PPWR declaration of conformity: what is required from August 2026
Most people are looking for a template. The binding one sits in Annex VIII of the regulation — the effort is elsewhere: in the technical documentation the declaration has to substantiate. What belongs in it, who signs, how long to keep it, and the five mistakes that happen most often in practice.
Hendrik Schulze·Stand: July 2026
Straight to the templates and checklistWhat the PPWR declaration of conformity is
From 12 August 2026, every piece of packaging placed on the EU market needs an EU declaration of conformity. It follows the template in Annex VIII of Regulation (EU) 2025/40 and confirms, per packaging type, that the requirements of the regulation are met.
Two misunderstandings are worth clearing up straight away. First: the declaration is issued per packaging type, not per shipment or batch — it is not a shipping document. Second, and more consequential in practice: the declaration itself is the smallest part of the work. It is the signature under a body of data that has to exist first.
That does not mean no requirements yet apply to the packaging itself. From August 2026 the substance requirements under Art. 5 bind — substances of concern kept to a minimum (para. 1), PFAS in food-contact packaging (para. 5), the 100 mg/kg heavy-metal sum (para. 4) — as does the basic duty that packaging must be recyclable (Art. 6(1)) and the ban on misleading sustainability claims (Art. 12(8)). Only later come the measurable grades and quotas: recyclability of at least grade C (Art. 6(3)), minimum recycled content (Art. 7), the empty-space limit (Art. 24) and the minimisation requirement of Art. 10 with both paragraphs — until 31 December 2029 Directive 94/62/EC still governs it (Art. 70(1)(b)). What matters for procurement: none of these requirements can be evidenced without supplier data. The full picture is in the overview of deadlines and obligations.
The technical documentation under Annex VII
What the declaration has to substantiate is the technical documentation under Annex VII. That is the actual substance of the project, and the records come predominantly from suppliers. Annex VII Nr. 2 names six elements:
- a) A general description of the packaging and its intended use
- b) Designs, manufacturing drawings and materials of components
- c) Descriptions and explanations necessary to understand the drawings and the functioning
- d) A list of the applied harmonised standards, common specifications and other technical specifications
- e) A qualitative description of the manner in which the assessments under Art. 6, 10 and 11 were carried out
- f) Test reports
Element b) is where projects fail: "Carton, 300 gsm" says nothing about drawings and materials of components. And elements d) and f) — the standards list and the test reports — are almost always missing from circulating overviews, although both are mandatory.
What each individual data area requires, where it breaks down in practice and why — unlike the declaration itself — there is no official template for it, is covered in the dedicated article on the Annex VII technical documentation.
The template — and its limits
The most common search on this topic is for a template. The answer is unsatisfyingly short: the binding template is in Annex VIII of the regulation itself. A PDF or Excel template from a third party does not replace it and has no independent legal standing.
With templates circulating freely, the date is worth checking too. Part of the detailed criteria — particularly for assessing recyclability — only arrives through delegated acts of the Commission, the Commission is required under Art. 6(4) to adopt them by 1 January 2028. Undated templates go stale accordingly.
What you actually need is a data template for your suppliers that asks for the Annex VII fields — mandatory, uniform, and a required part of every enquiry. No completed data, no quote. That is the part that needs lead time.
Who declares and who is liable
The declaration is issued by whoever places the packaging on the EU market. That is not automatically the packaging manufacturer. If you buy packaging and use it to package your own products, you place the packaged goods on the market — and the responsibility is yours.
That responsibility cannot be contracted away. What can and should be written into contracts is the supplier's duty to supply data: disclosure obligations, deadlines, and a duty to update on any material or formulation change. This is exactly where procurement sits at the decisive point, because it owns the supplier relationship — legal and sustainability can advise, only procurement can demand.
Retention and presentation to authorities
The declaration of conformity and the technical documentation must be kept for five years for single-use packaging and ten years for reusable packaging, each from placing on the market. Market surveillance authorities can request them on demand, and they must then be presentable at short notice.
"At short notice" implies a requirement that project plans often miss: the data set has to be versioned. When a supplier changes material, it must remain traceable which figures were valid at the time of placing on the market. A folder of overwritten PDFs does not do that.
The most reliable self-test is an internal audit simulation: pick ten articles at random and try to produce the complete documentation. Whatever is missing there will also be missing when an authority asks.
