The PPWR begins to fully apply from next week, and many companies are currently focussed on collecting declarations, specifications, and test reports. However, ensuring true compliance starts with one thing: ownership. Ahmet Fatih Çepni, packaging consultant and the founder of AD Creative, identifies the five major operational issues companies should address before signing a Declaration of Conformity.
In the weeks after my recent PPWR workshops, I kept receiving the same questions in different forms:
- Which documents should we ask our packaging suppliers for?
- Is a general PPWR declaration enough?
- Do we need a laboratory report?
- Is my company responsible or is my supplier?
- Is our document list enough for 12 August 2026?
These are good questions, and I hear them often. But I think they start one step too late. Before asking suppliers for documents, a company first needs to decide who those documents are for and who will make the final conformity decision.
In many companies, PPWR preparation has already become a document collection exercise. Procurement asks for technical data sheets and supplier declarations. Quality collects substance statements and test reports. Sustainability requires packaging weights, recycled content evidence and recyclability information.
The documents may arrive, but the links between them are not always clear. A supplier declaration may not say which packaging it covers. A laboratory report may not refer to the approved material specification. Different departments may even hold different weights for the same packaging component.
Regulation (EU) 2025/40 becomes generally applicable on 12 August 2026, although some requirements have later application dates or depend on delegated or implementing acts. Subject to the specific derogations in Article 15, the manufacturer must carry out the conformity assessment under Article 38 or have it carried out on its behalf. It must also prepare the technical documentation required by Annex VII and, once conformity has been demonstrated, draw up the EU Declaration of Conformity under Article 39. By drawing up that declaration, the manufacturer takes responsibility for the packaging’s compliance.
1. The manufacturer may not be the packaging converter
One of the most common misunderstandings I see concerns the word ‘manufacturer’.
Many companies assume that the manufacturer must be the converter that physically produces the empty bottle, pouch, carton, tray or label. The PPWR definition is wider than that.
Article 3(13) covers the natural or legal person that manufactures packaging or a packaged product. Subject to the specific micro enterprise provision, it also treats a person that has packaging or a packaged product designed or manufactured under its own name or trademark as the manufacturer.
The European Commission’s June 2026 guidance explains how it interprets this definition in common supply chain situations. The guidance does not replace the regulation, and the binding interpretation of EU law remains with the Court of Justice of the European Union.
Under the Commission’s interpretation, there should be one PPWR manufacturer in the supply chain.
For sales packaging, other than service packaging and for grouped packaging, this will normally be the economic operator that carries out the final processing steps, such as cutting, filling or sealing, filling the packaging with its product and places the packaging or packaged product on the Union market. In practice, this will often be the filler and, in many cases, the product brand owner.
For transport packaging, service packaging in its final form and primary production packaging, the manufacturer will normally be the company that manufactures the packaging. Where that packaging is clearly branded with the user’s name or trademark, the Commission’s interpretation is that the user is the manufacturer.
Importers and distributors can also take on manufacturer obligations. Under Article 21, this can happen when they place packaging on the market under their own name or trademark or when they modify packaging already placed on the market in a way that could affect compliance.
The Regulation also contains specific micro enterprise provisions in Article 3(13)(b) and Article 15(12). These conditions need to be checked separately. They should not be treated as a general exemption for SMEs.
A second distinction is also important: the PPWR manufacturer and the EPR producer are not automatically the same economic operator.
The manufacturer is responsible for the packaging’s conformity with the applicable requirements laid down in or pursuant to Articles 5 to 12. The producer is the manufacturer, importer or distributor that meets one of the territorials and placing on the market conditions in Article 3(15) and carries the relevant extended producer responsibility obligations in the Member State concerned. Depending on the packaging type, the supply chain and the market route, one company may hold both roles, or the roles may belong to different companies.
This should be resolved before anyone completes a DoC template.
As a practical control, companies should keep a documented responsibility map. Where relevant, it should cover the manufacturer, supplier, importer, distributor, final distributor, EPR producer, authorised representative and fulfilment service provider. It should also identify the internal function authorised to approve the conformity assessment.
