
    • Special e-commerce packaging
  2. Group into packaging families, for example by:
    • Material (plastic, paper, metal, glass, composites)
    • Format (bottle, pouch, tray, folding box, etc.)
    • Intended use (food / non-food, online shipping, reusable)
  3. Define from which point variants (e.g. changes to material, size or structure) require their own DoC.

For each distinct type of packaging or relevant variant (material, size, design), a separate PPWR Declaration of Conformity is generally required.

Common mistake: Many companies start with incomplete bills of materials and forget, for example, outer packaging or e-commerce sets. This later leads to gaps in compliance evidence.

Step 3: Collect mandatory data and evidence

The quality of your DoC fundamentally depends on the quality of your packaging data. Relevant information blocks include:

  • Material data
    • Full layer structures (base material, coatings, barriers, adhesives)
    • Recycled content (where relevant)
    • Information on critical substances (e.g. PFAS, heavy metals)
  • Design and construction data
    • Dimensions, wall thicknesses, filling volume
    • Weight of individual components
    • Labels, closures, inserts
  • Recycling and design data
    • Results of recyclability assessments using recognised methods
    • Information on reusability (for reusable packaging)
    • Compliance with design requirements, e.g. void space limits for e-commerce
  • Supplier and compliance data
    • Supplier declarations and certificates
    • Test reports (e.g. laboratory tests)
    • EPR-relevant information (material codes, fractions)

Tip: Use structured supplier questionnaires instead of individual emails. Digital workflows - for example via digital packaging management such as Packa - standardise questionnaires, send automatic reminders and maintain version-controlled documentation.

Step 4: Carry out the PPWR conformity assessment

Before you sign the DoC, you must be able to demonstrate why the packaging meets the PPWR requirements. A typical sequence is:

  1. Substance compliance review
    • Compare against limits and bans (e.g. heavy metals, PFAS in food contact packaging)
  2. Assessment of recyclability
    • Apply recognised assessment methods
    • Assign to collection and recycling streams (e.g. paper, plastic, glass)
  3. Check minimisation and design requirements
    • Material minimisation (no oversized packaging)
    • Compliance with design rules, such as void space limits in e-commerce
  4. Recycled content and reusability (where relevant)
  5. Documentation of assessment methods
    • List all standards, guidelines or norms used
    • Document any internal policies or tools

This assessment forms the core of your technical documentation - and is usually more important in regulatory inspections than the DoC itself.

Step 5: Structure your PPWR Declaration of Conformity using a sample template

According to Annex VIII of the PPWR, every DoC must contain specific mandatory information. Each DoC must include, among other things, a unique identification number, manufacturer details, clear identification of the packaging type, and a signed declaration of conformity.

A practical Declaration of Conformity sample includes:

  1. Unique identification number
  2. Company / responsible economic operator (name, address, contact details)
  3. Identification of the packaging (trade name, internal article number, description)
  4. Declaration of conformity (reference to the relevant PPWR articles, typically Articles 5-12)
  5. Legal bases and standards (references to PPWR articles and applied standards)
  6. Reference to technical documentation (location, e.g. central DMS)
  7. Date, place, name, function and signature of the authorised signatory

Tip: Use a structured PPWR Declaration of Conformity template to cover all mandatory fields and standardise internally. The PPWR Declaration of Conformity template from Packa supports you as a ready-to-use sample.

Step 6: Organise technical documentation and retention

The PPWR does not only require a complete DoC, but also technical documentation that proves it, including:

  • Material specifications and layer structures
  • Supplier declarations and certificates
  • Test evidence (lab tests, recyclability assessments)
  • Assessment reports on minimisation, recycled content, reusability
  • Evidence of traceability (batch or lot data, internal IDs)

Technical documentation relating to the PPWR DoC must generally be retained for at least 5 years for single-use packaging and 10 years for reusable packaging.

Common mistake: DoCs are stored as PDFs, often without version control or links to specifications. As soon as anything changes, the old DoC is no longer valid - without change management, the risk increases unnecessarily.

