PPWR EU Declaration of Conformity (Article 39, Annex VIII): Contents, Template and Who Signs It

The EU declaration of conformity (DoC) is the document in which the manufacturer states, under Article 39 of the PPWR (Regulation (EU) 2025/40), that its packaging meets the requirements of Articles 5 to 12, and it has been required since 12 August 2026 for packaging placed on the market. One declaration is drawn up for each packaging type, and no notified body takes part.

The declaration is the manufacturer's formal statement under the EU Packaging and Packaging Waste Regulation (PPWR) that its packaging meets the rules. It follows the model structure of Annex VIII: a numbered title, eight numbered points and a signature block. By drawing it up, the manufacturer assumes responsibility for the packaging's compliance (Art. 39(4) PPWR).

This page sets out what the declaration states, what it contains, how many are needed, who signs, how to prepare one step by step, how long it is kept by each operator and what happens when it is missing or wrong.

Compiled by the PackagingRegulation.org Editorial Team from the Regulation's text on EUR-Lex and the cited official sources; see our methodology and fact-checking.

The key facts of the PPWR declaration of conformity are summarised in the table below.

What Is the EU Declaration of Conformity under the PPWR?

A manufacturer's declaration of conformity under the PPWR states that fulfilment of the requirements of Articles 5 to 12 has been demonstrated for a packaging type (Art. 39(1) PPWR). It is the last of three steps that Art. 15(2) PPWR sets before packaging is placed on the market. The manufacturer first carries out the Art. 38 conformity assessment procedure or has it carried out on its behalf, then draws up the Annex VII technical documentation, and draws up the declaration once compliance has been demonstrated.

The declaration follows the assessment and the documentation and does not replace either of them. Art. 39(4) PPWR attaches the legal consequence: by drawing up the EU declaration of conformity, the manufacturer assumes responsibility for the compliance of the packaging. A "PPWR compliance statement" and a "declaration of compliance" are other names for the same Art. 39 document; the Regulation itself uses only "EU declaration of conformity".

Is the PPWR declaration of conformity a certificate or a CE marking?

No: the declaration is a self-declaration that closes the internal production control procedure (Module A, Annex VII), so no notified body issues a certificate and no CE marking is affixed for the PPWR. Art. 38 PPWR does not include third-party conformity assessment, and the Regulation provides no "PPWR certificate". Recital 109 adds that a CE marking on packaging does not indicate compliance with the PPWR.

What Does the PPWR Declaration of Conformity Contain under Annex VIII?

Annex VIII of the PPWR sets the model structure of the EU declaration of conformity: a numbered title, eight numbered points and a signature block. Art. 39(2) PPWR makes this structure binding: the declaration has the model structure set out in Annex VIII, contains the elements specified there and is continuously updated. The elements of the Annex VIII model are set out in the table below.

Point 7 applies only where a notified body is involved. Module A involves no notified body, so the manufacturer has no notified-body number to enter.

Can one declaration of conformity cover several EU acts?

Yes, where appropriate: Art. 39(3) PPWR provides a single EU declaration of conformity for all Union acts that require one, which may take the form of a dossier of the individual declarations. The dossier form lets the manufacturer keep the individual declarations side by side instead of merging them into one text.

In which language must the declaration of conformity be drawn up?

The declaration must be drawn up in, or translated into, the language or languages required by the Member State in which the packaging is placed or made available on the market (Art. 39(2) PPWR). Germany sets its rule in § 62 of the VerpackDG: the signed EU declaration of conformity is kept in German or English, with a translation into German on request. The German rule on declaration languages is one of the national rules explained under PPWR in Germany.

How Many Declarations of Conformity Does the PPWR Require?

The PPWR requires one EU declaration of conformity for each packaging type (Annex VII point 4). A manufacturer with 40 packaging types therefore draws up 40 declarations, each with its own number in the Annex VIII title. The same point 4 sets the retention period for each declaration: 5 years for single-use packaging and 10 years for reusable packaging after placing on the market.

"Type" here means each packaging format or each batch or series, not the material types listed in Annex II, according to the Commission's PPWR FAQ (non-binding), section XV. A PET bottle and a glass jar are two types; so are two bottle formats in the same material. What goes into the file behind each declaration is explained under PPWR technical documentation.

Do closures, labels and transport packaging need their own declaration?

A bottle with its closure and label is assessed and declared as one packaging unit, while pallets, collars, wrappings and straps used as transport packaging get no exemption and need their own assessments and declarations, according to the Commission's PPWR FAQ (non-binding), section XV. The closure and label are therefore not separate packaging types for the bottle's declaration. Transport packaging is different: the Commission reads it as packaging in its own right, so the stretch wrap on a pallet has its own assessment and declaration.

Can one declaration of conformity cover several sizes?

Yes, but only where the size does not affect compliance with Articles 5 to 12 and the product is the same, according to the Commission's PPWR FAQ (non-binding), section XV. Where the size does affect compliance with any of Articles 5 to 12, each size needs its own declaration.