The PPWR does not prescribe a document called a ‘responsibility map’. It is simply a practical management tool. It helps prevent a situation in which several companies collect information, but nobody takes responsibility for the conclusion.
2. A purchasing specification is not necessarily a compliance record
Most companies already have packaging specifications.
These records may include dimensions, colour references, printing requirements, material descriptions, pallet patterns, functional tolerances and quality criteria. They answer an important operational question: what must the supplier manufacture?
A PPWR technical file must answer more questions. Annex VII requires technical documentation that makes it possible to assess conformity with the applicable requirements. It must include an adequate analysis and assessment of the risks of nonconformity, identify the applicable requirements and cover, as far as relevant, the design, manufacture and operation of the packaging.
Depending on what is applicable, the documentation includes a general description and intended use, conceptual design and manufacturing drawings, component materials, explanations needed to understand those records, references to relevant standards or technical specifications, descriptions of the technical solutions adopted and supporting assessments, calculations and test reports.
That is the legal core. In practice, companies will usually need additional controlled information to connect the Annex VII file to the packaging they actually purchase and use.
Take a specification that describes a material only as ‘printed PE film’. This may be enough for purchasing, but it may not show the polymer grade and layer structure, coatings, inks and adhesives, applicable thickness and component weight, intended contact conditions, supplier and manufacturing source, specification or artwork revision, or the test reports and declarations supporting the assessment.
Not all of these items are separate headings required by Annex VII. They are operational data used to create traceability between the physical packaging, the controlled specification and the supporting evidence.
A PPWR packaging record should answer four simple questions:
- Which packaging was assessed?
- Which requirements apply to it?
- Which specification and revision were reviewed?
- What evidence supports each conclusion?
Again, ‘’packaging master record’ is not a document title prescribed by the Regulation. It is a practical way to maintain the traceability needed for the conformity assessment.
3. A supplier declaration needs a defined scope
Supplier engagement is essential for PPWR conformity. Article 16 requires suppliers of packaging or packaging materials to give the manufacturer all information and documentation needed to demonstrate conformity. This includes the Annex VII technical documentation required under or pursuant to Articles 5 to 11.
Where appropriate, documentation required under other Union legislation for contact sensitive packaging must also be included.
This is a clear information obligation for suppliers. It does not transfer the manufacturer’s responsibility to them.
It is also important that Article 16 refers to documentation required under or pursuant to Articles 5 to 11. The manufacturer’s wider obligation under Article 15 still covers the applicable requirements laid down in or pursuant to Articles 5 to 12, including relevant labelling requirements.
A document called ‘PPWR Declaration’ or ‘PPWR Compliant’ may be useful. But the title alone does not show what the document proves.
Before relying on it, the manufacturer should be able to see which material, component or packaging reference it covers; which specification and revision were assessed; which PPWR requirement is being addressed; which limit, criterion or technical specification was applied; whether the conclusion is based on testing, calculation, material knowledge or upstream evidence; which supporting reports are available; who issued and authorised the document; and how relevant formulation, material, supplier or manufacturing changes will be communicated.
The same problem can occur with laboratory reports. A report may use an accredited analytical method and show an acceptable result. It may still be insufficient for the technical file if the tested sample cannot be linked to the material currently purchased and used.
For example, a heavy metal or PFAS report carrying only a laboratory sample number does not, by itself, prove the link to a supplier, material code, formulation, manufacturing source or approved specification revision. The evidence chain should be clear: packaging type, component, controlled specification, supplier document or test report, applicable requirement and conformity conclusion.
Article 16 requires the supplier to provide the necessary information. Article 39 keeps responsibility for the final declaration with the manufacturer. Supplier evidence is therefore an input to the conformity assessment. It is not a transfer of accountability.
4. The unit of control should be the packaging type, not only the finished product SKU
Most brand owner systems are organized around finished product SKUs. That makes sense for sales, forecasting, inventory, artwork and production planning.
Packaging conformity needs another control level. Under the internal production control procedure in Annex VII, the manufacturer draws up a written EU Declaration of Conformity for each packaging type. Article 15(5) also requires packaging to carry a type, batch or serial number, or another element that allows identification. Annex VIII requires the object of the declaration to be identified in a way that allows traceability.
