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The EU Packaging and Packaging Waste Regulation (PPWR) 2025/40 requires that companies defined as manufacturers must issue a Declaration of Conformity (DoC).
This guide explains how to create a PPWR DoC based on the model structure in Annex VIII.
- The manufacturer must create the PPWR DoC
- A DoC is required for each packaging type
- Importers must request the DoC from the manufacturer
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EU PPWR DoC Example
Note: The DoC sample above only contains sample data. Rather than replicating this sample, you must base your PPWR DoC on Annex VIII and the latest version of the PPWR in its entirety.
Required Information
The table below breaks down the information required in a PPWR DoC, based on Annex VIII.
| PPWR DoC Item | Example / Guidelines |
| EU declaration of conformity No (*1) … | This is the title and number of the DoC |
| 1. No … (unique identification of the packaging): | This section can include the following information:
|
| 2. Name and address of the manufacturer and, where applicable, the manufacturer’s authorised representative: | a. Manufacturer company name
b. Manufacturer address |
| 3. This declaration of conformity is issued under the sole responsibility of the manufacturer. | This is a statement |
| 4. Object of the declaration (identification of the packaging allowing traceability): description of the packaging: | Provide additional information that can identify the packaging, which can include images |
| 5. The object of the declaration referred to point 4 is in conformity with the relevant Union harmonisation legislation: … (reference to the other Union acts applied). | a. List applicable EU regulations and directives
b. This includes the EU PPWR but packaged products can also be subject to other EU regulations and directives |
| 6. References to the relevant harmonised standards or the common specifications used or references to the other technical specifications in relation to which conformity is declared: | a. The PPWR set requirements that impact the design and functionality of packaging. These requirements can be met by ensuring compliance with harmonised standards.
b. Harmonised standards must be listed in this section. |
| 7. Where applicable, the notified body … (name, address, number) … performed … (description of intervention) … and issued the certificate(s): … (details, including the date of the certificate(s), and, where appropriate, information on the duration and conditions of validity). | Specify notified body information (when applicable) |
| 8. Additional information:
Signed for and on behalf of: (place and date of issue): (name, function) (signature): |
FAQ
Who is responsible for creating the PPWR DoC?
The PPWR Declaration of Conformity must be created by the manufacturer. The definition of a manufacturer can be found in Article 3 and includes the following:
a. Companies that manufacture packaging or a packaged product
b. Companies that have packaging or a packaged product manufactured under their own brand name
As such, a company that orders products based on its design and branding from external factories can be considered the manufacturer and is therefore required to create the DoC. This is the case even if the company does not operate its own production facilities.
Note that exemptions apply to companies defined as micro-enterprises.
Do we need one PPWR DoC for each packaging design?
Our understanding is that you need one PPWR Declaration of Conformity for each packaging type.
1. This is written in ANNEX VII:
The manufacturer shall draw up a written declaration of conformity for each packaging type and keep it together with the technical documentation at the disposal of the national authorities for 5 years after single-use packaging has been placed on the market, and 10 years after reusable packaging has been placed on the market. The declaration of conformity shall identify the packaging for which it has been drawn up.
2. The term “packaging type” is clarified here:
The packaging type should be understood as referring to the predominant polymer the packaging is made of, while packaging format should be understood as referring to the size and shape of a specific packaging unit.
Based on this, packaging type refers to the “predominant material the packaging is made of”.
Do we need separate DoCs for the product and the packaging?
CE marking regulations and directives require the creation of a DoC for products. Now, the PPWR requires a DoC also for the packaging.
The question is then whether you should add a separate PPWR DoC only for the packaging, or if you need to add the Annex VIII information into existing “product DoCs”. Fortunately, this is addressed by the PPWR legislation text:
To ensure access to information for market surveillance purposes, a single EU declaration of conformity should be drawn up in respect of all relevant Union legal acts. To reduce the administrative burden on economic operators, it should be possible for that single EU declaration of conformity to comprise a dossier of relevant individual declarations of conformity.
Here, the PPWR states the following:
a. You need a single Declaration of Conformity that covers all applicable EU regulations and directives
b. A single DoC can be made up of several individual declarations of conformity
If you are, for example, selling sunglasses, then the DoC dossier may look like this:
- PPE Regulation Declaration of Conformity
- PPWR Declaration of Conformity
Can importers create a PPWR DoC?
No, importers should not create a PPWR DoC. That being said, importers are required to:
a. Request the PPWR DoC from the company defined as the manufacturer
b. Check that it contains the required information
c. Review supporting documentation, including test reports
In short, importers do not create the DoC but must ensure that the manufacturer has done so correctly.
Do we need a PPWR DoC for product packaging?
Yes, product packaging is subject to the EU PPWR and the DoC requirement applies to packaging in general.
Do we need a PPWR DoC for transportation packaging?
We cannot find any exemption for transportation packaging. Our understanding is therefore that you need a DoC for transport packaging as well.
How long do we need to store a PPWR DoC?
The Declaration of Conformity must be kept for 5 to 10 years:
- Single-use packaging: 5 years
- Reusable packaging: 10 years
Notice that this likely refers to the last time a product was placed on the market, not the initial date. If you, for example, introduce a packaging type in 2027, then you need to keep the PPWR DoC until 2032 or 2037.
