PPWR Declaration of Conformity: A Filled-In Example, Field by Field

One blank field kills the document. Under Regulation (EU) 2025/40, a declaration of conformity missing any of its ten mandatory elements is invalid, and packaging without a valid declaration cannot legally sit on the EU market from 12 August 2026. Annex VIII lists the ten elements and offers no opinion on how to fill in any of them. So here is one, filled in.

The example: Kartonwerk Rheinland GmbH, a fictional corrugated board plant in Cologne. Its product is a single-wall corrugated e-commerce shipping box, FEFCO style 0427, article KR-427-M, 300 x 200 x 100 mm. Sold by the pallet to online retailers. Ordinary packaging, ordinary company, and exactly the kind of product that needs a signed DoC eleven months from now.

Two legal anchors before the form. Article 39 puts the declaration under the sole responsibility of the manufacturer: not the supplier, not the trade association, not the consultant who drafted it. And the conformity assessment behind it is Module A, internal production control, set out in Annex VII. No notified body. No mandatory third-party lab. You assess, you document, you sign. Cheap, and therefore entirely on you.

Download the filled-in sample as PDF

The ten fields, completed

#	Annex VIII element	Kartonwerk Rheinland's entry
1	DoC number (unique identification)	DOC-2026-0117, version 1.0
2	Name and address of the manufacturer	Kartonwerk Rheinland GmbH, Beispielstrasse 12, 50667 Cologne, Germany
3	Sole responsibility statement	"This declaration of conformity is issued under the sole responsibility of the manufacturer."
4	Object of the declaration (identification allowing traceability)	Single-wall corrugated board e-commerce shipping box, FEFCO 0427, article KR-427-M, 300 x 200 x 100 mm, single-use transport packaging, not intended for direct food contact. Technical drawing ref. TD-427-M rev. 2.
5	Conformity statement	"The object of the declaration described above is in conformity with Regulation (EU) 2025/40, in particular Articles 5, 6, 10 and 12, insofar as they apply to the packaging concerned."
6	Harmonised standards or common specifications used	None published in the OJEU at the date of issue. Conformity assessed against the regulation text using internal procedure QP-11 (recyclability and substance assessment).
7	Notified body (where applicable)	Not applicable. Conformity assessment procedure: Module A, internal production control, Annex VII.
8	Additional information	Supplier declarations for heavy metals (ref. SD-2026-031 to SD-2026-034), fibre composition data sheet, technical documentation file TF-427.
9	Signed for and on behalf of	Kartonwerk Rheinland GmbH, Cologne, 17 July 2026
10	Name, function, signature	Anna Beispiel, Head of Quality, (signature)

Ten fields. Maybe forty minutes of work, once the technical file behind them exists. The technical file is the actual work.

What each field wants from you

Field 1, the number. Any scheme works: DOC-2026-0117 is a fine number, and so is anything else you can still locate in three years. The number ties the declaration to your records, so make it sequential and never reuse it. New material, new supplier, new version number.

Field 2, the manufacturer. Registered legal name and postal address. Not the brand, not the webshop. A non-EU manufacturer using an authorised representative adds the representative's name and address in the same field.

Field 3, the statement. Copy the sentence exactly: "This declaration of conformity is issued under the sole responsibility of the manufacturer." This is not a writing exercise. Reformulated versions ("we believe our packaging broadly complies") are the compliance equivalent of crossing out a contract clause and initialing it.

Field 4, the object. Precise enough that an inspector holding the box can match it to the paper. Article number, material, dimensions, format, intended use. "Cardboard box" identifies roughly 40 billion products. One DoC can cover a family of packaging, but then the family needs defined boundaries: same material specification, same compliance profile, listed sizes.

Field 5, the conformity statement. Name the regulation and the articles that apply. For the corrugated box: Article 5 (substances of concern), Article 6 (recyclability), Article 10 (packaging minimisation), Article 12 (labelling). Articles 7 and 8 target plastic and bio-based plastic, Article 9 targets compostable packaging, Article 11 targets reusable packaging. None of them touch a single-use fibre box.

Field 6, the standards. As of mid-2026 no PPWR harmonised standards have been published in the OJEU. Until they exist, you state what you assessed against: the regulation text plus your documented internal method. When standards land, cite them by EN number and update the declaration.

Field 7, the notified body. Field 7 exists mostly so you can write "not applicable" in it. Module A involves no notified body. Write "not applicable" anyway: to a market surveillance officer, an empty field and a missing element look identical, and only one of them is harmless.

Fields 8 through 10. Evidence references, then place, date, and a named human with a function who signs. A DoC signed by nobody binds nobody, which authorities notice.

Which articles to cite, by packaging type

Packaging type	Cite	Typically not applicable
Corrugated e-commerce box (single-use, fibre)	Art. 5, 6, 10, 12	Art. 7, 8, 9, 11
Plastic mailer bag (single-use)	Art. 5, 6, 7, 10, 12	Art. 8, 9, 11
Food-contact plastic tray	Art. 5 (incl. PFAS limits), 6, 7, 10, 12	Art. 8, 9, 11
Reusable transport crate	Art. 5, 6, 10, 11, 12	Art. 7 (unless plastic), 8, 9
Compostable tea bag or capsule	Art. 5, 6, 9, 10, 12	Art. 7, 8, 11

The Article 5 numbers worth knowing by heart: lead, cadmium, mercury and hexavalent chromium, combined, at most 100 mg/kg in packaging or packaging components. For food-contact packaging the PFAS thresholds bite: 25 ppb for any single targeted PFAS, 250 ppb for the sum of targeted PFAS, 50 ppm for total organic fluorine. Kartonwerk's box is not food-contact, so its technical file records why the PFAS limits do not apply, with the reasoning written down rather than assumed.

Recycled fibre deserves a sentence of paranoia. Heavy metals enter corrugated board through recycled input, not through malice, so the 100 mg/kg ceiling is demonstrated with supplier declarations or test data per input source. That paperwork lives in the Annex VII file and gets a reference in field 8.

Mistakes that make a DoC invalid

• A missing element. Any of the ten. The regulation treats the packaging as non-conform, full stop.
• Paraphrased sole-responsibility wording. Use the sentence from Annex VIII, not your improved version.
• An object description that fits everything. "All our boxes" is not identification allowing traceability.
• Citing every article defensively. Declaring conformity with Article 9 for a non-compostable box is a false statement in a legal document, which is worse than an omission.
• No signature, or a signature with no name and function. Legally void.
• A stale declaration. New supplier, new coating, new recycled content: the old DoC now describes packaging you no longer make.

Keep it, and for how long

The declaration and the Annex VII technical documentation stay available to market surveillance authorities: 5 years for single-use packaging, 10 years for reusable packaging, counted from placing on the market. Full retention and access rules are in our step-by-step DoC guide.

The template, and the shortcut

Download the filled-in sample as PDF. Swap Kartonwerk's details for yours, adjust the article list to your packaging type using the table above, and have someone with authority sign it.

Or skip the manual assembly. Complydex generates Annex VIII declarations from your packaging data, with the correct article references per packaging type, versioning included. For the wider August deadline picture, see the PPWR compliance checklist for e-commerce and what happens when documents are missing in PPWR penalties and fines.

Generate your declaration of conformity with Complydex