PPWR: Paying EPR Fees Is Not the Same as Having a Declaration of Conformity

With 16 days until the PPWR applies on 12 August 2026, a lot of packaging-compliance tools lead with one headline number: what your Extended Producer Responsibility (EPR) fees will be. That number matters — but it is easy to walk away thinking “fees calculated, PPWR sorted.” It isn’t. Under the EU Packaging and Packaging Waste Regulation there are two separate obligations that people routinely conflate: paying your EPR fees and holding a Declaration of Conformity. This guide explains the difference, why it matters for how you choose software, and which one actually falls due on day one.

It draws on Regulation (EU) 2025/40and the European Commission’s guidance document and FAQ.

Two obligations, not one

The simplest way to hold the distinction: EPR fees are about the waste; the Declaration of Conformity is about the product.

• EPR feesfund the end-of-life system. When you place packaging on a national market, you register with that country’s producer-responsibility scheme and pay a fee — increasingly eco-modulated, so better-recyclable packaging costs less. This is a financial and registration obligation, set and enforced by each member state.
• The Declaration of Conformity (DoC)is about the packaging itself. It is a legal document in which the manufacturer declares, under sole responsibility, that the packaging meets the PPWR’s product requirements — backed by technical documentation. This is an EU-wide product obligation under Articles 38–39 and Annex VIII.

They are independent. You can be fully paid up on EPR fees in every market and still be non-compliant because you have no DoC — and you can have a perfect DoC and still owe unpaid fees. Market-surveillance authorities check the DoC and technical file; national schemes chase the fees. Different documents, different checkers, different penalties.

Why software leads with EPR fees (and what that leaves out)

Fee calculation is a natural headline feature: it produces a concrete euro figure, it maps cleanly onto structured packaging data (material, weight, format), and it recurs every year, so it’s easy to price and sell. Several capable tools — enterprise suites such as the osapiens/GreenDot platform, packaging-data suites, and US-first EPR products with an EU add-on — are built around exactly this.

The gap is that a fee number says nothing about whether your packaging passes the product rules. Calculating that a food tub will cost you a certain amount in French and German EPR fees does not tell you whether its inks and coatings stay under the PFAS and heavy-metal limits, and it does not, by itself, produce the signed Annex VIII declaration you must be able to show. Those are the parts that actually fall due on 12 August 2026 with no grace period. So “we calculate your EPR fees” and “you are PPWR compliant” are not the same claim — and it’s worth being clear which one a tool is making.

What actually applies on 12 August 2026

For the product side, the substantive day-one requirement is Article 5 — substances of concern: the heavy-metal concentration limits and the restriction on PFAS in food-contact packaging, applying with no stock-exhaustion period. Manufacturers must draw up a Declaration of Conformity, scoped to what actually applies now, backed by technical documentation (lab test reports, supplier declarations). Most of the rest of Articles 5–12 — recyclability grading, recycled content, minimisation, labelling — phase in from 2028 and 2030, so a DoC signed in 2026 should not over-declare them. We walk through the phasing in the DoC guide.

EPR registration and fee deadlines, by contrast, are set per member stateby each national scheme and don’t all land on 12 August. You can get a rough picture of the fee side with our free EPR fee estimator — but treat that as budgeting input, not as evidence of conformity.

What this means when you choose a tool

Neither obligation is optional, so the practical question is what a given tool actually covers. When you evaluate packaging-compliance software, separate the two:

• For EPR fees: does it calculate eco-modulated fees per country, and produce registration-ready or submission-ready reports?
• For conformity: does it check the Article 5 substance and PFAS limits against your lab data, and draft the Annex VIII Declaration of Conformity with human sign-off — or does it stop at a score?

A tool that only does the first leaves you to produce the DoC some other way. That’s a legitimate split — plenty of enterprise buyers run one system for fees and another for product conformity — but go in with your eyes open rather than assuming a fee calculator has covered your day-one obligation.

Where VerdLynx fits

VerdLynx is built product-first: it reads your lab Certificates of Analysis and checks them against the PPWR substance and PFAS thresholds, drafts the Annex VIII Declaration of Conformity (blocked until the substance check passes, with human sign-off), verifies on-pack markings, and keeps the archive with expiry reminders. It also includes a free EPR fee estimator for budgeting — but its centre of gravity is the conformity obligation the fee-calculation tools underplay. If you want to see how the two capabilities compare across the market, read the PPWR software comparison.

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This guide is general information, not legal advice. Confirm your specific obligations against Regulation (EU) 2025/40 and your national EPR scheme’s rules, and, where needed, qualified counsel. Named products are described from public sources as of July 2026; features change — verify current capabilities directly.