Declaration of Conformity under the PPWR: creating the declaration and the technical documentation

The EU Packaging and Packaging Waste Regulation (PPWR) has applied since 12 August 2026. Anyone who makes packaging or has it made and places it on the market under their own name must demonstrate for every packaging that it meets the requirements. This evidence has two parts: the EU declaration of conformity (DoC) under Annex VIII and the technical documentation under Annex VII. This article explains what the regulation requires for both documents, which information goes into them and what creating them means in practice.

Declaration of conformity

Annex VIII, Art. 39 PPWR

Technical documentation

Annex VII, Art. 15 PPWR

Unit

Per packaging, not per product line

Retention

5 years, 10 for reusable packaging

Who has to create the documents

The manufacturer is responsible. It carries out the conformity assessment under the internal production control procedure (Module A), draws up the technical documentation and issues the declaration of conformity under its sole responsibility. No notified body is involved. Importers must keep a copy of the declaration and ensure the technical documentation can be provided on request. Suppliers do not issue their own declaration, but under Art. 16 they must give the manufacturer all information and documents it needs for the evidence.

What goes into the declaration of conformity (Annex VIII)

The declaration of conformity is the legally binding statement that a packaging meets the requirements of the PPWR. Annex VIII sets out its content:

• A unique identification of the packaging, such as product, batch, type or serial number.
• Name and address of the manufacturer and, where applicable, its authorised representative.
• 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 that allows traceability, with an image where appropriate.
• A statement that the object is in conformity with the relevant Union harmonisation legislation.
• References to the harmonised standards, common specifications or other technical specifications applied.
• Additional information: place and date of issue, name and function of the signatory and the signature.

What goes into the technical documentation (Annex VII)

The technical documentation is the evidence behind the declaration. Annex VII does not prescribe a fixed form but a framework: it must show that every relevant requirement has been checked and with what result. In practice this covers:

• A general description of the packaging and its intended use.
• Structure, components, materials and weights, with drawings and diagrams where needed.
• Information on substance restrictions under Art. 5, such as heavy metals and substances of concern.
• The justification for minimising weight and volume under Art. 10.
• The recyclability assessment under Art. 6, once the criteria per category are set.
• The recycled content of plastic packaging under Art. 7, with evidence of origin.
• The list of standards and specifications applied.
• Test reports, calculations and supplier declarations on which the assessment is based.

1. 12 Aug 2026

   Evidence required

   Conformity assessment, technical documentation and declaration of conformity are binding.

2. 12 Feb 2027

   Fines possible

   Missing or incomplete evidence can be penalised in Germany.

3. 1 Jan 2030

   Design and material

   Recyclability and minimum recycled content must be evidenced in the documentation.

What creating them means in practice

On paper the requirements look manageable. The effort comes from volume and detail. Declaration and documentation are drawn up per packaging, not per product line. A range of a few hundred items means a few hundred sets of evidence, each with its own components, materials and weights.

• Gathering data: material information, weights and recycled content sit with different suppliers and have to be requested from each of them.
• Checking completeness: if a component or a data point is missing, the evidence has gaps, even if the declaration is signed.
• Keeping it current: if a material, supplier or component changes, the documentation and possibly the declaration have to be updated.
• Proving versions: the documents must be kept for five years, ten for reusable packaging, and it must be clear which state applied when.
• Delivering fast: on a reasoned request from the authority, the documents have to be provided within ten days.

Handling this with spreadsheets, emails and Word templates quickly means weeks of searching and losing track whenever something changes. An empty template does not help much if the data behind it is missing or out of date.

How Reguly supports you

Reguly brings packaging data, supplier information and evidence together in one place. From the recorded data, the declaration of conformity and the technical documentation are created per packaging, complete under Annex VIII and Annex VII, versioned and available at any time. Missing information becomes visible before it turns into a problem, and supplier requests run in a structured way instead of by email.