Supply Chain

PPWR Declaration of Conformity: What it is, who needs it, and what applies from 2026

The PPWR declaration of conformity is the manufacturer's written self-declaration under Article 39 of Regulation (EU) 2025/40 (PPWR), confirming that packaging meets the requirements set out in Articles 5 through 12. The structure and mandatory information are governed by Annex VIII, while the associated technical documentation is covered by Annex VII. As of August 12, 2026, no packaging may be placed on the EU market without this declaration. It is important to note that this is not a CE marking. There is no CE mark on the packaging, and generally, no notified body is involved. The declaration is a legally binding self-declaration, not an external certification.

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With the declaration of conformity under Article 39 of the PPWR, a standardized, binding proof document for packaging is being introduced across Europe for the first time. This blog explains what the declaration of conformity specifically contains, how it differs from technical documentation and the CE declaration of conformity, who is responsible for creating it, and how companies can prepare now for August 12, 2026.

The European Commission clarified the interpretation questions surrounding the PPWR on March 30, 2026, with a final guidance document and an accompanying FAQ paper. Both documents confirm the obligation to provide a declaration of conformity starting August 12, 2026, and provide additional clarifications that have been incorporated into this article.

What is the PPWR declaration of conformity?

The declaration of conformity is anchored in Article 39 of the PPWR. Once the conformity assessment procedure under Article 38 and Annex VII demonstrates that packaging meets the requirements of Articles 5 through 12, the packaging producer issues the EU declaration of conformity. By signing it, they assume full legal responsibility for the information provided. The declaration is therefore not an optional "nice-to-have" or a mere marketing tool, but a legally required prerequisite for placing any packaging on the EU market.

In terms of content, the declaration relates exclusively to the packaging, not the packaged product. It covers the core sustainability requirements of the PPWR: substance restrictions (Article 5, including heavy metals and PFAS), recyclability (Article 6), minimum recycled content (Article 7), bio-based plastics (Article 8), compostability (Article 9), packaging minimization (Article 10), and reuse and refilling (Articles 11 and 12).

Structurally, the declaration resembles the CE declaration of conformity known from product law (e.g., for machinery or electrical appliances)—however, the two procedures differ significantly in terms of content, partly because no CE marking is provided for packaging.

PPWR declaration of conformity vs. CE declaration of conformity: A comparison

Characteristic	PPWR Declaration of Conformity	CE Declaration of Conformity
Marking on the Product	No CE mark on the packaging	CE mark mandatory
Legal Basis	Article 39 of Regulation (EU) 2025/40	Respective product regulation/directive (e.g. Machinery Regulation)
Structure of the Declaration	Mandatory template per Annex VIII	Usually manufacturer-specific template per the respective regulation
Notified Body	Generally not required (internal procedure, Module A)	Mandatory for many product categories
Object of Reference	The packaging only, not the packaged product	The product itself
Retention Period	5 years (single-use) or 10 years (reusable)	Varies depending on the legal act

Important: No automatic obligation to disclose

A common misconception is that customers or distributors are automatically entitled to a supplier's declaration of conformity. This is not the case. The producer only needs to provide downstream economic operators with the data from the technical documentation that they require for their own conformity assessment. Providing the full declaration itself is a voluntary service. A legal obligation to disclose it exists only toward importers and authorized representatives for imports from third countries, and toward market surveillance authorities upon request.

Distinction: Declaration of conformity, EPR registration, and the Packaging Act

In practice, the PPWR declaration of conformity, registration in the German LUCID packaging register, and system participation under the Packaging Act (VerpackG) are often confused. However, these are three legally separate obligations that exist side-by-side and concern different actors, deadlines, and registers.

Obligation	Legal Basis	Applies To	Register/Evidence
EU Declaration of Conformity (DoC)	Art. 39 PPWR (EU level)	Producer of any packaging	No register – provided on request by the authority
LUCID Registration	VerpackG (Germany)	Manufacturers under extended producer responsibility	Central Agency Packaging Register (ZSVR)
System Participation (dual system)	VerpackG (Germany)	Manufacturers of packaging subject to system participation	Dual systems, annual declaration of completeness
Technical Documentation	Annex VII PPWR (EU level)	Producer of any packaging	Internal retention, no registration

Important for practice: The producer role under the PPWR (responsible for the declaration of conformity) and the manufacturer role under the Packaging Act (responsible for LUCID and system participation) often, but not necessarily, fall to the same company. Both obligations should be checked separately, as fulfilling one does not replace the other.

