PPWR Declaration of Conformity: Step-by-Step Guide

If you place packaging on the EU market, Regulation (EU) 2025/40 -- the Packaging and Packaging Waste Regulation (PPWR) -- requires you to draw up a Declaration of Conformity (DoC) for every packaging unit or packaging system you put into circulation. This document proves that your packaging meets the sustainability and safety requirements laid down in Articles 5 through 12 of the regulation.

This guide walks you through every section of the PPWR Declaration of Conformity as defined in Annex VIII, in plain language. No legal background needed.

What Is a Declaration of Conformity?

A Declaration of Conformity is a formal, written statement in which the manufacturer (or authorised representative) declares that a specific packaging product complies with the applicable provisions of the PPWR. Think of it as a passport for your packaging: without it, the packaging cannot legally be placed on the EU single market.

The EU Declaration of Conformity for packaging follows the structure set out in Annex VIII of Regulation (EU) 2025/40. It must be kept up to date whenever the regulation or harmonised standards change, and it must be supplied to market surveillance authorities within 10 days of a request.

Who Needs a DoC?

Three categories of economic operators interact with the DoC:

• Manufacturers -- must draw up the DoC and keep it for the retention period.
• Importers -- must obtain a copy from the manufacturer and keep it available.
• Distributors -- must be able to present the DoC (or ensure the manufacturer/importer can) to authorities on request.

If you are an SME importing packaging from outside the EU, you are responsible for verifying that the DoC exists and is accurate before placing the product on the market.

Annex VIII Breakdown: Section by Section

Below is a practical walkthrough of every element the DoC must contain. Use it as a checklist when filling in your own document.

#	Section	What to Fill In
1	DoC number	A unique identifier you assign (e.g., DOC-2026-00142). Use a sequential system you can trace back to your records.
2	Manufacturer identification	Full legal name, registered trade name, and postal address of the manufacturer. If an authorised representative signs instead, include their details too.
3	Packaging identification	A description precise enough to allow traceability: product name, article number or SKU, material type, dimensions, and any relevant images or technical drawings.
4	Conformity statement	A clear sentence: "This declaration of conformity is issued under the sole responsibility of the manufacturer."
5	Object of the declaration	Identify the specific packaging unit, system, or family covered. If one DoC covers a family, define the scope precisely (e.g., "All corrugated cardboard shipping boxes in the XY-300 series, sizes S through XL").
6	Material composition	Declare the materials and substances present, including recycled content percentages. Reference the obligations under Article 7 (recycled content targets) and Article 5 (substance restrictions).
7	Applicable requirements	List the specific PPWR articles the packaging must comply with. At minimum, reference Articles 5--12 as applicable: substance restrictions (Art. 5), recyclability (Art. 6), recycled content (Art. 7), bio-based plastics (Art. 8 if relevant), compostable packaging (Art. 9 if relevant), minimisation (Art. 10), reusable packaging (Art. 11 if relevant), and labelling (Art. 12).
8	Harmonised standards or specifications	Cite the harmonised standards (once published in the OJEU) or common technical specifications you applied to demonstrate conformity. If none are published yet, note that you relied on the regulation text and your own technical assessment.
9	Additional information	Any supplementary data that supports the declaration: third-party test reports, material data sheets, recyclability assessment results, or certification marks.
10	Signature	The declaration must be signed by a natural person authorised to sign on behalf of the manufacturer. Include: name, function/title, place and date of issue.

How to Fill in Each Field -- Practical Tips

1. DoC Number

Pick a numbering convention and stick to it. Many companies use the format DOC-[YEAR]-[SEQUENTIAL]. The number must be unique across all your declarations so that authorities -- and your own team -- can retrieve the document quickly.

2. Manufacturer Identification

Use your official registered name, not a brand name. Include the full postal address. If an authorised representative in the EU acts on your behalf (common for non-EU manufacturers), add a second block with their details and the written mandate reference.

3. Packaging Identification

Be specific. "Cardboard box" is not enough. State the article number, material composition summary, net dimensions, and weight. Attach a photo or technical drawing if it helps identification. The goal is that an inspector can pick up a piece of packaging, look at your DoC, and confirm it is the same item.

4 & 5. Conformity Statement and Object

These sections are mostly boilerplate, but the object description matters. If you produce 200 SKUs of the same material family with identical compliance properties, you can group them under one DoC -- but you must list the scope clearly.

6. Material Composition

Declare every layer and component. For multi-material packaging, list each material by weight percentage. If you claim recycled content under Article 7, state the exact percentage and the source (post-consumer, pre-consumer). Be prepared to back this up with supplier certificates or mass-balance documentation.

7. Applicable Requirements

Not every article applies to every packaging type. A single-use plastic bottle triggers Articles 5, 6, 7, 10, and 12. A reusable wooden crate might trigger Articles 5, 10, 11, and 12. Only cite the articles that are relevant, and for each one, confirm compliance.

8. Harmonised Standards

As of early 2026, the European Commission has not yet published harmonised standards specific to the PPWR. When they are published, reference them by their EN number and date. Until then, document your technical reasoning: what methods you used, what thresholds you applied, and why you consider the packaging compliant.

9. Additional Information

This is where you attach evidence. Common attachments include:

• Recyclability assessment -- laboratory test results or Design for Recycling guidelines compliance
• Recycled content verification -- supplier certificates, mass-balance audit results
• Substance test reports -- heavy metals (Article 5 limits), PFAS absence declarations
• Labelling mock-ups -- showing compliance with Article 12 requirements

10. Signature

A real person must sign. The signatory takes legal responsibility. Typically this is the Quality Manager, Regulatory Affairs Director, or Managing Director. Include their printed name, job title, location, and the date of signature.

Retention and Access

You must keep the DoC and all supporting technical documentation for a minimum of 5 years after single-use packaging is placed on the market, or 10 years for reusable packaging (Article 18).

When a market surveillance authority requests your DoC, you have 10 days to provide it. Failure to produce the document within that window can trigger enforcement actions, including fines or withdrawal of the packaging from the market.

Store DoCs in a system that allows fast retrieval: a document management system, a shared drive with clear naming conventions, or a compliance platform. Paper archives in a basement will not survive a 10-day deadline.

Common Mistakes to Avoid

1. Vague packaging descriptions -- "plastic bottle" tells an inspector nothing. Include SKU, dimensions, material breakdown.
2. Missing recycled content data -- if Article 7 applies, you need verifiable percentages, not estimates.
3. Outdated DoCs -- if you change suppliers or materials, update the DoC immediately. An old DoC for a new material is worse than no DoC at all.
4. No signature -- a DoC without a signature is legally void.
5. Confusing DoC families -- grouping unrelated packaging into one DoC to save effort usually backfires during audits.

Generate Your Declaration of Conformity Automatically

Creating a PPWR Declaration of Conformity manually is time-consuming and error-prone, especially when you manage dozens or hundreds of SKUs across multiple EU markets. Complydex automates the entire process: enter your packaging data once, and the platform generates a compliant DoC based on the Annex VIII template, pre-filled with the correct article references and ready for signature.

Generate your Declaration of Conformity automatically with Complydex