PPWR Declaration of Conformity

The PPWR Declaration of Conformity: What Companies Must Prepare Before August 2026

The Packaging and Packaging Waste Regulation, commonly referred to as PPWR, is set to reshape the way packaging compliance is managed across the European Union. For many businesses, the Regulation represents a major turning point because packaging will no longer be treated as a secondary operational topic. Instead, it becomes a regulated product category with its own conformity requirements, documentation obligations, and legal responsibilities.

From 12 August 2026, companies placing products on the EU market must ensure that packaging complies with the PPWR requirements. The Regulation introduces obligations related to substances of concern, recyclability, reusability, technical documentation, and the creation of the EU Declaration of Conformity, also referred to as the DoC.

For many organisations, this is uncharted territory. Companies that already manage CE marking obligations for electrical devices or machinery may recognise the logic behind the process. However, applying a conformity assessment framework to packaging creates a new layer of complexity because packaging data is typically fragmented across procurement, packaging development, quality management, sustainability teams, converters, raw material suppliers, and brand owners.

In other words, the writing is on the wall. Companies that postpone preparation until the final hour will likely struggle to collect the necessary evidence and organise the required documentation in time.

This article explains what the PPWR Declaration of Conformity is, what it should contain, who is responsible for creating it, who must collect it, and how it maps into the technical documentation required under Annex VII of the Regulation.

Introduction to PPWR Obligations

The PPWR introduces broad obligations affecting the entire packaging lifecycle. The Regulation applies to packaging placed on the EU market and creates requirements that influence packaging design, sourcing, manufacturing, data collection, documentation, and end of life considerations.

One of the most important conceptual changes is that the PPWR treats packaging as a standalone regulated product. This means packaging itself becomes subject to conformity assessment obligations, similar to many other regulated product categories in Europe.

The Regulation establishes obligations linked to:

• substances of concern,
• recyclability,
• reusable packaging systems,
• minimisation requirements,
• labelling,
• recycled content,
• and documentation management.

In practice, companies must collect packaging-related information from multiple actors throughout the value chain and ensure that the data is coherent, complete, and legally defensible. This becomes particularly challenging because packaging data is often scattered across disconnected systems and suppliers.

The Regulation explicitly acknowledges the complexity of value chain collaboration and the need for structured data collection.

As a result, the Declaration of Conformity becomes one of the central outputs of the entire PPWR compliance process.

What Is the PPWR Declaration of Conformity?

The Regulation requires in scope companies to “carry out the conformity assessment procedure and write the EU declaration of conformity.”

The PPWR Declaration of Conformity is the formal legal declaration through which the responsible economic operator confirms that a packaging unit complies with the applicable requirements of the Regulation. In other words, the DoC is the formal confirmation that the conformity assessment procedure has been carried out and that the packaging fulfils the relevant PPWR obligations.

The first obligations linked to the DoC apply from 12 August 2026. In particular, Article 5 concerning substances of concern starts applying from that date, while the first enforcement activities are expected from February 2027.

This means companies should not view 2026 as the beginning of preparation, but rather as the deadline by which internal systems, supplier communication processes, and technical documentation structures must already be functioning.

Once enforcement starts, authorities are unlikely to accept incomplete documentation or improvised declarations. As the saying goes, failing to prepare is preparing to fail.

What Should the Declaration of Conformity Contain?

The content of the DoC is defined in Annex VIII of the PPWR. Although the exact structure may evolve through implementing acts and guidance documents, the Declaration of Conformity is expected to contain the core information necessary to identify the packaging, the responsible economic operator, and the applicable legal requirements.

The DoC should generally include:

• identification of the packaging unit,
• name and address of the manufacturer,
• identification of the authorised representative where applicable,
• description of the packaging and intended use,
• references to the applicable PPWR provisions,
• references to harmonised standards or technical specifications used,
• declaration that the packaging complies with the applicable requirements,
• references to the technical documentation,
• signature of the responsible person.

The DoC, therefore, acts as the formal legal bridge between the packaging placed on the market and the technical evidence demonstrating compliance.

Importantly, the DoC does not replace the technical documentation. Instead, it summarises and formally declares the outcome of the conformity assessment process supported by that documentation.

This distinction is crucial because many companies mistakenly assume that generating the DoC is the primary challenge. In reality, the real challenge lies in building the evidence base required to justify the declaration itself.

Who Must Create the Declaration of Conformity?

Under the PPWR, the manufacturer bears primary responsibility for creating the Declaration of Conformity.

In practice, the manufacturer is the entity placing the packaging on the market under its name or trademark. This applies even when packaging production is outsourced to converters or external packaging suppliers.

The Regulation specifically highlights that manufacturers are legally liable for creating and updating the Declaration of Conformity despite relying on multiple partners throughout the value chain.

This creates a major operational challenge. For example:

• a retailer selling private label products,
• a cosmetics brand outsourcing packaging production,
• a food producer sourcing packaging from several converters,
• or an FMCG company using contract manufacturers,

may all qualify as manufacturers under the Regulation.

The legal responsibility therefore remains with the entity placing the packaging on the market, not necessarily the company physically manufacturing the packaging components.

