PPWR declaration of conformity: template (Annex VIII)

Most people looking for a PPWR declaration of conformity template do not need a blank form — they need certainty: which mandatory fields under Annex VIII really have to be in it, who is liable for the content and from when the duty applies. This overview walks you through every mandatory item of the EU declaration of conformity (DoC) under Art. 39 of the PPWR and shows why a blank template is more dangerous than it looks.

Legal basis

Art. 39 PPWR + model in Annex VIII

Procedure

Module A / internal production control (Annex VII)

Date of application

12 August 2026 (Art. 71)

Retention

5 years (single use) / 10 years (reusable)

Deadline to produce it

10 days on request (Art. 15(10))

CE marking

not required

What is the EU declaration of conformity (DoC)?

The EU declaration of conformity is the document with which the manufacturer of a packaging declares, in writing and on their own responsibility, that this packaging meets the substantive requirements of the PPWR (Art. 5 to 12). It is not a marketing statement and not an internal memo but a legal undertaking: by issuing it, the manufacturer assumes responsibility for the conformity of the packaging (Art. 39(4)).

The distinction from the technical documentation matters: the technical file under Annex VII substantiates conformity with drawings, material details, the standards applied and test reports. The declaration of conformity summarises the result and establishes responsibility. Both documents stand on their own — the declaration does not replace the file.

Who has to draw up the declaration of conformity?

The primary addressee is the manufacturer of the packaging (Art. 15). Before placing it on the market, they carry out the conformity assessment procedure under Annex VII — for packaging that is internal production control (Module A), a self-assessment without a notified body. Once conformity is demonstrated, they issue the EU declaration of conformity.

Mandatory fields of the PPWR declaration of conformity under Annex VIII

The PPWR sets out a model for the EU declaration of conformity in Annex VIII. It additionally contains the elements of the relevant Annex VII module and has to be kept up to date (Art. 39(2)). A complete declaration contains at least the following mandatory items:

• Details of the manufacturer: name, trade name or brand and postal address (Art. 15(6)).
• Identification of the packaging: an unambiguous reference to the packaging concerned, for example by type, batch or serial number (Art. 15(5)).
• The conformity declared: the statement that the packaging meets the relevant requirements of the PPWR (Art. 5 to 12).
• A reference to the technical documentation and to any harmonised standards or common specifications applied (Art. 36, 37).
• A statement that it is issued under the sole responsibility of the manufacturer (Art. 39(4)).
• Place and date of issue as well as the name, function and signature of the responsible person.

Why a blank template is risky

A blank Word or PDF model suggests the declaration is quickly dealt with. But the legal substance lies in the content, not the layout. Anyone filling in a blank template declares conformity on their own responsibility — and is liable themselves for the completeness and accuracy of every entry. If a mandatory field is missing, the wrong packaging is referenced, or the evidence in the technical file is absent, the risk sits with the signatory, not with whoever produced the template.

On top of that comes the duty to keep it current: where the design, the characteristics or the standards applied change, a fresh assessment may be required (Art. 15(4)) and the declaration has to be adjusted (Art. 39(2)). A static file filled in once does not reflect such changes and goes out of date unnoticed.

From when does the duty apply and how long do you keep it?

The conformity and documentation duties of the PPWR apply from 12 August 2026 (Art. 71). From that point, manufacturers may only place packaging on the market for which the procedure, the technical documentation and the declaration exist. The declaration and the file must be kept from the date of placing on the market: 5 years for single-use packaging, 10 years for reusable packaging (Art. 15(3)). On a reasoned request from the national authority the documents must be produced within 10 days (Art. 15(10)).