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PPWR Declaration of Conformity: required fields, template and the Annex VII technical documentation

Since 12 August 2026 no packaging may be placed on the EU market without an EU declaration of conformity under Article 39 and Annex VIII of the PPWR. What belongs in it, what the Annex VII technical documentation must contain and who signs it.

Author: myDPP Team

PPWR Declaration of Conformity: required fields, template and the Annex VII technical documentation

On 12 August 2026 the legal character of packaging changed. It is no longer merely a wrapper and an object of waste fees, but a product with its own conformity file — a conformity assessment, technical documentation and a written declaration signed by a named person. Anyone placing packaging on the EU market must be able to demonstrate, on request from market surveillance, that it meets the applicable requirements of Articles 5 to 12 of Regulation (EU) 2025/40. Without that evidence, placing it on the market is not lawful.

This is where the most common misreading begins. Many companies read the PPWR as a materials topic — recycled content, recyclability, PFAS — and understood the documentation duty as something that only matters once the material quotas arrive in 2030. It does not work that way. The declaration duty applies now, even though individual substantive requirements land later. This article explains what belongs in the declaration, what the Annex VII technical documentation must contain, who prepares it — and where packaging data converges with the digital product passport.

Key takeaways

  • Two articles and two annexes carry the obligation. Article 38 governs the conformity assessment procedure and points to the technical documentation in Annex VII; Article 39 governs the EU declaration of conformity, whose model sits in Annex VIII.
  • It is a self-declaration, not a certification. The PPWR uses internal production control. In the standard case no notified body is involved and no test house issues a certificate — responsibility rests entirely with the manufacturer of the packaging.
  • The declaration must identify specific packaging. A blanket statement covering an entire range does not satisfy the requirement. Variants can be grouped only while material and construction stay identical.
  • Retention: at least five years for single-use packaging, ten years for reusable packaging from placing on the market — for the declaration and the technical documentation alike.
  • Two roles are easily confused. The entity that manufactures the packaging, or has it made under its own name or trademark, owns conformity, documentation and the declaration. The entity liable under extended producer responsibility — registration, scheme participation, reporting — may be a different company entirely.
  • Not every requirement in Articles 5 to 12 applies today. The substance restrictions in Article 5 and the minimisation assessment in Article 10 apply since 12 August 2026; recyclability performance grades and recycled-content quotas arrive from 2030. The declaration covers whatever is applicable at the moment of placing on the market.
  • Filling usually makes you the responsible party. A company that buys empty stock packaging, fills it and sells under its own brand cannot fall back on the supplier’s declaration.
  • myDPP does not issue declarations of conformity. It manages the product and packaging data — materials, weights, recycled content, test reports, versions — from which declarations, reports and product passports are generated.

What the PPWR declaration is — and what it is not

The EU declaration of conformity is a written, legally binding statement by the manufacturer that a specific packaging item meets the applicable PPWR requirements. It is the tip of a pyramid: below it sits the technical documentation, and below that the test reports, material data sheets and supplier evidence. The single sheet of paper — or single PDF — is worthless if the layers underneath are missing.

Three misunderstandings have followed the document since August 2026.

First, it is not a certificate. No body grants, approves or countersigns a PPWR declaration of conformity. Providers selling “PPWR certification” are selling consultancy and laboratory analysis at best — you issue the document yourself, and you carry the liability.

Second, it does not replace registration and licensing duties. The declaration concerns the properties of the packaging. Whether you are entered in a national producer register such as LUCID and participating in a compliance scheme is an entirely separate question with its own legal basis. Both must be satisfied.

Third, it is not consumer information. The declaration is addressed to market surveillance authorities and, in part, to business customers who need to prove their own conformity. It is not meant to sit on the pack or behind the QR code — even though the same data will be needed there later.

If you are looking for the generic framework for declarations of conformity across EU product law, our article on the EU declaration of conformity with template and mandatory fields covers it. The PPWR follows the same logic but has its own annex, its own retention periods and its own audience.

Manufacturer or producer? The term the duty hangs on

The PPWR uses two terms that everyday language treats as synonyms but the regulation keeps apart. Getting them the wrong way round has been the single biggest source of error in the first months, and the German language version — where they became Erzeuger and Hersteller — made it worse.

The manufacturer of the packaging is whoever makes it, or has it designed or made under its own name or trademark. This term carries the conformity assessment under Article 38, the technical documentation under Annex VII, the declaration under Article 39, and the marking with name, trademark and address.

