PPWR Declaration of Conformity: What Goes In It, Who Signs — With a Full Example

With 14 days until the PPWR applies on 12 August 2026,the Declaration of Conformity (DoC) is the document that proves a piece of packaging meets the EU’s new rules. It is a legal instrument: a named person signs it, and the manufacturer takes responsibility for what it says. This guide explains what the DoC is, exactly what goes in it, who signs, and — the part most teams get wrong — which requirements you actually have to demonstrate on day one. It includes a complete worked example you can copy, no email address required.

It draws on Regulation (EU) 2025/40(Articles 38 and 39, and Annexes VII & VIII) and the European Commission’s guidance document and FAQ.

What is a Declaration of Conformity under the PPWR?

The EU Declaration of Conformity is the manufacturer’s written statement that its packaging meets the PPWR’s requirements. Two articles create it. Article 38 requires a conformity assessment following the procedure in Annex VII — for packaging this is Module A, internal production control: the manufacturer assesses its own packaging and keeps the evidence; there is no notified body. Article 39 then requires the manufacturer to draw up the DoC using the model in Annex VIII, keep it continuously updated, and translate it into the languages of every member state where the packaging is placed on the market.

What must the Declaration of Conformity contain? (Annex VIII)

Annex VIII sets the model. In practice a compliant DoC carries these elements — treat it as your template:

1. A unique declaration number that identifies the packaging.
2. The name and address of the manufacturer and, where appointed, its authorised representative.
3. A statement that the declaration is issued under the manufacturer’s sole responsibility.
4. The object of the declaration — identification of the packaging allowing traceability (its type, batch or serial number).
5. A statement of conformity. Article 39(1) is explicit: the DoC states that “the fulfilment of the requirements laid down in or pursuant to Articles 5 to 12 has been demonstrated.”
6. References to any harmonised standards, common specifications or other technical specifications applied.
7. Where relevant, notified-body details — not applicable to packaging, which uses internal production control (Module A).
8. The signature block: signed for and on behalf of the manufacturer, with place and date of issue, and the signatory’s name and function.

What a completed DoC looks like — a worked example

Here is a complete example for a fictional manufacturer, numbered to match the Annex VIII elements above. It is deliberately drafted the way a DoC signed in August 2026 should be — scoped to what has actually been assessed — rather than the over-declared version you will see in many templates. Copy the structure freely.

Three choices in this example are deliberate:

• The conformity statement is scoped. It declares the Articles 5–12 requirements that apply at the date of issue and names what was actually demonstrated (Article 5). Many templates declare blanket conformity with the whole regulation — including requirements that cannot yet be assessed. Don’t sign what you haven’t demonstrated.
• No EN standards are cited. The old EN standards no longer give a presumption of conformity (see below), so citing them adds nothing and can mislead. The evidence lives in the technical file.
• The object is the whole packaging unit— tub, lid, label, inks and adhesives together, identified at batch-series level, matching the FAQ’s reading of “packaging type.”

Who signs it?

The manufacturer draws up and signs the DoC — or an authorised representativeappointed by a written mandate (Article 17). The conformity assessment itself can be carried out by a lab or a certification scheme on the manufacturer’s behalf, but the declaration belongs to the manufacturer. As the Commission’s FAQ puts it, the manufacturer is the sole economic operator bearing legal responsibility for the packaging’s compliance, regardless of who actually drafted the DoC. So the person who signs should be authorised to commit the manufacturer.

What actually applies on 12 August 2026?

This is where most teams over-declare. The statement references Articles 5 to 12, but those requirements phase in on different dates — you can only demonstrate the ones actually in force:

• Article 5 — substances of concern: applies on 12 August 2026, including the PFAS restriction in food-contact packaging (with no stock-exhaustion grace period). This is the substantive requirement you demonstrate at launch.
• Article 6 — recyclability:the general “all packaging shall be recyclable” rule applies, but the Commission’s guidance says manufacturers do not perform the Article 38 / Annex VII conformity assessment for recyclability until the design-for-recycling delegated act enters into force (expected around 2028; binding grades from 2030).
• Articles 7, 10 and 24 — recycled content, packaging minimisation and the empty-space ratio: from 1 January 2030.
• Articles 12 and 13 — labelling: from August 2028.

The practical rule: a DoC signed in 2026 substantively demonstrates Article 5, and it should not claim assessments that haven’t been done. Because Article 39 requires the DoC to be continuously updated, plan to revisit it as labelling (2028) and recyclability, recycled content and minimisation (2030) come into force. For a fuller timeline, see our plain-English PPWR guide.

One declaration per packaging type — not per SKU

Annex VII requires a written DoC “for each packaging type.” The FAQ clarifies that “type” means each packaging format or batch/series, not the material. The assessment and declaration cover the entire packaging unit— bottle, closure and label together, not each component on its own. Draft the DoC at the level where packaging shares the same characteristics for the applicable requirements: different sizes of the same product can share one DoC only if the size difference doesn’t affect compliance with Articles 5–12. Transport packaging is not exempt — pallets, collars, wraps and straps each need their own declarations.

Harmonised standards: no automatic presumption of conformity yet

Under the old Packaging Directive, meeting a harmonised standard gave a presumption of conformity. Under the PPWR that has changed: the Commission’s FAQ confirms the pre-existing EN standards can now be used only as guidance — they give no presumption of conformity— with one exception, EN 13428 on packaging minimisation, which stays valid until the end of 2029. Presumption of conformity returns only once the Commission publishes new harmonised standards in the Official Journal. So don’t cite an old EN number on your DoC expecting it to prove conformity — leave it out unless a standard has genuinely been applied.

The technical documentation behind it (Annex VII)

The DoC is the visible tip — it must be backed by technical documentation that lets an authority assess conformity: a description of the packaging and its intended use, the design and materials, the standards or specifications applied, a qualitative description of how the Article 6, 10 and 11 assessments were carried out (as far as relevant), and test reports. Keep the DoC and technical file for 5 years (single-use packaging) or 10 years (reusable packaging) after the packaging is placed on the market — and be ready to hand them over fast: on a reasoned request from a national authority, the documents must be provided within 10 days, in electronic form and, on request, on paper (Article 15(10)).

Importers and distributors: collecting your suppliers’ DoCs

If you import or distribute packaging you didn’t manufacture, you must make sure the manufacturer has drawn up the Declaration of Conformity and technical documentation and keep a copy available for market- surveillance authorities — the same 5-to-10-year window and the same 10-day response clock. In practice that means collecting a DoC from every packaging supplier and holding it, which is a real operational task once you have dozens of suppliers and hundreds of SKUs.

Common mistakes to avoid

• Declaring conformity with all of Articles 5–12 when only Article 5 has actually been assessed.
• Citing old EN standards as if they still prove conformity.
• Drafting per-SKU or per-component instead of per packaging type / whole unit.
• Forgetting the language requirement for each market of placement.
• Treating the DoC as one-and-done instead of keeping it updated as requirements phase in.

How VerdLynx helps

VerdLynx drafts Annex VIII declarations from your SKU data, scopes them to what actually applies now, blocks signing until the substance check passes, and gives importers a workflow to request and collect suppliers’ DoCs. See the Digital Product Passport guide or estimate your packaging EPR fees, or start free below.

Try VerdLynx free → 10 SKUs, no card needed

This guide is general information, not legal advice. Confirm your specific obligations against Regulation (EU) 2025/40 and, where needed, qualified counsel. The binding interpretation of EU law rests with the Court of Justice of the European Union.