In this blog, we explain what the EU Conformity Declaration under PPWR means, who must issue it, what it should include, and how manufacturers can prepare for the 12 August 2026 deadline.
The Packaging and Packaging Waste Regulation (PPWR) is being put into place across the European Union. A new requirement is changing how compliance with packaging rules is recorded. As of 12 August 2026, all types of packaging sold within the EU market are required to be accompanied by an EU Conformity Declaration, which is a formal statement that proves the packaging complies with the PPWR regulation. It is essential to understand what this statement is all about, who needs to do it, and how to do it for any packaging manufacturer or brand that wants to enter the EU market.
Here’s a complete, step-by-step guide in detail to help you prepare.
Key Takeaways
- The EU Conformity Declaration is an obligatory document that ensures packaging complies with PPWR regulations before entering the EU market.
- A correct EU Declaration requires a direct correlation between packaging design, materials, and regulatory requirements.
- Full EU Conformity can only be achieved through appropriate technical documentation and timely assessments.
- Specialised compliance assistance can facilitate documentation, minimise risks, and maximise regulatory preparedness.
EU Conformity Declaration Under PPWR – Quick Overview
| Section | Key Requirement | What It Means for Manufacturers |
| Legal Basis | Required under PPWR (Regulation (EU) 2025/40) | Packaging must comply before entering the EU market |
| Mandatory From | 12-Aug-26 | No packaging can be placed on the EU market without a valid declaration |
| Responsible Party | Manufacturer, importer, authorised representative, or certain distributors | The entity placing packaging on the EU market must issue the declaration |
| Required Content | Identification number, packaging description, manufacturer details, responsibility statement, legal references, standards used, signature | The declaration must clearly link packaging design to PPWR requirements |
| Supporting Documents | Technical file including design specs, assessments, test results, supplier evidence | Must be retained (5 years single-use, 10 years reusable) |
| Language & Format | Available in required Member State language; digitally accessible | Must be retrievable during inspections |
| Non-Compliance Risk | Fines, market bans, exclusion from EU market | Missing documentation equals regulatory risk even if packaging meets technical standards |
1. What Is an EU Conformity Declaration under PPWR?
The EU Packaging and Packaging Waste Regulation (PPWR) says that a “EU Conformity Declaration” is a legal document that must be filled out. It confirms that a specific packaging type complies with the applicable PPWR requirements related to design, recyclability, minimisation, reuse, and other sustainability criteria.
This document is not a simple checklist. It is a binding statement from the manufacturer or the economic operator acting as the “producer” affirming that the packaging design meets all regulatory criteria outlined in Articles 5–12 of the PPWR.
2. Who Must Issue the EU Conformity Declaration?
The obligation lies primarily with the packaging manufacturer, defined as the entity that places the packaging on the EU market for the first time. Manufacturers must conduct a conformity assessment and then issue the declaration before placing packaging on the EU market.
In cases where packaging originates outside the EU, importers or authorised representatives may fulfil the obligation provided they act in compliance with PPWR requirements and maintain the necessary documentation.
Distributors that sell packaging under their own name or change packaging in ways that affect compliance may also be responsible for making the declaration.
3. When Does It Become Mandatory?
The PPWR came into force in February 2025, but the obligation to have a conformity declaration will only fully apply from 12 August 2026. From that date on, it will not be possible to put any packaging on the market in the EU without a valid EU Conformity Declaration for that type of packaging.
This is part of a wider timeline set out in the PPWR, which also includes obligations for labelling and recycled content by 2030.
4. What Must the EU Conformity Declaration Include?
Article 39 of the PPWR says that there is a standard model in Annex VIII that lists the basic things that must be in the statement. The following must be in an approved EU Conformity Declaration:
- Unique Identification Number: A reference number that connects the document to internal references, material numbers, or supplier numbers.
- Packaging Identification: A description of the packaging, including size, materials, and any critical components.
- Manufacturer Details: Name, address, and contact information of the manufacturer or authorised representative.
- Statement of Responsibility: A formal declaration that the manufacturer accepts sole responsibility for conformity with PPWR requirements.
- Reference to Legislation: A statement confirming compliance with PPWR (Regulation (EU) 2025/40) and any other applicable EU laws.
- Design and Test Basis: Reference to standards and technical specifications used to demonstrate conformity.
- Signature, Date, and Place: The declaration must be signed by an authorised official with their name, position, and date.
These points ensure the document clearly links a specific packaging design to the regulatory requirements it claims to meet.
5. Supporting Technical Documentation
The statement is only one part of a bigger set of rules for compliance. In addition to the statement of conformity, manufacturers must also keep the following technical documents:
- Packaging design specifications and variant details.
- Results of conformity assessments, such as recyclability calculations or reuse validations.
- Supporting tests, studies, and supplier documents are used as evidence.
This technical file needs to be kept for a certain amount of time, usually five years for single-use packaging and ten years for reusable packaging. The market surveillance officials must be able to access it if they request it.
6. Language, Format, and Accessibility Requirements
In the Member State where the package is marketed, the EU Conformity Declaration must be available in the language specified by that state. Businesses that sell packaging in several EU nations frequently create translated versions.
Declarations can be stored digitally, but they must be accessible and retrievable promptly during inspections by authorities.
7. Risks of Non-Compliance
The lack of preparation or maintenance of a valid EU Conformity Declaration can have serious consequences. Packaging without a valid declaration can be regarded as non-compliant. This can result in fines, a ban on market access, or exclusion from the EU market.
Even if the packaging meets all technical requirements, companies are at risk during audits or inspections if conformity documentation is missing.
8. How Digital Tools Can Help
Preparing an EU Conformity Declaration can be complex because a significant amount of information must be completed accurately. Computer software can help organise the process by adding material information and verifying recyclability.
Digital documentation tools make the process simpler for manufacturers and suppliers. Platforms that combine compliance documents with overall PPWR preparation also make it simple to update and manage declarations over time.
Summing Up
The EU Conformity Declaration under the PPWR is a basic compliance requirement that improves transparency and accountability for packaging sold in the EU. Manufacturers can make structured and verifiable disclosures well before August 2026 if they understand the deadlines, documentation requirements, and technical standards.
PackIntelX supports this process by helping you generate, manage, and update EU Conformity Declarations alongside PPWR compliance workflows, turning regulatory requirements into structured execution.
Partner with PackIntelX today to move from compliance complexity to confident execution!