The producer in the extended producer responsibility sense is whoever first places packaged goods on the market of a member state. This term carries registration, scheme participation, quantity reporting and the financing of waste management — the subject of our article on extended producer responsibility for packaging.

In practice four constellations recur:

  • The packaging converter produces folding cartons and sells them to brand owners. It is the manufacturer of the empty packaging and issues a declaration for it.
  • The own-brand filler buys stock packaging, fills and seals it and sells under its own name. That normally makes it the manufacturer of the sales packaging — the supplier’s declaration does not automatically cover its configuration.
  • The importer of unchanged branded goods usually does not become the manufacturer, but must verify that the declaration and marking exist, and may become the producer for EPR purposes.
  • The private-label retailer is regularly the manufacturer, regardless of who actually produces and where.

The regulation contains a carve-out for micro-enterprises: where a micro-enterprise has packaging made under its own name or trademark and the supplier is located in the Union, the supplier is deemed to be the manufacturer (Art. 3(13)(b), Art. 15(12), Art. 21 second subparagraph). If the supplier sits in a third country, the rule does not apply. EPR duties are unaffected — these are two separate regimes. The roles in both chains are set out in detail in PPWR obligations of manufacturer, importer and distributor.

The route to a declaration: conformity assessment under Article 38

Before a declaration may be issued, the conformity assessment must have been completed. The PPWR uses internal production control — the module known elsewhere in product law as Module A, described in context in our article on conformity assessment procedures and modules.

Internal production control means three things. The manufacturer assesses conformity itself. It documents that assessment so a third party can follow it. And it ensures that ongoing production matches the assessed state — not just the first sample.

That last point is routinely underestimated. A declaration resting on a 2025 laboratory report for a formulation the supplier changed in 2026 has become factually wrong without anyone having signed anything false. So the procedure needs triggers: material change, supplier change, tooling change, formulation change and changes in the law must all force a fresh assessment.

A notified body is not involved in the standard case. In packaging, the notified body field in the declaration is usually left empty or marked “not applicable”. Entering a number there out of CE habit creates an untrue statement.

What the Annex VII technical documentation must contain

The technical documentation is the part that takes work. It is not a file you compile once, but the data foundation from which the declaration draws its meaning. Annex VII requires at minimum:

  • A general description of the packaging and its intended use — which product, which function, sales, grouped or transport packaging.
  • Design drawings, manufacturing drawings and component plans showing the construction: layers, composites, closures, labels, adhesives, inks.
  • The material composition of all components, including weight per material. Without that breakdown, no recycled-content share and no recyclability grade can be calculated later.
  • A list of the harmonised standards or technical specifications applied — with reference and year of issue.
  • The recyclability, minimisation and, for reusable packaging, reusability assessments under Articles 6, 10 and 11.
  • The recycled-content calculation under Article 7 once the quotas apply, with supply-chain evidence.
  • Test reports and evidence on substances of concern under Article 5 — heavy metals in particular, and PFAS where there is food contact.

Two properties separate a file that holds from one that collapses at the first question. It must be traceable: every figure needs a source, every source a date. And it must be versioned: if an authority asks in 2028 which formulation applied in 2026, the state at that time has to be reconstructible — not only today’s.

A file built from shared folders full of supplier PDFs will not achieve this. The reason is the same one that keeps DPP data out of spreadsheets: there is no structure from which calculations and evidence can be derived reproducibly. Our article on DPP and PIM sets out that connection in more detail.

The content of the declaration under Annex VIII

Annex VIII sets the model. In substance it is ten blocks, all of which must be present:

  1. A unique identification number for the declaration. It must identify the declaration unambiguously and should tie into your own article or document numbering so it can still be matched years later.
  2. Name and address of the manufacturer, and of the authorised representative where one is appointed. A PO box will not do; the address must be one where the company can actually be reached.
  3. The statement that the declaration is issued under the sole responsibility of the manufacturer. This is not boilerplate — it is precisely why no test house countersigns.
  4. Unique identification of the packaging allowing traceability: type, article number, batch or serial number where applicable.
  5. A description of the object of the declaration with materials and relevant characteristics — specific enough that a third party can recognise the packaging concerned.
  6. The conformity statement with an explicit reference to Regulation (EU) 2025/40 and the relevant requirements of Articles 5 to 12.
  7. References to the harmonised standards or technical specifications applied, each with year of issue.
  8. Notified body details where one was involved — for packaging, normally not.
  9. Additional information where needed for understanding, such as notes on variants or limits of application.
  10. Place, date and signature with the name and function of the signatory.

