From the 12th of August this year, all packaging sold in EU markets will be legally required to have its own PPWR-related Declaration of Conformity (DoC). In this article Adrian Reyes, founder and CEO of Emission Core, walks us through a specimen DoC, explaining what each section means and how to fill it out correctly.
For weeks now the same question keeps coming in my DMs and calls: can you show me a Declaration of Conformity? So here is one, a full specimen, both pages, made for a fictional bakery and watermarked, because the internet is the internet.
Below I go section by section with the article of the regulation behind each point. This is a legal document, and if I can’t point to the article I shouldn’t write the sentence.
The document exists because of three provisions working together. Article 4(1) says packaging shall only be placed on the market if it complies with the regulation, Article 15(1) makes the manufacturer responsible for that, and Article 15(2) says that once the conformity assessment under Article 38 has shown compliance, the manufacturer draws up the declaration.
The assessment itself is Module A, internal production control under Annex VII, which means there is no notified body and no CE mark: you assess yourself, you sign yourself, and the burden of proof stays with you.
The declaration follows the model in Annex VIII, which has eight numbered sections.
Section 1 is the unique identification of the packaging, and the rule here is one packaging type, one DoC. A carton with a tray and a film inside counts as one composite unit, so it gets one document, while writing “all our packaging” identifies nothing and doesn’t meet the requirement.
Section 2 names the manufacturer, and you have to watch out with this word. Under Article 3(1)(13) the manufacturer is whoever has the packaging or the packaged product designed or produced under its own name or trademark, which is not necessarily the factory, and the Commission guidance adds that there is only one manufacturer in a supply chain. In practice this means that if you sell private label, this role is yours, and if as an importer or distributor you put your own brand on the packaging or modify it in a way that can affect compliance, Article 21 puts you in the same position. There is an exception for micro enterprises, so if you’re a very small company, check it.
Section 3 is a single sentence stating that the declaration is issued under the sole responsibility of the manufacturer, and section 4 describes the packaging with enough detail for traceability: the unit, the components and the materials, with the full breakdown going into the technical documentation rather than here.
Section 5 is the conformity statement, written with the exact wording of the regulation: the applicable requirements laid down in or pursuant to Articles 5 to 12. The word applicable is important, and page 2 of the specimen explains why.
Section 6 asks for the standards used, and the honest situation in 2026 is that no harmonised standards under Article 36 and no common specifications under Article 37 have been published for these requirements, so you declare against the analytical methods in your technical file. If a supplier sends you a DoC with a list of standards in this section, ask which ones and check them.
Section 7 is the notified body, which under Module A doesn’t exist, so it reads “not applicable”. The section still has to appear, because the numbering of the model is fixed and the inspector reads the document against it.
Section 8 is additional information, and this is where the applicability matrix goes. The PPWR applies in phases, so a correct DoC has to state, for each article from 5 to 12, whether it applies on the date of issue or not.
From 12 August 2026 the substance restrictions of Article 5 apply, including the PFAS limits of Article 5(5) for food contact packaging, where the Commission guidance is clear that there is no transition for stock: packaging placed on the market after that date complies or it doesn’t ship. The general recyclability obligation of Article 6(1) also applies from that date, and until the design for recycling criteria of Article 6(2)(a) arrive, the guidance says you assess under the old framework of Directive 94/62/EC and EN 13430.
The rest comes later. Recycled content under Article 7 applies from 1 January 2030 at the earliest, compostability under Article 9 from 12 February 2028 for the listed categories, and labelling under Article 12(1) from 12 August 2028 at the earliest. Minimisation under Article 10 applies from 1 January 2030, but careful here, because Article 70(1)(b) keeps the old minimisation requirements and their standard alive until the end of 2029, so not yet applicable doesn’t mean stop minimising.
If the matrix is wrong in any direction, the document is wrong. I’ve seen DoCs declaring 2030 requirements today and companies convinced that nothing applies before then; the matrix exists to prevent both.
Then comes the signature with name, function, place and date. With the declaration the manufacturer takes the responsibility for the compliance of the packaging (Article 39), and behind the signature sits the technical documentation of Annex VII, built with the information your suppliers must give you under Article 16(1). If a national authority asks, you have 10 days to produce it (Article 15(10)), and you keep it for 5 years, or 10 for reusable packaging (Article 15(3)). Two things almost nobody tells you: the DoC is not a one-time exercise, since Article 15(4) requires a re-assessment when changes in the packaging or in the standards can affect conformity, and importers have their own duty to check that the assessment was done before the packaging enters the market.
The three mistakes I see every week: one DoC for the whole catalogue, which fails section 1; a signed DoC with no technical file behind it, which holds only until an authority uses its 10 days; and the phasing errors described above, in one direction or the other.
The specimen is fictional and the watermark is deliberate. Your real one carries your company name and a real signature, and from 12 August the person who signs takes legal responsibility for every line on the page. Check yours against these eight sections before that date.
Disclaimer: This article is for informational purposes only and does not constitute legal advice.
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Supporting documents
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