Step 7: Digitise and scale your processes (with Packa)

Spreadsheets, scattered folders and email attachments quickly reach their limits when you have many SKUs. The PPWR demands article-level data and audit-proof evidence - for this you need a structured digital system.

The Packa software for digital packaging management has been developed specifically for this use case:

  • Packa can centralise packaging data from Excel, CSV, PDF and ERP exports - including direct integration with ERP systems (such as SAP).
  • AI-supported digitisation converts unstructured documents into analysable data sets and typically identifies 30-70% of missing packaging data.
  • Integrated PPWR checks and recycling analyses assess packaging at article level.
  • Automated supplier communication collects data and certificates in a structured and version-controlled way.
  • DoCs and technical documentation are stored audit-ready - including history and traceability.

This turns a PPWR project into a scalable standard process that also works for new products, relaunches and regulatory updates.

Typical mistakes with PPWR Declarations of Conformity - and how to avoid them

In customer projects, the same stumbling blocks appear again and again:

  1. No complete overview of the packaging portfolio
    • Solution: Central master data system with unique IDs and clear roles.
  2. Packaging data in silos (spreadsheets, email, local drives)
    • Solution: Digital platform with standardised fields and access rights.
  3. Focusing on the form instead of the technical documentation
    • Solution: First build the conformity assessment and evidence, then fill out the DoC.
  4. DoCs without version control
    • Solution: Clear rules for re-issuing (e.g. when materials change), plus version management.
  5. Involving suppliers too late
    • Solution: Standardised questionnaires, early communication, clear deadlines and digital workflows.

Troubleshooting tip: If you are already missing data today (e.g. on coatings, adhesives), prioritise high-risk packaging: food packaging, multi-layer composites, special e-commerce solutions. These will require the most effort.

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Next steps: From your first DoC to a scalable system

Once you have created your first PPWR Declaration of Conformity, the next question is: How do I scale this to my entire portfolio?

Recommended roadmap:

  • 1. Run a quick check
    Use a concise checklist to identify gaps in data, evidence and processes - for example the free PPWR checklist from Packa.
  • 2. Plan your template rollout
    Standardise your template for all business units and markets. This reduces room for interpretation and simplifies training.
  • 3. Introduce digital packaging management
    Consider a specialised solution such as the Packa software for digital packaging management to centrally manage data, evidence and DoCs.
  • 4. Define governance and KPIs
    Establish responsibilities, approval workflows and KPIs (for example, the share of packaging with a complete DoC).
  • 5. Test audit readiness
    Simulate a market surveillance request: can you provide all documentation for a randomly selected packaging item within a few hours?

The earlier you start, the more likely PPWR 2026 will become a manageable project for your company - rather than a crisis.

FAQ on the PPWR Declaration of Conformity 2026

1. From when do I need a PPWR Declaration of Conformity for my packaging?

The PPWR entered into force on 11 February 2025. After 18 months, the following applies: From 12 August 2026, all packaging placed on the EU market must be covered by a PPWR Declaration of Conformity and corresponding technical documentation.

2. Does the PPWR Declaration of Conformity also apply to small businesses?

Yes. The PPWR does not differentiate between companies by size when it comes to the fundamental requirements. It applies to all companies that place packaging on the EU market - from medium-sized FMCG manufacturers to global corporations.

3. Is one standard Declaration of Conformity template sufficient for all countries?

The DoC is based on the harmonised PPWR across Europe. A well-structured template containing all mandatory information is therefore suitable for all EU countries. In addition, verify any country-specific requirements (e.g. language or supplementary national obligations).

4. How often do I have to update a PPWR Declaration of Conformity?

Whenever relevant parameters of the packaging change - such as material, structure, weight, recyclability or intended use - you should review whether a new DoC is required. Changes in regulations or standards can also trigger the need for an update.

5. Can I manage the PPWR Declaration of Conformity in my ERP system (e.g. SAP)?

You can maintain basic information in your ERP system. However, the PPWR DoC requires comprehensive technical documentation, version-controlled files and workflows. Standard ERP screens typically reach their limits here. A specialised platform such as Packa, which integrates ERP exports (e.g. from SAP) and additional data sources, makes it much easier to manage specifications, evidence and Declarations of Conformity.

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