Block four matters most. A declaration describing “our cardboard packaging” or “all packaging in the 2026 range” cannot be checked against anything and is therefore unusable. The declaration has to be attributable to specific packaging.

Template: the structure of a PPWR declaration of conformity

There is no official form to download and fill in — Annex VIII prescribes a structure, not a document. The shape looks like this:

EU DECLARATION OF CONFORMITY
under Article 39 and Annex VIII of Regulation (EU) 2025/40 (PPWR)

1. Declaration number:  PPWR-2026-0147

2. Manufacturer:        Example Packaging Ltd
                        1 Example Street, 12345 Exampletown, Germany

3. This declaration is issued under the sole responsibility
   of the manufacturer.

4. Object of the declaration:
                        Folding carton FC-220-A
                        Article number 4711-220
                        Batch/serial: see marking on the packaging

5. Description:         Sales packaging, carton board 220 g/m2,
                        printed one side, no plastic coating,
                        total weight 34 g, water-based adhesive

6. The object of the declaration described above is in conformity
   with the relevant requirements of Articles 5 to 12 of
   Regulation (EU) 2025/40.

7. Harmonised standards and specifications applied:
                        <reference with year of issue>

8. Notified body:       not applicable
                        (procedure: internal production control, Annex VII)

9. Additional information: Applies to size variants 220-A and 220-B
                        with identical material composition.

10. Signed for and on behalf of: Example Packaging Ltd
    Place, date:        Exampletown, 20 August 2026
    Name, function:     <name>, <function>
    Signature:          ______________________

The angle-bracketed entries are deliberately left open. Standard references without a year of issue and signatures without authority to bind the company are two of the most frequent findings — neither can be copied from a template; both have to be determined case by case.

Which requirements in Articles 5 to 12 already apply

The conformity statement covers the requirements applicable at the moment of placing on the market. The timeline is staggered.

Since 12 August 2026:

  • Article 5 — substances of concern. The sum of the heavy metals lead, cadmium, mercury and hexavalent chromium is capped at 100 mg/kg. Food-contact packaging is subject to PFAS limits for individual substances and for the sum; there is no transition period for stock already produced, and recycled material is not exempt.
  • Article 10 — minimisation. The qualitative minimisation assessment under Annex IV must be documented. Design features whose only purpose is to make the product look bigger — double walls, false bottoms, unnecessary layers — are not permitted.
  • Article 11 — reusable packaging, where packaging is placed on the market as reusable.
  • Articles 38 and 39 — the procedure, the technical documentation and the declaration itself.

From 2030 onwards:

  • Article 6 — recyclability. From 1 January 2030 packaging must be assessed against design-for-recycling criteria and assigned a performance grade; from 1 January 2038 only the upper grades may be placed on the market. The Commission sets the detail in delegated acts.
  • Article 7 — recycled content. Minimum shares for plastic packaging bite from 2030; the calculation and verification methodology arrives via an implementing act.
  • Article 10(1) — empty space ratio. The limit on empty space in grouped, transport and e-commerce packaging applies as a standalone duty from 1 January 2030.

In practice: the declaration you issue today is narrower in substance than the one you will issue in 2030. That does not make it any less binding — and it must be updated as each new requirement becomes applicable. Our PPWR overview places the substantive requirements in context.

One declaration for how many packaging items?

This question decides the workload. A company with 400 article numbers does not want to sign 400 declarations — and in many cases does not have to.

What can be grouped is what does not differ in the assessed properties. Size variants of the same folding carton, from the same board, with the same adhesive and the same print method, share the assessment under Articles 5, 6, 7 and 10 in substance — here a declaration with clearly named variants is defensible.

What cannot be grouped is anything that changes the assessment: a different material, a different coating, a different composite, a different supplier with a different formulation, a different function (sales versus transport packaging), or food contact versus non-food contact, because the PFAS limits then apply.

The robust approach is to use the assessment dimensions as the grouping key, not the commercial logic. Packaging families cut along product ranges or customer segments are almost always too coarse.

Retention, producing the file on request, and the chain of duties

The declaration and the technical documentation must be kept: at least five years for single-use packaging and at least ten years for reusable packaging, counted from placing on the market. Packaging last placed on the market in 2026 therefore has to be documented until 2031 or 2036 — through staff changes, system migrations and business transfers. That is the real reason not to keep this data in a folder on a shared drive.