Legal basis: An overview of Article 39 and Annex VIII

Article 39 requires the producer to issue an EU declaration of conformity after a successful conformity assessment procedure, confirming under their own responsibility that the packaging meets the relevant requirements. By signing, the producer assumes full legal responsibility for the information. Annex VIII specifies the binding structure of the declaration; Annex VII governs the associated technical documentation and the assessment procedure.

If packaging is subject to multiple EU legal acts simultaneously, a single, combined declaration of conformity may be issued, provided that all relevant legal acts are clearly named therein. This reduces administrative effort but does not change the depth of the required content verification.

What mandatory information does Annex VIII require?

Annex VIII defines the minimum information that a declaration of conformity must contain. While wording and order may vary slightly depending on the source, the mandatory fields can be summarized into the following core elements:

Required Field	Content
Unique Identification Number	Reference linking the declaration to internal systems (e.g. article, batch, or material number)
Name and Address of the Producer	Where applicable, also name and address of the authorized representative
Statement of Responsibility	Explicit statement that the declaration is issued under the sole responsibility of the producer
Subject of the Declaration	Clear description of the packaging including type, batch, or serial number – "all our packaging" is not sufficient
Conformity Statement	Declaration that the packaging meets Articles 5 to 12 of the PPWR
Standards/Specifications Applied	Harmonized standards or other technical specifications on which the assessment is based
Details of the Notified Body	Only if an external testing body was involved – for packaging, usually "not applicable"
Place, Date, Signature	Name, position, and signature of the responsible person

If any of these elements are missing, the declaration is considered incomplete. In case of doubt, the packaging will be treated by market surveillance as packaging without a valid declaration. This carries distribution risks, up to and including a sales ban on the affected packaging.

How does the declaration of conformity relate to the technical documentation?

The declaration of conformity and the technical documentation are two separate documents with different functions, but together they form a package of evidence: the declaration is the short, signed summary, while the technical documentation provides the supporting evidence.

Aspect	Technical Documentation (Annex VII)	Declaration of Conformity (Annex VIII)
Function	Documents in detail how conformity was achieved	Legally binding summary of the result
Typical Content	Design drawings, material specifications, test reports, calculations on recycled content and recyclability	Identification number, producer details, conformity statement, signature
Scope	May comprise several documents depending on the packaging	Usually one to two pages per packaging item
Primarily Prepared By	Engineering, procurement, quality management, suppliers	Producer (signing person)
Review by Authorities	Must be provided on justified request (usually within 10 days)	A copy must also be held by importers and distributors

Who is responsible for creating the documentation? Roles and responsibilities

The PPWR clearly distinguishes between roles in the supply chain. Which role a company takes on depends on the specific situation. A company can certainly hold multiple roles simultaneously.

Role	Core Obligation	Example
Producer	Carries out the conformity assessment procedure, prepares technical documentation and declaration of conformity	A consumer goods manufacturer having packaging developed under its own brand
Importer	Checks that a valid declaration and technical documentation from the producer exist; keeps copies available for authorities	A wholesaler importing packaged goods from a third country into the EU
Distributor	Verifies that the producer and, where applicable, the importer have fulfilled their obligations; checks labeling	A retail company selling products in stores without being a producer itself
Brand Owner	Is considered a producer as soon as packaging is placed on the market under its own name or brand	A retail company with private-label products

Practical tip

Check your role for each type of packaging, not just per company. The same company may be a producer for one product line and act as an importer or distributor for another. A blanket classification often leads to gaps in the chain of evidence.

Special rule for micro-enterprises

Article 3 of the PPWR provides an exemption for micro-enterprises: those with fewer than 10 employees and an annual turnover or annual balance sheet total of no more than 2 million euros are not considered producers if the packaging is manufactured or developed by a supplier based in the same EU Member State. In this case, the supplier assumes the role of producer and, consequently, the obligation to issue the declaration of conformity.