Five common mistakes
Writing the declaration before the data exists
The declaration is an outcome, not a task. Issuing it without complete Annex VII documentation means declaring something you cannot substantiate.
Treating supplier statements as documentation
A product data sheet as a PDF in an inbox is not an auditable data set: it cannot be versioned, cannot be evaluated per item, and goes stale silently with every material or supplier change.
Counting post-industrial as post-consumer recyclate
Only post-consumer recyclate counts towards the recycled-content targets. Production waste does not — counting it overstates your share.
Waiting for someone else’s template
The binding template is in Annex VIII of the regulation. The effort sits in the data behind it — and that comes from suppliers who answer in weeks, not days.
Naming no owner
PPWR documentation falls between legal, sustainability and procurement. Without named ownership carrying both mandate and budget, nothing moves.
How to set up the underlying data project in practice — inventory, supplier template, requalification, a central data base — is covered in the overview article under five steps to a solid data base. Procurement teams that want to collect this data from their suppliers in a structured way will find how that emerges as a by-product of normal sourcing on the page about PPWR software for documentation and reporting. Packaging manufacturers who have to supply this data to their customers will find it under PPWR reporting for producers.
Sources & method
- Regulation (EU) 2025/40 (PPWR), published in the EU Official Journal on 22 Jan 2025, in force since 11 Feb 2025 — requirements for the declaration of conformity and technical documentation from Annex VIII and Annex VII respectively; recycled-content shares from Art. 7.
- The binding field structure of the declaration follows from the template in Annex VIII of the regulation text. This article describes the data that template has to substantiate; it does not reproduce it as a form.
- European Commission PPWR guidelines and FAQ of 30 Mar 2026 (not legally binding).
- Criteria for assessing recyclability follow via delegated acts of the Commission (the Commission is required under Art. 6(4) to adopt them by 1 January 2028) and are not yet available.
- Information as of 28 July 2026. This article is editorial guidance, not legal advice.
Frequently asked questions about the PPWR declaration of conformity
What goes into the PPWR declaration of conformity?
The declaration follows the template in Annex VIII of Regulation (EU) 2025/40 and confirms, per packaging type, that the requirements are met. Substantively it rests entirely on the technical documentation under Annex VII Nr. 2: a general description and intended use, designs, manufacturing drawings and materials of components, the explanations for them, the list of applied standards and specifications, a qualitative description of how the assessments were carried out, and test reports — plus an analysis of the risks of non-conformity. Take the binding field structure straight from the template in the regulation — the real effort lies in the data that has to substantiate it.
Is there an official template for the PPWR declaration of conformity?
Yes — inside the regulation itself: Annex VIII of Regulation (EU) 2025/40 contains the template. A separate PDF or Excel template from a third party does not replace it and carries no legal weight of its own. In practice you need two things: the template for the form, and a structured per-article data base for the content. Be wary of templates circulating without a date: some of the detailed criteria only arrive through delegated acts, so freely available templates go out of date quickly.
When does the declaration of conformity become mandatory?
From 12 August 2026. From that date the PPWR applies directly in every EU member state, and both the declaration of conformity and the technical documentation are mandatory for every piece of packaging placed on the market. The product requirements — recyclability of at least grade C, minimum recycled content, the void-space limit — only follow from 1 January 2030.
Who has to issue the declaration of conformity?
The “manufacturer” within the meaning of Art. 3(1)(13) — whoever has packaging or a packaged product designed or manufactured under their own name or trademark. That is not automatically the packaging producer: if you buy packaging and use it to package your own products, you are normally the manufacturer. Your suppliers provide the records — they are obliged to under Art. 16(1) — and you sign the declaration. One exception reverses this: where the trademark holder is a micro-enterprise and its packaging supplier is established in the same member state, Art. 3(1)(13)(b) makes the supplier the manufacturer.
How long does the documentation have to be kept?
Five years for single-use packaging and ten years for reusable packaging, each counted from placing it on the market. Market surveillance authorities can request the records on demand, and they must then be presentable at short notice. A practical test: could you produce the complete documentation for ten randomly picked articles today?
What happens if the declaration of conformity is missing?
Missing or incomplete documentation is a formal non-conformity and therefore a standalone infringement — even where the packaging itself meets every product requirement. Market surveillance authorities can order corrective measures up to a ban on making available, withdrawal or recall; the level of fines is set by the member states.