The PPWR declaration of conformity is not a formality to be completed at the end of the process. It is the document through which the responsible party declares that the packaging complies with the applicable requirements of the regulation.
For this reason, it should not be treated as a standard form to be signed on the basis of a generic supplier declaration. Before signature, at least three points must be clear: which packaging is covered, which evidence is available and whether the technical file is consistent with the packaging actually placed on the market.
The PPWR declaration concerns the packaging, not the product
The PPWR declaration of conformity is separate from the EU declaration of conformity for the CE-marked product.
A product may have its own CE declaration for the applicable legislation, for example LVD, EMC, RoHS or other product regulations. The packaging containing that product follows a separate documentation path under the PPWR.
The packaging declaration is required by Annex VIII of Regulation (EU) 2025/40. Its object is not the product inside the packaging, but the packaging itself: materials, components, applicable requirements, technical documentation and conformity assessment of the packaging.
This distinction matters because it avoids a frequent misunderstanding: attaching the product DoC does not mean also having the PPWR declaration for the packaging.
From 12 August 2026, documentation carries more weight
From 12 August 2026, the general obligations of the regulation become operational also from a documentation standpoint. The PPWR declaration of conformity therefore takes on a practical role: making responsibility for the packaging traceable and linking it to the available technical documentation.
At this stage, the declaration should rely especially on:
- correct identification of the packaging;
- the packaging technical file;
- data and statements received from suppliers;
- PPWR requirements already applicable from 2026;
- elements to be kept on the roadmap for later deadlines.
The point is not to anticipate all future requirements without distinction, but to avoid signing the declaration without a proportionate and verifiable documentation basis.
Whoever signs assumes responsibility
The PPWR declaration is issued under the responsibility of the manufacturer of the packaging. In the context of sales packaging, the manufacturer is not always the party that physically produces the packaging: it may also be the filler or the party placing the packaging on the market under its own name or trademark.
A pure importer, on the other hand, should not automatically be treated as the signatory of the declaration. Its role is different: checking that the documentation exists and that the relevant obligations have been addressed. However, if an importer or distributor places its own name or trademark on the packaging, it may assume the role of manufacturer under the regulation.
Signature, therefore, is not a neutral administrative step. It is the point at which scope, supplier data and technical file must be sufficiently consistent.
Why the technical file comes first
The PPWR declaration of conformity should come after the technical file, not before.
The technical file collects and organises the evidence. The declaration uses that documentation basis to attest conformity of the packaging with the applicable requirements. If the file is incomplete, misaligned or linked to outdated packaging versions, the declaration may also rest on a weak basis.
For this reason, two levels should remain separate:
- the PPWR technical file, which documents and supports the assessment;
- the PPWR declaration, which formalises the assumption of responsibility.
Suppliers remain decisive
Much of the data needed to prepare a reliable declaration is not produced internally by the company marketing the product. It comes from packaging suppliers, material producers, converters or other parties in the supply chain.
The information may concern composition, materials, weights, components, treatments, coatings, adhesives, inks, substances and available tests. For food-contact packaging, oversight of PFAS requires particular attention.
However, the supplier declaration does not automatically replace the PPWR declaration of the responsible company. The information received must be read, linked to the actual packaging and assessed against the scope of the declaration.
One declaration or several declarations?
The declaration may cover several formats or dimensions of the same type of packaging, provided that the differences do not affect conformity with the applicable requirements.
The practical point is not to multiply unnecessary documents, but to avoid overly generic declarations. A declaration covering several packaging versions must make it possible to understand which versions are included and why they can be treated together.
When materials, relevant dimensions, suppliers, treatments or technical specifications change, the scope of the declaration must be reassessed.
Keeping the declaration available
The declaration of conformity and the technical documentation must be kept for 5 years for single-use packaging and 10 years for reusable packaging, under Regulation (EU) 2025/40, Article 15.
The documentation must also be available in the event of a request from the competent authorities. This reinforces an essential point: the declaration does not stand alone, but must remain linked to an ordered and updated documentation archive.
When a structured path is needed
The PPWR declaration becomes delicate when there are many packaging items, several suppliers and technical data arrive in non-uniform formats.
In these cases, signing a model before clarifying the scope may create a documentation risk. A structured path helps distinguish priority packaging, understand which information is already available and check whether the technical file is sufficient to support the declaration.
This does not mean guaranteeing final compliance regardless of the data available. It means setting up a coherent documentation basis before the declaration becomes a formal act.
Frequently asked questions
What is the PPWR declaration of conformity?
It is the declaration required by Annex VIII of Regulation (EU) 2025/40 through which the responsible party attests conformity of the packaging with the applicable PPWR requirements.
Does the PPWR declaration replace the CE declaration for the product?
No. The PPWR declaration concerns the packaging. The CE declaration for the product, where required, concerns the product and remains a separate document.
Is a supplier declaration enough to sign the PPWR declaration?
No. Supplier declarations may be useful evidence, but they do not replace the technical file or the assessment by the responsible party.
Is the PPWR declaration already needed from 12 August 2026?
Yes. From 12 August 2026, the general obligations of the regulation become operational, including conformity assessment of packaging and the related documentation.
Can the PPWR declaration cover several packaging items?
Yes, if they are formats or dimensions of the same type of packaging and if the variations do not affect conformity with the applicable requirements. The scope must still be clear.
Need to set up a PPWR declaration?
The PPWR declaration requires a coherent documentation basis before signature.