Example: A micro-enterprise has folding boxes with its own logo produced by a German packaging manufacturer. Under Article 3, the packaging manufacturer, not the micro-enterprise, is considered the producer, provided both companies are located in the same Member State. The micro-enterprise does not need to carry out a conformity assessment, create technical documentation, or issue a declaration of conformity for this packaging.

Important: The exemption does not apply to all obligations

The micro-enterprise exemption applies exclusively to producer obligations under the PPWR (conformity assessment, technical documentation, declaration of conformity). For registration in the LUCID packaging register and system participation under the Packaging Act (VerpackG), however, the status of "manufacturer" is what matters. There is no corresponding micro-enterprise exemption for this. A micro-enterprise may therefore be exempt from the declaration of conformity while still being independently required to register with LUCID.

When do the obligations take effect – and how long must records be kept?

The PPWR entered into force on February 11, 2025. Following a transition period, it will apply directly in all EU Member States from August 12, 2026, without the need for national transposition and without a sell-off period for existing stock. From this date, no packaging may be placed on the market without a valid declaration of conformity and technical documentation.

Milestone	Date	Significance
PPWR Enters Into Force	February 11, 2025	Regulation formally applies, though many obligations are not yet in effect
EU Guidance Document & Commission FAQ	March 30, 2026	Binding interpretive guidance on conformity assessment, PFAS limits, and more
Declaration of Conformity & Technical Documentation Take Effect	August 12, 2026	First hard obligation: no packaging without a DoC
Harmonized Labeling / Design-for-Recycling	From 2027–2030 (phased)	Further requirements added progressively via delegated acts

The retention period for the declaration of conformity and technical documentation is five years from the date the packaging is placed on the market for single-use packaging, and ten years for reusable packaging. Authorities may request these documents as part of market surveillance, audits, or upon reasoned request, typically with a ten-day deadline for submission. Article 39(5) also requires authorities to conduct risk-based spot checks of declarations of conformity, regardless of specific complaints.

A detail often missing from practical guides: Declarations of conformity can only be legally issued from August 12, 2026, as the underlying material requirements of Articles 5 to 12 only become applicable at that time. Issuing them earlier is not legally possible. However, companies can prepare in terms of content beforehand by collecting data and building their technical documentation.

Sanctions: What happens if the declaration of conformity is missing or incorrect

If a market surveillance authority determines that the declaration of conformity is missing or has not been issued correctly, this is considered a formal non-compliance under Article 62 of the PPWR. This triggers a step-by-step procedure:

Request for correction: The economic operator must remedy the non-compliance within a reasonable period.
Prohibition of supply: If the non-compliance persists, the Member State must prohibit the packaging from being made available on the market.
Recall or withdrawal: In the event of continued non-compliance, the authority may order the recall or withdrawal of the affected packaging from the market.

The PPWR does not set the specific amount of fines itself: according to Article 68, EU Member States must enact their own effective, proportionate, and dissuasive sanctioning rules by February 12, 2027. Until the German Packaging Implementation Act (VerpackDG) is passed, projections are based on the existing fine framework of the Packaging Act (VerpackG), which provides for up to 200,000 euros per violation for serious offenses. The material obligations of the PPWR apply independently of this from August 12, 2026, regardless of whether national sanctioning rules are fully formulated by that date.

Important: Regulatory sanctions are not the only risk. Under the PPWR, online marketplaces like Amazon are required to verify sellers' EPR registration and can suspend providers who lack proof of conformity. Brick-and-mortar retail partners are also increasingly demanding declarations of conformity from their suppliers before listing products, regardless of the status of national fine regulations.

One declaration per packaging – or bundled for multiple variants?

In principle, yes: every packaging unit placed on the market requires its own declaration. In practice, however, the effort can be streamlined. Identical packaging that differs only in size can be grouped into a single declaration, provided that none of the material requirements change as a result. For example, a manufacturer of folding boxes in five sizes with identical material and construction can issue one declaration for the entire product family, as long as the material composition and recyclability remain the same across all sizes. If the material changes, however—such as a laminated version with an additional plastic layer—a separate assessment and usually a separate declaration are required.