Who Signs the PPWR Declaration of Conformity?

The manufacturer signs the PPWR declaration of conformity; by drawing it up, it assumes responsibility for the packaging's compliance (Art. 39(4) PPWR). The manufacturer is any natural or legal person that manufactures packaging or a packaged product (Art. 3(1)(13) PPWR). Where packaging is designed or manufactured under a person's own name or trademark, that person is the manufacturer (point (a)). The signature block of Annex VIII records the place and date, the name and function of the person who signs, and the signature.

Commission Notice C/2026/3084 (OJ C, 10.6.2026), a non-binding guidance document, explains who the manufacturer is in practice. For sales and grouped packaging, the manufacturer is normally the filler, often the brand owner. For transport, service and primary production packaging, it is normally the company manufacturing the packaging, unless the packaging is branded by the user. The Notice adds that there is always only one manufacturer in a supply chain, so a filled bottle has one declaration signatory, not one per stage.

When does an importer, distributor or supplier become the signatory?

An importer or distributor takes over the manufacturer's obligations, including the declaration, when it places packaging on the market under its own name or trademark or modifies it in a way that could affect compliance (Art. 21 PPWR). A packaging supplier becomes the signatory through the micro-enterprise rules. Art. 3(1)(13)(b) PPWR names the supplier as manufacturer where the brand owner is a micro-enterprise and its supplier is located in the same Member State. Art. 15(12) PPWR, for the purposes of Art. 15, names the supplier where the micro-enterprise brand owner's supplier is located in the Union. The three triggers are listed below.

• Own name or trademark: an importer or distributor that places packaging on the market under its own name or trademark becomes the manufacturer (Art. 21 PPWR).
• Modification: an importer or distributor that modifies packaging in a way that could affect compliance becomes the manufacturer (Art. 21 PPWR).
• Micro-enterprise brand owner: the supplier is the manufacturer where the brand owner has fewer than 10 persons and a turnover or balance sheet total not above EUR 2 million under Recommendation 2003/361/EC (Art. 3(1)(13)(b), 15(12) PPWR).

The micro-enterprise rule moves the duty to the supplier; it is not an exemption from it.

Can a consultant, laboratory or authorised representative draw up the declaration?

Others may prepare the paperwork, but the legal responsibility stays with the manufacturer: Commission Notice C/2026/3084 states that the manufacturer is the sole economic operator bearing legal responsibility regardless of who actually drafted the EU declaration of conformity. The Art. 38 procedure can be carried out by the manufacturer or by someone else on its behalf, for example a laboratory or a certification scheme, according to the same Notice. Art. 15(2) PPWR uses the same wording: the manufacturer carries out the procedure "or has it carried out on their behalf".

The manufacturer may appoint an authorised representative by written mandate under Art. 17 PPWR, which is optional. The representative keeps the declaration and the technical documentation for 5 or 10 years and provides them within 10 days of a request (Art. 17(2) PPWR). The Art. 15(1) obligations and drawing up the Annex VII technical documentation are not part of the mandate. The product-compliance representative is not the authorised representative for EPR, a different role under Art. 45(3) PPWR.

PPWR Declaration of Conformity Template: How to Prepare It Step by Step

The only binding template for a PPWR declaration of conformity is the Annex VIII model structure, which Art. 39(2) PPWR requires every declaration to follow. A completed declaration rests on six earlier steps, from identifying the manufacturer to the technical documentation, so the template is the final page of a longer file. The seven steps to prepare one declaration are listed below.

1. Identify the manufacturer: the person under whose name or trademark the packaging is designed or manufactured, or the supplier where Art. 3(1)(13)(b) or Art. 15(12) PPWR shifts the role.
2. Define each packaging type and its identification by type, batch or serial number or another element, given in an accompanying document where size or nature does not allow (Art. 15(5) PPWR).
3. Collect the information and documentation that suppliers must provide to demonstrate conformity, including the Annex VII documentation required under Articles 5 to 11 (Art. 16(1) PPWR).
4. Carry out the Art. 38 internal production control and draw up the Annex VII technical documentation, with test reports and an analysis of the risks of non-conformity.
5. Complete the numbered title and the eight Annex VIII points for that packaging type, entering point 7 on the notified body only where applicable.
6. Sign the declaration in the Annex VIII signature block, stating the place and date and the name and function of the signatory.
7. Keep the declaration for 5 or 10 years, update it continuously, re-assess under Art. 38 when conformity could be affected, and translate it where a Member State requires.

When Must the Declaration Be Ready, and How Long Must It Be Kept?