The documents must be produced at the request of a market surveillance authority, within the deadline set. In practice deadlines of around ten days are used; anyone who starts assembling the file at that point has already lost.

The duties do not stop with the manufacturer. The importer must verify that the procedure was carried out and that the declaration and marking exist, and must not place packaging on the market where it has reason to doubt conformity. The distributor must check before making packaging available that the required marking is present. And whoever sells packaging under their own name, or modifies it in a way that affects conformity, takes on the manufacturer’s duties in full — declaration included.

For business customers the corollary is that you need hard data from suppliers, not assurances. A line reading “PPWR compliant” in a quotation is not evidence. What you need is the material breakdown, weights, dated test reports and a commitment to be notified when formulations change.

Six mistakes that make a declaration worthless

The object cannot be identified. “All cardboard packaging from company X” cannot be matched to any packaging item. Without a specific designation the declaration cannot be verified.

The notified body is invented. Test-house details carried over from CE practice turn a self-declaration into a false statement — and draw the authority’s attention to exactly that point.

Standard references without a year of issue. A standard without a year leaves open which version was applied. After a revision it is no longer possible to tell whether the assessment still holds.

Material data comes from the supplier without a date and without a duty to notify changes. If the supplier reformulates and nobody hears about it, the declaration goes quietly wrong. The notification duty belongs in the contract, not in goodwill.

There is no trigger for reassessment. Without defined trigger points — material change, tooling change, new supplier, new legal position — the file ages while production carries on.

The signature carries no authority. Whoever signs must be able to bind the company. A signature from quality assurance without the corresponding authorisation does not carry the document.

From declaration to data model: five steps

1. Cut the packaging portfolio along assessment dimensions. Not by product range, but by material, construction, coating, contact type and function. The result is the list of declarations you actually need.

2. Name the data gaps per group. Missing weights per material, missing PFAS testing where there is food contact, missing recycled-content evidence. That list is your procurement brief to the supply chain.

3. Put supplier requirements in the contract. Material breakdown in structured form, dated test reports, a duty to notify formulation changes. Without this step every file stays fragile.

4. Keep the data structured and versioned. One record per packaging item with history, feeding the declaration, the EPR report and the product passport alike. Maintain those three separately and you will have three divergent versions of the truth.

5. Tie declarations to events, not to the calendar. Material change, supplier change and legal change trigger reassessment. An annual review complements that; it does not replace it.

This is precisely where myDPP fits. It does not issue declarations and does not replace advice — it keeps product and packaging data so that material breakdowns, weights, recycled-content figures and evidence sit versioned in one place and feed both the conformity file and the digital product passport. Our DPP implementation checklist describes what a practical start looks like.

Frequently asked questions

Is there an official PPWR declaration of conformity template to download?

Annex VIII of Regulation (EU) 2025/40 contains the model that the declaration must follow in structure and content. There is no official fill-in form that replaces the substantive assessment. Templates from associations and vendors can reproduce the structure — the entries on object, standards and assessment you have to substantiate yourself.

Who must sign the PPWR declaration of conformity?

The manufacturer of the packaging — whoever makes it or has it made under its own name or trademark — represented by a person with authority to bind the company. Manufacturers outside the EU may appoint an authorised representative.

Do I need a declaration for every article number?

Not necessarily. Variants can be grouped as long as they do not differ in the assessed properties, typically size variants with identical material and construction. As soon as material, coating, composite, supplier or contact type differs, a separate assessment is required.

Do I have to hand the declaration to my customers?

It must be produced for market surveillance authorities. Business customers need the data required for their own conformity assessment; passing on the declaration itself is common practice but not mandatory in every case. Suppliers should settle this contractually.

How long must I keep the documents?

At least five years for single-use packaging and at least ten years for reusable packaging, in each case from placing on the market — for the declaration and the technical documentation.

Is a notified body required?

Not in the standard case. The PPWR uses internal production control; the assessment is done by the manufacturer. For packaging the notified body field usually stays empty.

Can myDPP issue the declaration of conformity for me?

No. The declaration is a legal statement by the manufacturer and cannot be taken over by a software vendor. myDPP manages the data that feeds the declaration and the technical documentation — materials, weights, recycled content, test reports, versions.

Sources

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