Template and sample: What Annex VIII already specifies

Annex VIII of the regulation already contains a sample form with the prescribed structure. This is not an invention of consulting firms, but part of the legal text itself. However, it is a general framework structure, not a pre-filled, industry-specific template. Associations such as the VCI (for the chemical industry) or individual chambers of commerce and industry have published adapted tools based on this, which provide examples of wording and instructions for completion.

Important: A downloaded template does not replace a substantive review. The structure according to Annex VIII is mandatory. The correct assignment of articles, standards, and test evidence to the respective packaging remains the responsibility and liability risk of the producer.

Step-by-step: How companies create their declaration of conformity

In practice, the creation of a declaration of conformity can be divided into six steps, regardless of whether a company has a few or several hundred packaging variants in its portfolio:

1. Clarify role: Is the company the producer, importer, or distributor for the respective packaging—and does the small enterprise exemption apply?

2. Build packaging master data: Structure and record material, weight, construction, and supplier for each packaging variant.

3. Obtain supplier evidence: Request material declarations, test reports, and recyclate certificates from packaging suppliers.

4. Conduct conformity assessment: Check and document whether the packaging meets Articles 5 to 12 and create the technical documentation according to Annex VII.

5. Issue declaration of conformity: Complete the sample according to Annex VIII, clearly identify each packaging unit, and have it signed by a responsible person.

6. Archive and keep up to date: Store the declaration and technical documentation in an audit-proof and versioned manner—update in the event of material or design changes.

Typical errors that invalidate the declaration of conformity

Mistake	Why It's Not Enough
Using an existing quality certificate (e.g. ISO 9001) as a substitute	Does not replace a PPWR DoC; the declaration must explicitly reference Regulation (EU) 2025/40
Issuing one blanket declaration for the entire product range	Annex VIII requires unique identification of each individual packaging item
Issuing a declaration without underlying technical documentation	If the documentation cannot be provided on request within the deadline, conformity is deemed unproven
Not setting up an update process	With a material change, new supplier, or design change, the declaration becomes outdated unnoticed
Unstructured storage in email inboxes	A five- to ten-year retention obligation cannot be reliably proven for audits this way in practice

Further practical challenges

In addition to the sources of error mentioned, other problems regularly arise during operational implementation across hundreds or thousands of packaging variants:

Data on material, recyclate content, and recyclability are scattered across purchasing, development, quality management, and suppliers, with no central source.

Suppliers provide documentation late, incomplete, or in inconsistent formats.

Different material combinations (composites, multilayer films) make uniform assessment difficult.

Missing documents are only noticed during an official inquiry, when the ten-day deadline is already ticking.

Excel-based management reaches its limits with several hundred packaging items and multilingual requirements.

Why software is becoming increasingly indispensable for PPWR documentation

Starting in August 2026, companies must maintain a reliable chain of evidence for every piece of packaging that can be presented upon request at any time, spanning years and accounting for changing suppliers and packaging variants. Manual processes in spreadsheets quickly reach their limits as soon as versioning, deadlines, and multilingual requirements come into play.

Specialized PPWR software like cubemos helps companies to

manage packaging data centrally and in a structured way, rather than scattering it across emails and spreadsheets,

document evidence for each package in a traceable manner and link it to the technical documentation,

collect supplier data in a structured way and consolidate it automatically,

track requirements and deadlines for each packaging variant,

map changes to materials or design in an audit-proof and versioned manner,

provide reports and evidence quickly and completely in the event of an official inquiry,

and reuse packaging data once it has been captured for other ESG requirements such as EUDR, CSRD, or VSME, instead of collecting it all over again.

This ensures that the declaration of conformity is not just a one-off chore, but a permanently reliable component of the compliance process.

Frequently Asked Questions (FAQ)

What is a PPWR declaration of conformity?

A PPWR declaration of conformity is the producer's written self-declaration under Article 39 of Regulation (EU) 2025/40, confirming that packaging meets the requirements of Articles 5 to 12 of the PPWR. It is based on a prior conformity assessment and technical documentation.

