"Can you send us your PPWR certificate?" Packaging managers are fielding this question from buyers, trading partners, and auditors alike. The honest answer is uncomfortable, but straightforward: a PPWR certificate does not exist. The EU Packaging Regulation makes no provision for certification - not by authorities, not by notified bodies.

What does exist is an evidence chain that you build and own yourself. This post explains what that chain consists of, why the "certificate" framing persists anyway, and what you can actually hand to trading partners.

The short answer

The PPWR - Regulation (EU) 2025/40 - does not operate through certificates. It operates through self-declaration under your own responsibility. This is standard practice in EU product law and works exactly like CE marking: the manufacturer declares conformity and must be able to substantiate it on demand.

There is no body that issues you a document. There is a documentation obligation that you either meet - or don't.

Why the term won't go away

Three reasons that reinforce each other in practice:

Habit from other frameworks. Many packaging managers are familiar with certifications from ISO 9001, FSC, or BRCGS. Those schemes do involve audited certificates with defined validity periods. Expecting the same from the PPWR is a natural reflex - but an incorrect one.

Vague procurement requests. Purchasing teams ask for the "PPWR certificate" because they need to fill a field in a supplier database. What they almost always mean is the declaration of conformity.

Service provider marketing. Some vendors market proprietary audit marks or expert opinions in a way that implies official recognition. Those documents can be technically useful, but they do not substitute for any of the statutory obligations.

What the PPWR actually requires

Three building blocks, each one resting on the next.

1. The EU Declaration of Conformity (Article 39, Annex VIII)

The EU Declaration of Conformity is the document trading partners have in mind when they ask for a certificate. It is a written statement by the manufacturer that a specific packaging item meets the requirements of Articles 5 through 12 of the PPWR - covering, among other things, substances of concern, recyclability, recycled content, minimization, and labeling.

The legal basis is Article 39 of the PPWR. The structure is prescribed - and binding - in Annex VIII: if a mandatory field is missing, the declaration is treated as if it was never issued. A formally incomplete declaration of conformity is legally no better than no declaration at all.

2. The technical documentation (Annex VII)

The declaration of conformity is only the surface. Underneath it sits the technical documentation required by Annex VII - the actual burden of proof.

For each packaging type, this documentation must include, among other things:

  • the complete material composition by layer and component
  • weights and quantity data
  • evidence regarding substances of concern, including PFAS
  • the recyclability assessment
  • proof of recycled content for plastic packaging
  • the justification for packaging minimization
  • supplier declarations and test reports you are relying on

You are not required to submit these documents proactively, but you must be able to produce them immediately when a market surveillance authority requests them.

3. The conformity assessment procedure (Module A)

The PPWR uses Module A, internal production control. This means you carry out the assessment yourself, without involving a notified body. That is precisely why there is no certificate - there is no one who would issue one.

The flip side: the responsibility rests entirely with you. There is no external auditor whose sign-off you can point to if a dispute arises.

When does this apply?

The PPWR entered into force on 11 February 2025 and applies from 12 August 2026. From that date, packaging may only be placed on the market if a valid declaration of conformity and the corresponding technical documentation are in place.

That date has now passed. If you haven't built your evidence chain yet, you're not working toward a future obligation - you're closing an existing gap.

What trading partners actually want from you

When a customer asks for the "PPWR certificate," the most practical response is to provide:

  1. the EU Declaration of Conformity per Annex VIII for the specific packaging being supplied
  2. on request, an extract from the technical documentation - rarely the full dossier, which often contains trade secrets
  3. where relevant, supplementary test reports or expert opinions, for example on recyclability

The second point deserves attention: you are not obligated to hand over your complete technical documentation to customers. The obligation to produce it applies to market surveillance authorities. What you share with trading partners is governed by what you've agreed contractually.

Where certificates still play a role

For completeness: voluntary testing is not without value. A recyclability assessment conducted according to a recognized methodology can provide a solid foundation for your evaluation under Article 6. Test reports from an accredited laboratory are strong supporting evidence for the substance requirements.

The distinction lies in their function: such documents are components within your technical documentation. They replace neither the declaration of conformity nor the documentation as a whole.

What to do now

Inventory your packaging portfolio. You need the evidence chain per packaging type, not per product. The first step is a reliable list of everything you actually place on the market.

Identify data gaps for each requirement. For most companies, recycled content and PFAS evidence are the weakest points - because both pieces of information sit deep in the supply chain.

Collect supplier declarations systematically. Without upstream data, no declaration of conformity can be signed with confidence. Relying on email attachments and spreadsheets here means losing traceability fast.

Assign clear ownership. The declaration of conformity is signed by a specific person. Decide in advance who that is and on what basis they are signing.

Frequently asked questions

Do I need a separate declaration of conformity for every packaging item? You need one per packaging type. Identical packaging with the same material composition can be grouped together; different variants cannot.

Who signs the declaration of conformity? An authorized signatory of the company placing the packaging on the market. Responsibility cannot be delegated to suppliers or service providers.

My supplier says they've already confirmed PPWR conformity. Is that enough? No - if you are the one placing the packaging on the market. Your supplier's declaration is one component of your documentation, not a substitute for it.

Are there transitional arrangements? Certain individual requirements of the PPWR phase in at later dates, particularly for labeling and recycled content quotas. The obligation to have a declaration of conformity and technical documentation in place has applied since 12 August 2026.

More on PPWR

From the certificate question to a solid evidence chain

The upside of there being no certification: you're not dependent on audit schedules or certification bodies. The downside: no one takes the burden of proof off your hands.

What ultimately matters is the quality of your data. If you maintain materials, weights, recycled content figures, and supplier evidence in one structured place, you can generate and substantiate a declaration of conformity in minutes. If you have to piece the data together from scattered spreadsheets, you won't be able to produce it when it counts.

If you'd like to assess how solid your evidence chain is right now: Talk to packaging experts

This post provides a general overview as of September 2026 and does not constitute legal advice. The authoritative source is the regulation text in its current version, together with any delegated acts issued under it.

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