PPWR declaration of conformity: a template you can fill in
The declaration of conformity under Annex VIII is the document with which you declare that your packaging meets the requirements of the PPWR. It is not a formality: if a mandatory item is missing, the declaration is incomplete. Here you will find every required field, a fully worked example and the template to adopt.
Ben Koenigs
Co-Founder & CPO, Reguly · Stand August 2026
- Every mandatory item under Annex VIII, explained field by field
- A fully worked example for a folding carton
- Notes on which source inside the company each item comes from
Who has to issue the declaration
The declaration of conformity is issued by whoever places the packaging on the EU internal market. That is usually the manufacturer — for imports from a third country, the importer, who thereby assumes the manufacturer’s duties.
What matters is not who physically produces the packaging but under whose name or brand it reaches the market. Anyone selling a packaging under their own brand counts as the manufacturer, even where a contract manufacturer produced it.
The mandatory items under Annex VIII
Annex VIII prescribes the content. The declaration is not a free-form document — it has to contain the following items, and they must be unambiguously assignable to a specific packaging:
- A unique identifier for the packaging or packaging type
- Name and address of the manufacturer, and for imports also of the importer
- A statement that the declaration of conformity is issued under the sole responsibility of the manufacturer
- The object of the declaration — a description of the packaging sufficient for traceability
- A reference to the relevant harmonised standards or technical specifications
- Date of issue, place, name and signature of the responsible person
How long you have to keep the document
The declaration of conformity and the technical documentation behind it must be kept for ten years from the date of placing on the market and produced to market surveillance authorities on request.
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 recycled-content figures are in the document but nothing substantiates them
- The declaration is signed but the corresponding technical documentation does not exist
This template is a working aid and does not replace legal advice. What governs is the text of the regulation as it applies at the time.