This guide explains what the declaration must contain, who draws it up, how long it is kept, and what to request from a supplier.

Key Takeaways

  • Regulation (EU) 2025/40 (PPWR) has applied since 12 August 2026, and the manufacturer draws up an EU declaration of conformity for each packaging type.
  • The declaration follows a model in Annex VIII, backed by a technical file under the Annex VII procedure, which is internal production control.
  • The manufacturer is the company under whose name or trademark the packaging is placed on the market, even if another company makes or fills it.
  • Documents are kept for 5 years for single-use packaging and 10 years for reusable packaging, and authorities can ask for them within 10 days.
  • In Germany, the signed declaration can be held in German or English.

In This Article

What Is the PPWR Declaration of Conformity?

The declaration is a written statement by the manufacturer that the packaging meets the requirements that apply to it. Article 39 of the Regulation says it must state that compliance with Articles 5 to 12 has been demonstrated, follow the model structure in Annex VIII, contain the elements of the Annex VII procedure and be continuously updated.

By drawing it up, the manufacturer takes responsibility for the compliance of the packaging. That responsibility cannot be passed on by contract, according to the Commission’s PPWR FAQ, which is not binding.

What Must the Declaration of Conformity Contain?

Annex VIII sets out a model with these elements:

  1. a unique identification number of the declaration
  2. the name and address of the manufacturer and, where applicable, the authorized representative
  3. a statement that it is issued under the sole responsibility of the manufacturer
  4. the object of the declaration: an identification of the packaging that allows traceability, and a description
  5. the Union legislation the packaging complies with
  6. references to the harmonised standards or other specifications used
  7. where applicable, the notified body and its certificate
  8. additional information

It ends with a signature block: place and date of issue, and the name, function and signature of the person signing for the manufacturer. Annex VIII does not say which role must sign.

The declaration is written per packaging type. Where one packaging unit has several parts, such as a box, an insert and a label, the FAQ says a single assessment and declaration is enough for the unit as a whole, as long as it covers every part.

What Sits Behind the Declaration?

The manufacturer assesses conformity with the procedure in Annex VII, internal production control, and keeps a technical file. The file includes at least:

  • a general description of the packaging and its intended use
  • design drawings and the materials of the components
  • the standards or specifications used
  • a description of how the relevant assessments were carried out
  • test reports
  • an analysis of the risks of non-conformity

Compliance with the combined heavy metals limit of 100 milligrams per kilogram (Article 5 of the Regulation), and with the PFAS limits for food-contact packaging, is shown in this file. The limits apply from 12 August 2026. PFAS limits apply to food-contact packaging only, so a gift box for a pin set is outside them, while the heavy metals limit applies to all packaging.

Who Is the Manufacturer for Merchandise Packaging?

According to the FAQ, the manufacturer is the company under whose name or trademark the packaging is placed on the market, even where another company makes or fills it. If the packaging has no name or trademark, the manufacturer is whoever orders it and sets the design specification.

For merchandise this has a practical effect. If a club specifies the design of a gift box and has it produced, the club is likely the manufacturer. If a rights holder only licenses its crest and does not set the packaging characteristics, the FAQ says it should not be treated as the manufacturer. This is our reading of the FAQ’s general rules, because it gives no merchandise example, so agree the roles in writing. Our overview of PPWR for merchandise explains how the roles apply to common packaging.

Suppliers of packaging or materials are normally not manufacturers. They must give the manufacturer the information and documentation it needs, and cannot refuse. Importers must check that the non-EU manufacturer has done the assessment and keep a copy of the declaration, and distributors must check the labelling and identification.

How Long Must It Be Kept, and in Which Language?

Article 15 sets the retention at 5 years from placing on the market for single-use packaging and 10 years for reusable packaging. On a reasoned request, the manufacturer provides the documentation within 10 days, in electronic form, and in paper on request.

On language, Article 39 says the declaration is drawn up in, or translated into, the languages required by the Member State where the packaging is placed on the market. In Germany, the implementing act (VerpackDG, section 62) lets the manufacturer hold a signed declaration in German or English, with a German translation on the authority’s request.

What Happens If It Is Missing?

Under Article 62, a Member State must require the operator to correct a missing or incorrect declaration, or incomplete technical documentation. If the problem persists, it must take measures to prohibit the packaging from being made available, or ensure it is recalled. The Commission FAQ says authorities should first warn and support operators rather than follow a sanction-oriented approach, but that is guidance, and penalties are set nationally.

What Should a Buyer Request?

  • the signed declaration in Annex VIII form, with its identification number and the packaging identifier
  • confirmation of who the manufacturer is for each packaging type, with name and address
  • heavy metals test evidence for the 100 milligrams per kilogram limit
  • for food-contact packaging only, PFAS evidence
  • a commitment to keep the technical file for the required period and to update the declaration when the design changes

Ask for the same 10-day turnaround that authorities can demand. Our guide to quality control for metal merchandise lists the checks that belong to the product itself.

When Do the Later Requirements Start?

The declaration applies from 12 August 2026 and covers the requirements that already apply, mainly the substance limits. This is our reading of the Regulation and the FAQ, since no single sentence in the sources states it. Other requirements join later: minimization and recycled content from 2030, and harmonised labels from 12 August 2028 or 24 months after the implementing acts, whichever is later. Packaging placed on the market before 12 August 2026 can stay on the market.

Frequently Asked Questions

Who signs the declaration?

A person acting for and on behalf of the manufacturer. Annex VIII asks for name, function and signature but does not name a role.

Does a gift box for pins need a declaration?

Packaging placed on the market needs one, and the PFAS limits do not apply because the box is not food-contact packaging. Items that are an integral part of the product and disposed of with it are excluded, so check each case.

Can the supplier draw it up for us?

Only if the supplier is the manufacturer. A brand owner that is the manufacturer can have a laboratory or an authorized representative help, but the responsibility stays with the manufacturer.

Do old stocks need relabelling?

Packaging placed on the market before 12 August 2026 can remain on the market, according to the Commission FAQ, so it does not have to be withdrawn. The FAQ does not address relabelling separately, so check with your adviser.

Where do I find a template?

Annex VIII is the official model. We found no separate Commission template, and vendor templates should be checked against Annex VIII.

Conclusion

The declaration is short. The technical file behind it is not. Agree who the manufacturer is, ask for the declaration and the file, and keep both for the required period.

Reach out to discuss packaging documentation for your merchandise.