From 12 August 2026, every packaging type placed on the EU market must be covered by an EU declaration of conformity to the new Packaging and Packaging Waste Regulation (PPWR – Regulation (EU) 2025/40).
For packaging engineers and quality managers, this is more than a formal extra document: it becomes the central proof that your packaging design – including “design for recycling” – meets the EU-Verpackungsverordnung requirements.
This article explains:
- the legal basis of the PPWR declaration of conformity
- the mandatory content according to Article 39 and Annex VIII PPWR
- retention periods (5–10 years) for documents
- a practical, step-by-step approach to setting up a compliant process
Our checklist helps you verify that you meet all prerequisites for the declaration of conformity.
1. What is the PPWR declaration of conformity – and who needs it?
Under the new EU packaging and packaging waste regulation, manufacturers must perform a conformity assessment for each packaging type and then draw up an EU declaration of conformity (DoC).
In simple terms, the PPWR declaration of conformity:
- confirms that a packaging item complies with the core PPWR requirements (Articles 5–12 – e.g. minimisation, recyclability, reuse, restricted formats, material restrictions)
- links that statement to a specific, traceable packaging design and manufacturer
- is the key document authorities will request in audits and market surveillance procedures
Who is responsible?
- Manufacturers of packaging (including converters producing private-label packaging) are legally required to carry out the conformity assessment and issue the DoC.
- Importers and distributors must ensure that a valid DoC and technical documentation exist before they place packaging on the EU market.
- Brand owners, fillers and retailers need access to DoCs across their packaging portfolio to demonstrate PPWR compliance for all packaging they place on the market.
2. Legal basis and PPWR timeline: why August 2026 is critical
Key dates for the EU-Verpackungsverordnung (PPWR) are:
- 12 August 2026 – PPWR starts to apply in all Member States. From this date:
- Conformity assessment,
- technical documentation, and
- EU declarations of conformity
are mandatory for each packaging type placed on the market.
- 2027 – Digital identifiers (e.g. QR codes) become mandatory for certain packaging to link to structured environmental information.
- 12 August 2028 – Harmonised EU labelling for packaging applies.
- 2030 – All packaging must be “recyclable” under PPWR criteria and meet recycling-content targets for plastics, accelerating “design for recycling”.
For packaging technology and quality teams, the first big milestone is clear: you must have a functioning conformity assessment and DoC process running for every packaging family by August 2026.
3. Mandatory content: what must the PPWR declaration of conformity include?
Article 39 PPWR requires that the EU declaration of conformity follows the model in Annex VIII. In practice, it should include at least the following elements:
Checklist: Minimum content of the PPWR declaration of conformity
- Identification number of the declaration
- A unique DoC number so you can link the document to internal systems, SAP material numbers and supplier IDs.
- Identification of the packaging
- A unique identification of the packaging (e.g. article code, drawing number).
- Description enabling traceability: packaging type (e.g. “folding carton for chocolate, 200g”), dimensions, materials, layers, key components (closure, label, liner).
- Manufacturer (and authorised representative, if any)
- Name, address and contact details of the packaging manufacturer.
- Where applicable, details of the manufacturer’s authorised representative in the EU.
- Statement of responsibility
- A clear sentence that the declaration is issued under the sole responsibility of the manufacturer and that the packaging complies with PPWR requirements (Articles 5–12).
- Reference to Union legislation
- A statement that the packaging is in conformity with Regulation (EU) 2025/40 on packaging and packaging waste.
- Where relevant, a list of other applicable Union acts for which this DoC also applies (e.g. food-contact, batteries, etc.).
- Design and test basis
- References to harmonised standards, common specifications or internal specifications used to demonstrate compliance (e.g. recyclability assessment methods, minimisation methodologies).
- Place, date and signature
- Place and date of issue.
- Name and position of the signatory, and a signature on behalf of the manufacturer.
If you design packaging with “design for recycling” in mind, the DoC is where you formally connect that design work with the legal compliance requirements.