A finished product SKU and a packaging type are not always the same thing. One controlled packaging type may support several finished product SKUs where the relevant design, materials, specification and conformity characteristics remain unchanged.
At the same time, one SKU may contain several packaging elements: a bottle, closure, pump, label, carton, leaflet, transport case, stretch film and pallet configuration. Managing the SKU as one undifferentiated packaging record may hide evidence gaps at component level. The Regulation does not give a detailed commercial method for grouping several SKUs under one packaging type. Any grouping therefore needs to be technically justified case by case.
Packages should not be treated as the same type only because they look similar or are used for similar products. Differences in material composition, structure, component weight, barrier properties, intended use, printing system or manufacturing specification may affect the applicability assessment or the supporting evidence.
Even an artwork or colour change may need review if it introduces a different ink, coating, supplier or material specification. Packaging type control also makes change management more practical.
Article 15(4) requires manufacturers to maintain the conformity of series production and to take proper account of changes in packaging design, characteristics and the standards or technical specifications used to declare or verify conformity. Where conformity could be affected, a reassessment must be carried out. Article 39 requires the DoC to be kept up to date.
A supplier or manufacturing site change does not automatically require a new DoC. It should, however, trigger a documented impact review. The review should check whether the change affects the controlled specification, packaging characteristics, supporting evidence, applicability assessment or conformity conclusion. If it does, the technical documentation must be reassessed and the DoC updated where necessary.
Without packaging type identification and revision control, these decisions often depend on email history or individual memory.
5. PPWR and EPR should share controlled data, not legal logic
PPWR conformity and EPR are different legal processes. The conformity assessment covers applicable packaging requirements laid down in or pursuant to Articles 5 to 12. EPR determines which economic operator carries the applicable registration, reporting, financial and other extended producer responsibility obligations in each Member State.
The producer role depends on the conditions in Article 3(15), including the packaging type, the territory where the packaging is first made available and in cross border situations, whether products are supplied directly to end users.
The two processes should not be merged into one legal assessment. However, they depend on much of the same source information: packaging material and component weight, packaging format and level, reusable or single use status, packaging and product identifiers, market destination, recycled content information and quantities made available on the market.
In many companies, these data are kept in different places. Procurement has the supplier specification. Packaging development has the drawings. Quality keeps food contact and substance documentation. Sustainability maintains a separate packaging weight file for EPR reporting. Regulatory affairs prepares the DoC from another dataset.
The risk is easy to see: the same package can have different weights, material classifications or packaging level definitions depending on which department is asked.
The answer is not one enormous spreadsheet. It is a governed packaging data structure with clear data ownership, approved sources, revision control and defined relationships between packaging types, components, suppliers, SKUs and markets.
This is a management model, not a named PPWR requirement. Its value is that the same controlled source data can support different outputs while each legal obligation remains separate. These outputs may include PPWR technical documentation, EU Declarations of Conformity, EPR registration and reporting, customer questionnaires, packaging weight disclosures and recycled content or packaging minimisation projects.
The aim is not to force every department into the same process. It is to stop different teams from using competing versions of the same packaging information.
The DoC is the output, not the starting point
Companies preparing for PPWR will need supplier declarations, technical specifications, assessments, test reports, technical documentation and EU Declarations of Conformity. But the number of documents in a folder is not a reliable measure of readiness.
A company is better prepared when it can answer five questions clearly:
- Who is the PPWR manufacturer for this packaging?
- Which controlled packaging type is being assessed?
- Which requirements currently apply to it?
- What evidence supports each conformity conclusion?
- What happens when the specification, supplier or manufacturing conditions change?
The EU Declaration of Conformity is an important legal document. It is also a relatively short document.
Its credibility depends on what sits behind it: a clear role decision, controlled packaging data, technical documentation, traceable supplier evidence, an applicability assessment and working change control.
This is why I do not see PPWR as only a documentation exercise. The documents matter, but they only make sense when the company has decided who owns and manage the packaging, the evidence and the final conformity decision.
PPWR compliance starts with ownership.
This article reflects an operational packaging compliance perspective and does not constitute legal advice.
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