The EU’s new Packaging and Packaging Waste Regulation (PPWR) will significantly change how packaging compliance works across Europe. One key element of this shift is the Declaration of Conformity (DoC).
Under PPWR, manufacturers placing packaging on the EU market will need to formally declare that their packaging complies with the regulation’s design, sustainability and material requirements. This declaration must be supported by technical documentation that can be provided to regulators on request.
Understanding the Declaration of Conformity now will be essential for preparing for the new regulatory framework. This article outlines the packaging compliance responsibilities for manufacturers, importers and distributors.
What is the Declaration of Conformity?
The Declaration of Conformity (DoC) is a formal legal document stating that packaging placed on the EU market complies with the applicable requirements of PPWR.
It is issued by the manufacturer – the entity responsible for manufacturing the packaging or having it designed or manufactured under their name or trademark.
The declaration confirms that the manufacturer has:
- Assessed the packaging against applicable PPWR requirements
- Verified compliance with relevant technical standards or specifications
- Prepared supporting documentation demonstrating compliance.
The Declaration of Conformity is a standalone document supported by technical documentation, which must be made available to market surveillance authorities upon request.
In practice, the DoC means companies must be able to demonstrate compliance before packaging is placed on the market, rather than only responding to issues after inspection.
What Packaging Requirements Must Be Declared?
When issuing a Declaration of Conformity, manufacturers are confirming that their packaging complies with all relevant PPWR requirements applicable to that packaging type.
Depending on the packaging and its intended use, these may include:
- Substances of concern (Article 5)
- Recyclability requirements (Article 6)
- Minimum recycled content in plastic packaging (Article 7)
- Biobased feedstock in plastic packaging (Article 8, where applicable)
- Compostable packaging requirements (Article 9, where applicable)
- Packaging minimisation (Article 10)
- Reuse requirements (Article 11, where applicable)
- Labelling requirements (Article 12)
The Declaration of Conformity confirms that the packaging meets all applicable provisions under the regulation.
What Should Be Included in the Declaration of Conformity?
Under PPWR, the Declaration of Conformity must follow the format set out in Annex VIII, be kept up to date, and confirm compliance with the relevant regulatory requirements.
It must include:
- A unique identification number for the packaging
- The name and address of the manufacturer and, where relevant, its authorised representative
- A description of the packaging sufficient to allow identification and traceability
- A statement that the declaration is issued under the manufacturer’s sole responsibility
- References to the relevant EU legislation
- References to the harmonised standards, common specifications or technical specifications used to demonstrate conformity
- Where applicable, details of any notified body involved and any certificates issued.
The declaration must be made available in the language required by the Member State where the packaging is placed on, or made available on, the market.
Where other EU legislation also requires a declaration of conformity, a single combined declaration may be used where appropriate.
By issuing and signing the declaration, the manufacturer takes full responsibility for the compliance of the packaging.
What Should Be Included in the Technical Documentation?
While the Declaration of Conformity itself is a relatively short document, it must be supported by comprehensive technical documentation demonstrating compliance.
This documentation may include:
- Packaging design specifications and drawings
- Bills of materials and material composition data
- Supplier declarations and certifications
- Testing results or assessments, such as recyclability evaluations
- Compliance assessments against applicable PPWR requirements
- Evidence supporting packaging minimisation and design claims
This technical file must be sufficiently detailed to demonstrate how compliance has been achieved.
How Should You Structure Your Compliance Evidence?
While PPWR clearly defines what must be included in the Declaration of Conformity and supporting technical documentation, it is less prescriptive about how that evidence should be structured in practice.
This creates a key operational challenge for producers: at what level should compliance be assessed, documented, and maintained?
In practice, most organisations will need to consider three levels:
- Packaging Type Level
PPWR requires a Declaration of Conformity to be created for each “packaging type.”
Where multiple products use the same packaging specification, it may be possible to group them under a shared declaration, provided traceability is maintained. - Component Level
Compliance must reflect the packaging as placed on the market, including all integrated and separate components.
In practice, this often requires component-level data (e.g. cap, bottle, label), particularly for recyclability assessments and material composition. - SKU Level
Many businesses manage compliance evidence at SKU level to ensure traceability.
While not explicitly required for the Declaration itself, this approach can provide greater confidence when responding to regulatory requests or audits.
Our view:
The legal requirement to hold a Declaration of Conformity is already well defined, including its structure under Annex VIII.
The remaining challenge is designing a system that is both proportionate and scalable.
Until market practices mature, producers should adopt a documented approach that:
- groups packaging where appropriate
- retains sufficient component-level detail
- ensures SKU-level traceability where needed
This is essential to meeting the expected burden of proof under market surveillance.
Who Is Responsible for the Declaration?
Responsibility for preparing the Declaration of Conformity sits with the manufacturer.
However, other economic operators also have defined responsibilities:
- Manufacturers – Must ensure packaging is compliant, prepare the Declaration of Conformity, and maintain supporting technical documentation.
- Importers – Must ensure that packaging placed on the EU market is compliant and that a valid Declaration of Conformity and supporting documentation are in place.
- Distributors – Must not make packaging available on the market if they know, or have reason to believe, that it does not comply with PPWR.
The Declaration of Conformity is issued by the manufacturer. Importers and other economic operators must ensure that a valid declaration exists before packaging is placed on the EU market.
This shared responsibility ensures compliance is maintained throughout the supply chain.
When Will the Declaration Be Required?
PPWR is expected to apply from August 2026, with many of the most significant design and performance requirements becoming stricter by 2030.
Businesses placing packaging on the EU market should begin preparing now, as the Declaration of Conformity will become a core requirement for demonstrating compliance under the new framework.
Risk of Non-Compliance
Manufacturers must keep the Declaration of Conformity and supporting technical documentation available for inspection by national authorities for a defined period after the packaging has been placed on the market, in line with EU product compliance frameworks.
This retention period is specified as:
- five years for single-use packaging
- ten years for reusable packaging.
This is calculated from the date the packaging is first placed on the market.
If a business cannot provide the declaration when requested, or if the supporting documentation does not adequately demonstrate compliance, it may face enforcement action and potential market restrictions.
Authorities are expected to carry out risk-based market surveillance, which may include reviewing Declarations of Conformity and technical documentation. Where packaging is found to be non-compliant, action may be taken, including requiring products to be withdrawn from the market.
Building a Practical Compliance Strategy
Preparing a Declaration of Conformity is not just a documentation exercise, it requires a structured approach to packaging data, supplier information, and compliance evidence.
Clarity helps producers design and implement a practical conformity strategy that balances:
- Legal defensibility.
- Operational efficiency.
- Audit readiness.
We support with:
- Structuring packaging types and grouping logic.
- Identifying where component-level data is required.
- Building SKU-level traceability where needed.
- Engaging suppliers to collect missing documentation.
If you’re unsure whether your current data and documentation would stand up to regulatory scrutiny, we can help you assess your position and define a clear route to compliance.
Get in touch with our PPWR specialists to start preparing.
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