4. Technical documentation & retention periods (5–10 years)
The declaration of conformity is only the visible tip of the iceberg. Manufacturers must also maintain technical documentation supporting the declaration. According to Article 15 PPWR, this includes:
- description of the packaging design and variants
- results of conformity assessments per Annex VII (e.g. packaging minimisation, recyclability calculations, reuse characteristics)
- supporting tests, studies, simulations and supplier documents
Retention periods are strict:
- for single-use packaging: keep the technical documentation and the EU declaration of conformity for 5 years after the packaging is placed on the market
- for reusable packaging: keep them for 10 years after placement on the market
For quality assurance, this means your documentation system must be audit-ready over many years – and resilient against staff turnover, system changes and supplier switches.
5. How to build a PPWR-compliant DoC process: a practical approach
For packaging technology and QA teams, the challenge is less the template itself and more the process and data behind it.
Step 1: Map your packaging portfolio
- List all packaging types and variants (sales, grouped, transport, e-commerce).
- Create a logical family structure (e.g. by material, format, application) as a basis for DoCs and technical files.
Step 2: Centralise and digitise specifications
- Collect drawings, bills of materials, material data sheets and supplier declarations.
- Standardise these into consistent digital parameters (materials, layers, weights, inks, adhesives) to support recyclability and minimisation checks.
A digital packaging management platform like Packa can import specs from Excel, PDFs and ERP exports, digitise them with AI and centralise supplier documentation in a single, audit-ready database.
Step 3: Run the PPWR conformity assessment
For each packaging family:
- Check design for recycling (collection, sorting and recycling at scale) against PPWR criteria and relevant standards.
- Assess packaging minimisation (no unnecessary weight or volume).
- Verify compliance with restrictions on formats and materials.
- Document methods, data and assumptions – these form part of Annex VII technical documentation.
Step 4: Draft and standardise your DoC template
- Create a master template that mirrors Annex VIII structure.
- Pre-fill static company information, then generate per-article DoCs with:
- specific packaging IDs and descriptions
- references to the correct conformity assessment documentation
- Where packaging is covered by several regulations, consider a single combined DoC dossier to reduce duplication.
Step 5: Define roles, workflow and change management
- Assign clear responsibility (typically QA or regulatory) for issuing and updating DoCs.
- Link the DoC workflow to change management in packaging design: every significant change (material switch, weight reduction, new supplier) must trigger a review and, if necessary, a new DoC version.
Step 6: Set up secure, long-term document storage
- Store DoCs and supporting technical documentation in a central, version-controlled system with access rights and audit logs.
- Ensure retention periods (5 or 10 years) are covered, even if ERP systems change or plants are restructured.
Packa, for example, is designed as an audit-ready repository for packaging specifications, supplier documentation and compliance evidence, with automated reminders for expiring documents and structured PPWR checks.
6. Typical pitfalls – and how to avoid them
Teams preparing for the PPWR declaration of conformity often run into similar issues:
-
Fragmented data: Specs in Excel, e-mails, PDFs and local folders make it hard to prove traceability from DoC to actual packaging.
→ Solution: central, digital packaging database across procurement, QA and packaging technology. -
Inconsistent IDs: Internal material codes, supplier article numbers and DoC IDs don’t line up.
→ Solution: define a single ID logic and enforce it in all documents and systems. -
Static documents in a dynamic environment: Packaging designs change, but DoCs are not updated.
→ Solution: link DoCs to change management and require documented review for every design change. -
No visibility across the portfolio: You don’t know which packaging types still lack a valid DoC or technical file.
→ Solution: use dashboards or reports showing PPWR readiness per packaging family.
7. Next step: Use a checklist to close your gaps
The obligation to issue a PPWR declaration of conformity for every packaging type from August 2026 is fixed – but how you prepare is up to you. If you rely on manual files and scattered data, the risk of gaps and non-compliance is high.
To structure your preparation, we recommend working with a concise, practical checklist.
Our PPWR checklist helps you verify that you meet all prerequisites for the declaration of conformity – from centralised packaging data and “design for recycling” assessments to supplier documentation, internal responsibilities and retention rules.
With a clear checklist and a digital, audit-ready packaging management platform, you can turn the PPWR declaration of conformity from a regulatory burden into a robust backbone for compliant, future-proof packaging.