EU Declaration of Conformity Under the PPWR: Complete 2026 Guide for Manufacturers

The Packaging and Packaging Waste Regulation (PPWR) is coming into force across the European Union. A key requirement of this Regulation is changing the way packaging compliance is documented. From the 12th of August, 2026, all packaging sold in the EU market will have to be accompanied by an EU Declaration of Conformity, that is, a formal declaration confirming that the packaging complies with the requirements of the PPWR regulation. It is crucial to understand what this declaration consists of, who is required to issue it, and how to prepare it for any packaging or brand manufacturer wishing to enter the EU market.

This comprehensive, step-by-step guide explains the PPWR EU Declaration of Conformity requirements and how to comply with them. 

Key Points: PPWR EU Declaration of Conformity:

• The EU declaration of conformity is a mandatory document that ensures that packaging complies with the rules of the PPWR regulation before it is placed on the EU market.
• A correct EU declaration requires a direct correlation between packaging design, materials and regulatory requirements.
• Full compliance with EU rules can only be ensured through adequate technical documentation and timely assessments.
• Specialised compliance assistance can facilitate documentation management, minimise risk, and optimise regulatory readiness.

EU Declaration of Conformity under the PPWR – Quick Overview

1. What is an EU declaration of conformity under the PPWR?

The EU Packaging and Packaging Waste Regulation (PPWR) states that the ‘EU Declaration of Conformity’ is a legal document that must be completed. It certifies that a specific type of packaging complies with the applicable requirements of the PPWR relating to design, recyclability, minimisation, reuse and other sustainability criteria.

This document is not simply a checklist. It is a binding declaration by the manufacturer or economic operator acting as a ‘producer’ that the packaging design meets all the regulatory criteria set out in Articles 5 to 12 of the PPWR.

2. Who must issue the EU declaration of conformity?

The obligation falls primarily on the manufacturer of the packaging, defined as the person who places the packaging on the EU market for the first time. Manufacturers must carry out a conformity assessment and then issue the declaration before placing the packaging on the EU market.

If packaging is imported from countries outside the EU, importers or authorised representatives can fulfil this obligation provided they act in accordance with the requirements of the PPWR and keep the necessary documentation.

Distributors who sell packaging under their own brand or modify packaging in such a way as to compromise compliance may also be required to submit the declaration.

3. When does the PPWR EU Declaration of Conformity become mandatory? 

The PPWR came into force in February 2025, but the requirement to have an EU Declaration of Conformity will only fully apply from the 12th of August 2026. From that date, it will no longer be possible to place packaging on the EU market without a valid EU declaration of conformity for that type of packaging.

This is part of a broader timetable set out in the PPWR, which also includes labelling and recycled content obligations by 2030.

4. What must an EU Declaration of Conformity contain under the PPWR? 

Article 39 of the PPWR states that Annex VIII contains a standard template listing the key elements that must be included in the declaration. An approved EU Declaration of Conformity must contain the following:

1. Unique identification number: A reference number that links the document to internal references, part numbers, or vendor codes.
2. Packaging identification: A description of the packaging, including dimensions, materials, and any critical components.
3. Manufacturer data: Name, address and contact details of the manufacturer or authorised representative.
4. Declaration of responsibility: A formal declaration confirming that the manufacturer assumes sole responsibility for compliance with the requirements of the PPWR.
5. Regulatory reference: A declaration of compliance with the PPWR Regulation (Regulation (EU) 2025/40) and any other applicable EU legislation.
6. Design and testing basis: A reference to the standards and technical specifications used to demonstrate compliance.
7. Signature, date and place: The declaration must be signed by an authorised official, stating their name, title and the date.

These points ensure that the document clearly links a given packaging design to the regulatory requirements it claims to meet.

5. What technical documentation is required for the PPWR EU Declaration of Conformity? 

The EU Declaration of Conformity is only one part of a broader compliance framework. In addition to the declaration of conformity, manufacturers must also keep the following technical documents:

• Packaging design specifications and variant details.
• Results of conformity assessments, such as recyclability calculations or reuse verifications.
• Tests, studies and supplier documents used as supporting evidence.

This technical file must be kept for a specified period, typically five years for single-use packaging and ten years for reusable packaging.  It must also be made available to market surveillance authorities upon request. 

6. What are the PPWR EU Declaration of Conformity language, format, and accessibility requirements? 

In the Member State where the packaging is marketed, the EU Declaration of Conformity must be available in the language specified by that State. Companies selling packaging in different EU countries often produce translated versions of packaging.

Declarations can be stored digitally, but must be accessible and retrievable promptly in the event of an inspection by the authorities.

7. What are the risks of non-compliance with the PPWR EU Declaration of Conformity? 

Failure to prepare or update a valid EU Declaration of Conformity can result in serious consequences. Packaging without a valid declaration may be considered non-compliant. This can lead to financial penalties, a ban on market access or exclusion from the EU market.

Even if the packaging meets all technical requirements, companies may still fail audits or inspections if the necessary compliance documentation is missing.

8. How can digital tools help with the PPWR EU Declaration of Conformity? 

Drafting an EU declaration of conformity can be complex, as a significant amount of information must be accurately recorded. Software can help to organise the process, capture the necessary information and verify recyclability.

Digital documentation tools simplify the process for manufacturers and suppliers. Platforms that integrate compliance documents with wider PPWR compliance also make it easier to update and manage declarations over time.

Key Takeaways: PPWR EU Declaration of Conformity 

The EU Declaration of Conformity under the PPWR Regulation is a key compliance requirement that improves transparency and accountability for packaging sold in the EU. Manufacturers can provide structured and verifiable information well in advance of August 2026, provided they are clear about applicable deadlines, documentary requirements and technical standards.