The declaration must exist before the packaging is placed on the market, which applies to packaging placed on the market from 12 August 2026, the PPWR's general application date (Art. 15(2), Art. 71). The Regulation entered into force on 11 February 2025. Packaging placed on the market before 12 August 2026 may stay on the market. After the first issue, the declaration is continuously updated (Art. 39(2) PPWR), and Art. 15(4) PPWR requires procedures that keep series production in conformity, with a re-assessment under Art. 38 where conformity could be affected. The general application date is one of several PPWR application dates; the timeline lists every other one.

Retention runs from the date the packaging was placed on the market: 5 years for single-use packaging and 10 years for reusable packaging (Art. 15(3) PPWR). The manufacturer provides the documentation within 10 days of receiving a reasoned request from a national authority, in electronic form and on paper on request (Art. 15(10) PPWR). Art. 15(11) PPWR exempts custom-made transport packaging for configurable medical devices and medical systems used in industrial and healthcare environments from Art. 15(2) and (3), so no declaration duty arises for it. The table below shows who keeps or checks the declaration.

What must importers and distributors keep or check?

Importers keep a copy of the EU declaration of conformity for 5 years (single-use packaging) or 10 years (reusable packaging) and must first check that the manufacturer carried out the Art. 38 procedure and drew up the Annex VII technical documentation (Art. 18(2)(a) and 18(7) PPWR). The importer also checks the Art. 12 labelling, the required accompanying documents and the manufacturer's Art. 15(5) and (6) identification and contact details (Art. 18(2)(b) to (d)), and provides documents within 10 days (Art. 18(8)). Distributors check three points under Art. 19(2) PPWR: that the producer is registered in the Art. 44 register, that the packaging is labelled under Art. 12, and that Art. 15(5), (6) and 18(3) are complied with; the declaration is not among them. Suppliers are not responsible for drawing up a declaration and cannot refuse the documentation, according to the Commission's PPWR FAQ (non-binding), section X. Every other check before import is set out in the PPWR obligations of importers.

What Happens If the Declaration of Conformity Is Missing or Wrong?

Competent authorities must endeavour to check the accuracy of at least part of the declarations of conformity every year, choosing them on a risk basis (Art. 39(5) PPWR). A check that finds an inaccurate declaration leads to the formal non-compliance rules of Art. 62.

Art. 62(1) PPWR lists a declaration that has not been drawn up (point (a)) or has not been drawn up correctly (point (b)) as formal non-compliance, together with Annex VII technical documentation that is missing, incomplete or erroneous (point (d)). Where the formal non-compliance persists, Art. 62(2) PPWR leads to a prohibition of making the packaging available on the market, a recall or a withdrawal. The PPWR sets no fine amount; Member States lay down and notify penalty rules by 12 February 2027 (Art. 68 PPWR), as explained under PPWR penalties and market surveillance.

How Does the Declaration of Conformity Fit into PPWR Compliance?

The declaration of conformity is the final step of the manufacturer's conformity route under the PPWR, after the Art. 38 conformity assessment and the Annex VII technical documentation. Art. 15(2) PPWR sets this order for every packaging type before placing on the market. The declaration is one document in wider PPWR compliance; the plan lists every operator duty.

The Annex VII technical documentation holds the general description and intended use, the design and materials, the harmonised standards, common specifications or other specifications applied, a qualitative description of the assessments under Art. 6, 10 and 11, test reports and a risk analysis. Packaging that conforms to harmonised standards cited in the Official Journal (Art. 36(3)) or to common specifications (Art. 37(1)) is presumed to comply with Articles 5 to 12, 24 and 26. The Art. 7(8) implementing act on the format of technical documentation for recycled content was due by 31 December 2026 and is not adopted as of 24 October 2026.

Which PPWR requirements does the declaration of conformity cover?

The declaration covers the requirements laid down in or pursuant to Articles 5 to 12 of the PPWR, from substances of concern to labelling. In the order of the Regulation these are substances of concern including the PFAS limits for food-contact packaging (Art. 5), recyclability (Art. 6), recycled content (Art. 7), bio-based feedstock (Art. 8), compostability (Art. 9), minimisation (Art. 10), reusability (Art. 11) and labelling (Art. 12). Each rule the declaration covers is explained under PPWR requirements for packaging.

Several of these articles refer the proof back to the technical file. Art. 5(6), 6(9), 10(4) and 11(3) PPWR state that compliance is demonstrated in the Annex VII technical documentation.

Does the declaration of conformity replace EPR registration?

No: the declaration concerns the packaging's compliance with Articles 5 to 12, while EPR registration is a separate producer duty in the register of each Member State (Art. 44 PPWR). Registration, reporting and fees are explained under packaging EPR under the PPWR.

Does packaging made outside the EU need an EU declaration of conformity?

Yes: packaging from a third country needs the same declaration, and the importer established in the Union checks the documentation and keeps a copy of the declaration. The importer is the natural or legal person established within the Union that places packaging from a third country on the market (Art. 3(1)(17) PPWR), and imported packaging is placed on the market at release for free circulation, according to Notice C/2026/3084. This page covers the EU rule only.