PPWR declaration of conformity: a template you can fill in

Who has to issue the declaration

The declaration is issued by the manufacturer, the term used in Regulation (EU) 2025/40 (the German text says “Erzeuger”). That is whoever makes the packaging, or has it made, under their own name or brand. For sales and grouped packaging this is usually the brand owner or filler, for contract filling the principal, and for private labels the retailer.

The packaging supplier does not issue a declaration for your filled packaging, but has to provide the documents you need for the assessment (Art. 16). For plain shipping boxes bought in (even with a shipping label), stretch film or tape, the Commission FAQ of August 2026 treats their maker as the manufacturer; request that maker’s declaration as evidence.

The eight points of Annex VIII

Annex VIII prescribes the structure and the headings; it is best to adopt the headings word for word. One declaration covers one type of packaging and the whole packaging unit with all its components, such as bottle, closure and label.

• Header: identification number of the declaration — its own number, not the identifier of the packaging — with version and date
• 1. Unique identification of the packaging: type, batch or serial number, identical to the marking on the packaging
• 2. Name and postal address of the manufacturer and, where applicable, of the authorised representative
• 3. The fixed sentence on the manufacturer’s sole responsibility
• 4. Object of the declaration: a description of the packaging with packaging type, intended use and all components with their material
• 5. Regulation (EU) 2025/40 with its Official Journal reference, the requirements from Articles 5 to 12 being declared, and any other Union legislation applied
• 6. Technical specifications with edition or date and the number of the technical documentation; no harmonised standards have been published under Art. 36 yet
• 7. Notified body: not applicable, because packaging is assessed under Module A (internal production control)
• 8. Additional information, such as exemptions or requirements that apply later; then place, date, name, function and signature

What does not belong in the declaration

Weights, recycled content, recyclability grades, test results and calculations belong in the technical documentation under Annex VII, not in the declaration. The declaration refers to that documentation under point 6.

The declaration covers the requirements that apply on the date of issue. Since 12 August 2026 these are the substance restrictions of Art. 5 (PFAS only for food-contact packaging), recyclability under Art. 6(1) at the previous level, minimisation under EN 13428 during the transition, Art. 11 for reusable packaging and Art. 12(8). Recyclability grades, recycled-content targets and the new material label apply later and will then trigger a new version of the declaration.

How long you have to keep the document

The declaration and the technical documentation must be kept for five years from placing on the market, ten years for reusable packaging (Art. 15(3)). On a reasoned request from an authority the documents must be produced within ten days.

In practice that means: the declaration has to remain findable and legible long after the packaging has stopped being produced — and after the person who signed it has left the company.

The most common mistakes

• The declaration describes a product instead of the packaging
• The unique identifier is missing, so the declaration cannot be assigned to a specific packaging
• The declaration contains material data such as recycled content or recyclability grades, which belong in the technical documentation
• Point 6 lists harmonised standards that do not yet exist under the PPWR
• The declaration is signed but the corresponding technical documentation does not exist