Is the PPWR declaration of conformity mandatory?

Yes. As of August 12, 2026, no packaging may be placed on the EU market without a valid declaration of conformity. The regulation does not provide for a transition or sell-through period for existing stock.

When can the declaration of conformity be issued?

Legally, no earlier than August 12, 2026, as the underlying material requirements of Articles 5 to 12 only become applicable at that time. However, companies can prepare beforehand by collecting data and compiling the technical documentation.

Who is responsible for creating the declaration of conformity?

In principle, the packaging producer—that is, the company that manufactures packaging under its own name or brand, or has it manufactured. Importers and distributors have supplementary verification and record-keeping obligations.

Is there an exemption for micro-enterprises?

Yes. According to Article 3 of the PPWR, a micro-enterprise (fewer than 10 employees, annual turnover or balance sheet total of no more than €2 million) is not considered a producer if the packaging is sourced from a supplier based in the same Member State. In that case, the supplier assumes the producer obligations, including the declaration of conformity. This exemption does not apply to registration obligations under the Packaging Act.

What documents are required for the declaration of conformity?

The basis is the technical documentation according to Annex VII (including material specifications, design drawings, and test reports on recyclability, recycled content, and heavy metals). The declaration itself summarizes this evidence according to the structure of Annex VIII.

Which packaging is affected by this requirement?

In principle, all packaging made available on the EU market for the first time from August 12, 2026, regardless of the material. For certain requirements, such as design-for-recycling criteria, staggered deadlines apply in some cases.

Is there an official template for the PPWR declaration of conformity?

Annex VIII of the regulation contains a mandatory framework structure. Industry associations and chambers, such as the VCI or individual Chambers of Commerce and Industry (IHKs), provide fillable templates based on this. There is no single ready-made template for all industries, as the specific content depends on the packaging type and material.

Must the declaration of conformity be submitted to an authority?

No. It does not need to be actively submitted, but it must be available to be presented upon request by a market surveillance authority, usually within ten days of the request, along with the technical documentation.

Do I have to provide the declaration of conformity to my customer?

Generally, not automatically. The producer only needs to provide downstream economic operators with the data from the technical documentation necessary for their own conformity assessment; providing the full declaration is voluntary. A legal obligation to pass it on exists only for importers and authorized representatives regarding imports from third countries.

Is the declaration of conformity the same as LUCID registration?

No. The declaration of conformity under Article 39 of the PPWR concerns the producer role at the EU level. Registration in the LUCID packaging register and system participation concern the manufacturer role under the German Packaging Act (VerpackG). Both obligations exist independently of each other and may apply to different companies in the supply chain.

What are the consequences of a missing or incomplete declaration?

According to Article 62 of the PPWR, this is initially considered a formal non-compliance: it will be followed by a request for correction, and in the event of continued violation, a ban on making the product available, and, if in doubt, a recall or withdrawal from the market. Member States will set the specific fines by February 12, 2027; in Germany, the existing fine framework of the Packaging Act (up to 200,000 euros per violation) serves as a guideline.

Who monitors compliance with the PPWR declaration of conformity?

The national market surveillance authorities of the EU Member States. Article 39(5) mandates that they conduct risk-based spot checks, regardless of specific complaints. Increasingly, online marketplaces and trading partners are also requiring proof before listing products.

What data must companies collect for the declaration?

In particular, information on material composition, recycled content, recyclability, substance restrictions (including heavy metals, PFAS), packaging design and minimization, and, where applicable, reuse and refilling.

How long must the declaration of conformity be kept?

Five years from the date of placing on the market for single-use packaging, and ten years for reusable packaging.

Can software support the creation and management of the declaration of conformity?

Yes. Specialized compliance software such as cubemos can centrally manage packaging data, consolidate supplier documentation, track deadlines, version changes in an audit-proof manner, and provide evidence quickly when needed.

Where can I find the official PPWR requirements?

Regulation (EU) 2025/40 is available in full on EUR-Lex. Additionally, the European Commission published a guidance document and an FAQ paper on March 30, 2026, which clarify key interpretation issues.

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