The Importer Exception: When Importers Become Manufacturers

There is, however, an important exception that deserves particular attention.

Where the non-EU manufacturer is not established within the European Union, the EU importer may effectively become responsible for ensuring compliance obligations are fulfilled.

This means importers may need to ensure:

• the conformity assessment procedure was completed,
• the technical documentation exists,
• the DoC is properly drafted,
• and the required evidence is available upon request from authorities.

For many importers, this represents a significant shift in responsibilities.

Historically, importers often relied on supplier declarations with limited verification. Under the PPWR, that approach may no longer be sufficient. Authorities are increasingly expecting economic operators to demonstrate real oversight and structured governance over compliance documentation.

In plain English, importers cannot simply cross their fingers and hope suppliers have everything under control.

Why Importers Must Prepare Suppliers Early

Many non-EU suppliers are still unfamiliar with the PPWR framework and may not fully understand what the Declaration of Conformity actually requires.

This creates a practical reality that many EU importers will need to actively guide suppliers through the compliance process.

Importers will often need to:

• explain PPWR obligations,
• define required evidence,
• structure the data collection process,
• review documentation quality,
• identify gaps,
• and ensure consistency across suppliers.

This challenge becomes even greater for companies sourcing complex packaging systems composed of multiple materials and components.

For example, a single packaging unit may involve:

• plastic components,
• paper labels,
• inks,
• adhesives,
• coatings,
• barriers,
• recycled content declarations,
• and laboratory test reports.

Gathering all this information from different suppliers can quickly become a logistical headache.

The Role Of The Authorised Representatives

Another critical aspect concerns authorised representatives. Where applicable, the Declaration of Conformity may need to be signed by an authorised representative established in the European Union acting on behalf of the responsible economic operator.

This becomes especially relevant for non-EU manufacturers placing packaging on the European market.

As a result, importers should already begin preparing supplier onboarding processes, communication workflows, and documentation governance models. Waiting until 2026 could leave companies scrambling to close compliance gaps under significant time pressure.

What Must Distributors Do?

The obligations under the PPWR do not stop with manufacturers and importers. Distributors also play an important role within the compliance chain.

Under the PPWR framework, distributors are expected to ensure that compliant packaging documentation accompanies the products they make available on the market. This obligation stems from the distributor obligations defined in the Regulation applicable to economic operators handling packaging and packaged products.

In practical terms, distributors must collect and retain the Declaration of Conformity and cooperate with market surveillance authorities upon request.

This obligation follows the same logic already established in many other EU product regulations. Downstream actors are expected to verify that the required conformity documentation exists before making products available on the market.

As a consequence, distributors will increasingly request:

• the DoC,
• references to technical documentation,
• packaging identifiers,
• and supporting evidence references

from their suppliers before accepting products into their systems.

This means the Declaration of Conformity will gradually become a standard commercial requirement throughout the supply chain.

How the DoC Maps Into the Technical Documentation

One of the most important concepts to understand is the relationship between the Declaration of Conformity and the technical documentation required under Annex VII.

The two documents are inseparable. The technical documentation contains the underlying evidence demonstrating compliance with the Regulation. The Declaration of Conformity formally declares that this evidence exists and supports compliance.

In simple terms:

• the technical documentation proves compliance,
• the DoC declares compliance.

The technical documentation under Annex VII is expected to include information such as:

• packaging specifications,
• design drawings,
• material composition,
• laboratory analyses,
• recyclability assessments,
• evidence concerning substances of concern,
• reusable packaging evaluations,
• supplier declarations,
• conformity assessment procedures,
• and risk analyses.

The Declaration of Conformity then references this documentation and confirms that the packaging complies with the applicable PPWR provisions.

This creates a two way relationship between the documents:

• Without the technical documentation, the DoC has no legal foundation.
• Without the DoC, the technical documentation does not complete the formal conformity process.

This is precisely why companies should avoid treating the Declaration of Conformity as a standalone PDF generated at the end of a project. The DoC is merely the visible tip of the iceberg. Beneath it sits a much larger compliance governance system involving supplier engagement, data collection, evidence management, technical assessments, and documentation control.

Conclusion

The PPWR Declaration of Conformity represents far more than another administrative requirement.

It introduces a new accountability framework for packaging and forces companies to rethink how packaging compliance data is collected, verified, and managed across the value chain.

From 12 August 2026 onwards, companies placing packaging on the EU market must be prepared to demonstrate compliance through structured technical documentation and properly drafted Declarations of Conformity.

Manufacturers remain primarily responsible for the DoC, but importers and distributors also carry important obligations linked to documentation oversight and collection.

The challenge is, therefore, operational.

Companies must coordinate suppliers, organise packaging data, manage evidence, maintain documentation, and ensure consistency across potentially thousands of packaging units.

Those who start early will have the time needed to establish scalable governance processes and avoid last-minute firefighting. Those who delay may quickly discover that PPWR compliance is not something that can be solved overnight.

As the dust settles around the evolving requirements of the Regulation, one thing is already crystal clear: structured documentation and strong value chain collaboration will become indispensable for packaging compliance in Europe.