Who Signs the PPWR Declaration of Conformity: Manufacturer, Importer, Distributor, or You?
Who signs the PPWR Declaration of Conformity: how the manufacturer role really works, what importers and distributors verify, and when a seller is liable.
Who Signs the PPWR Declaration of Conformity: Manufacturer, Importer, Distributor, or You?
Five roles, one signature. Regulation (EU) 2025/40 recognises manufacturers, importers, distributors, fulfilment service providers and authorised representatives as economic operators. Exactly one of those roles draws up and signs the EU Declaration of Conformity: the manufacturer, under Article 39, following the model in Annex VIII. From 12 August 2026, every packaging type placed on the EU market needs that document behind it.
Simple, on paper. In practice "manufacturer" does not mean what most supply chains think it means. The company running the corrugator is often not the manufacturer. The brand that has never touched a converting line often is.
The DoC also has a strange sociological status. Several parties in the chain must be able to produce it for a market surveillance authority within 10 days of a request, and each of them quietly assumes someone else is writing it. The converter thinks the brand handles it. The brand thinks it comes with the boxes. The importer assumes it exists somewhere upstream. Article 39 assumes nothing. Someone signs. This post is about working out whether that someone is you.
The brand-on-the-box rule
The PPWR defines the manufacturer by name and trademark, not by machinery. Under the definitions in Article 3, a manufacturer is anyone who manufactures packaging, or has packaging designed or manufactured, and markets it under their own name or trademark.
Read that second clause again. You commission a converter in Poland or Shenzhen to produce a mailer box. Your logo goes on it. Under the PPWR, you are the manufacturer of that packaging. The converter made the box. You made the promise.
And the promise is substantial. Article 15 requires the manufacturer, before placing packaging on the market, to:
- Carry out the conformity assessment procedure and prepare the technical documentation
- Draw up the EU Declaration of Conformity under Article 39
- Keep the DoC and technical documentation for 5 years after a single-use packaging unit is placed on the market, 10 years for reusable packaging
- Apply the labelling required by the regulation
- Hand documentation to a market surveillance authority within 10 days of a request
None of this transfers by contract. You can pay the converter to run the tests and draft the file. The signature obligation stays with the entity whose name is on the box.
The importer: verify before you place
An importer is established in the EU and places packaging from a third country on the EU market. The importer does not sign the DoC. The importer's job under Article 18 is colder: verification before placement.
Before an importer may place packaging on the market, they must check that:
- The manufacturer carried out the conformity assessment and prepared the technical documentation
- The manufacturer drew up the EU Declaration of Conformity
- The packaging bears the required labelling
- Their own name, registered trade name or trademark, and postal address appear on the packaging or its accompanying documents
Importers keep a copy of the DoC at the disposal of authorities for the same 5-year or 10-year window, must not place packaging they have reason to believe is non-conforming, and get the same 10-day clock on documentation requests.
Note what "verify the DoC exists" means when the third-country manufacturer never wrote one. It means the goods do not get placed on the market. The verification duty is a quiet forcing device: either your supplier produces the file, or you produce it under mandate, or the containers stay expensive decorations. If you sell into the EU from outside it, the mechanics are covered in our guide for non-EU sellers shipping to Europe.
The distributor: verify before you resell
A distributor makes packaging available on the market without importing it or branding it. Duty level: lighter, not zero. Under Article 19, before making packaging available, a distributor verifies that:
- The packaging bears the required labelling
- The manufacturer and, where relevant, the importer have met their identification requirements
- The producer is registered in the relevant national EPR register
Distributors must also keep storage and transport conditions from jeopardising compliance, must not sell packaging they believe is non-conforming, and must inform the manufacturer, the importer and the authorities when packaging presents a risk. A wholesaler who has never heard of the PPWR is, from August 2026, a compliance checkpoint. Nobody has told most wholesalers this.
The fulfilment service provider
Article 20 covers warehouses that pack and ship for others. Their obligation is narrow: warehousing, handling, packing, addressing and dispatching must not jeopardise the packaging's compliance with Articles 5 to 12.
The narrowness matters. Using a fulfilment provider, including FBA, does not move any obligation off your desk. Amazon handles the shelf and the label printer. You remain the operator responsible for registration, fees, and the DoC.
The authorised representative
A non-EU manufacturer can appoint an authorised representative by written mandate under Article 17. The AR keeps the DoC and technical documentation at the disposal of authorities and cooperates with them on request. What the AR cannot do is absorb responsibility: the compliance of the packaging remains the manufacturer's problem at all times. Think of the AR as a legally required forwarding address with filing duties. Details in our authorised representative guide.
Article 21: the three ways a seller becomes the manufacturer
Article 21 is where e-commerce sellers get caught. An importer or distributor is treated as the manufacturer, with the full Article 15 duty set, when they either place packaging on the market under their own name or trademark, or modify packaging already placed on the market in a way that could affect its compliance.
Three trip wires, in ascending order of surprise:
1. Private label. You buy generic product in generic packaging, apply your brand, sell it. You are now the manufacturer of that packaging. This is the single most common way a "reseller" acquires a signature obligation without noticing.
2. Direct import. Buying directly from a factory in a third country makes you the importer, with the Article 18 verification duties. Combine it with your own branding and Article 21 upgrades you to manufacturer. Most D2C brands sourcing from Asia hit both wires at once.
3. Modification. Repacking bulk goods into your own boxes, bundling products into a new branded outer, relabelling in a way that affects compliance: each of these can make you the manufacturer of the packaging you created or altered. The original manufacturer's DoC covers their packaging, not your remix of it.
The decision table
| If you... | You are | Your PPWR duties |
|---|---|---|
| Make packaging, or have it made, and sell under your own name or trademark | Manufacturer (Art 15) | Conformity assessment, technical documentation, draw up and sign the DoC, keep it 5 or 10 years, labelling, 10-day response |
| Put your brand on packaging a converter produced for you | Manufacturer (Art 15) | Same as above; the converter's role is contractual, not regulatory |
| Are established in the EU and bring packaged goods in from a third country | Importer (Art 18) | Verify assessment done and DoC drawn up, check labelling, add your name and address, keep a DoC copy, refuse non-conforming stock |
| Resell within the EU without branding or altering anything | Distributor (Art 19) | Verify labelling and operator identification, verify EPR registration, protect compliance in storage and transport |
| Warehouse, pack, address and dispatch for other operators | Fulfilment service provider (Art 20) | Keep handling from jeopardising compliance with Articles 5 to 12 |
| Import or resell under your own brand | Manufacturer (Art 21) | The full Article 15 set, including the signature |
| Modify packaging already on the market in a way that could affect compliance | Manufacturer (Art 21) | Same |
Two rows can apply at once. A D2C brand importing own-branded goods is importer and manufacturer simultaneously and owes both duty sets. The regulation does not care what your invoice says your role is.
Find your row, then do the work
The chain logic of the PPWR is deliberate: at least three parties must each confirm the DoC exists before packaging reaches a consumer, which is precisely why "someone else is handling it" fails as a strategy. From 12 August 2026, the first missing link stops the chain.
Work out your row in the table. If it says manufacturer, you need a Declaration of Conformity per packaging type, drawn to the Annex VIII model, before the deadline. The format and content are covered in our Declaration of Conformity guide.
Or skip the format study: answer a few questions about your company and packaging and Complydex determines your role in the chain and generates the DoC that goes with it.