The PPWR Declaration of Conformity: What you need to know now

Contents:

• What is the PPWR and why is there now a declaration of conformity?
• What exactly is behind the PPWR declaration of conformity?
• What must be included in the declaration of conformity?
• Our recommendations for a smooth implementation

 

Key takeaways: The PPWR declaration of conformity is mandatory proof that packaging complies with the new EU requirements. From August 2026, certain companies will be required to provide a corresponding declaration for their packaging, including technical documentation. The declaration of conformity must address, among other things, the material composition, recyclability and recycled content of each type of packaging. Specifically, the declaration must address Articles 5 to 12 of the PPWR.

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The new EU Packaging Regulation, or PPWR for short, brings a breath of fresh air to the topic of packaging compliance. What was previously heavily regulated by national laws will now be more uniform across Europe. For many companies, this means new obligations, new processes and, above all, new documentation requirements.

A central element of the PPWR will be the so-called declaration of conformity. It is intended to ensure greater transparency in the supply chain and to prove that packaging complies with legal requirements and may be lawfully placed on the market in the EU. It sounds complicated, but with the right preparation, the issue can be easily integrated into existing processes. Here you can find out what the declaration of conformity entails, who it affects and what content is required.

 

What is the PPWR and why is there now a declaration of conformity?

With the Packaging and Packaging Waste Regulation (PPWR), the EU aims to regulate packaging in a more sustainable and recyclable manner and to standardise regulations across Europe. Instead of a directive that each country implements differently, a regulation will apply in all Member States in future.

To ensure that these new rules do not just exist on paper, clear proof of compliance is required. This is where the declaration of conformity comes into play. This is enshrined in Article 39 of the PPWR and is a written self-declaration. According to the definition in the PPWR, all producers are obliged to issue this declaration.

It is the official proof that packaging meets all relevant PPWR requirements: from material composition to recyclability. The declaration of conformity creates transparency, ensures uniform standards and is intended to enable authorities to specifically check compliance with the regulations.

 

What exactly is behind the PPWR declaration of conformity?

The declaration of conformity is a formal statement by the responsible company that a particular type of packaging complies with the requirements of the PPWR. It is based on a prior conformity assessment and technical documentation.

In other words, before packaging is placed on the EU market, it must be tested and documented to ensure that it meets all legal requirements. The result of this test is recorded in the declaration of conformity.

This declaration is not a one-off document to be filed away, but must be available at all times and presented to the competent authorities on request.

Who is affected by the declaration of conformity?

According to the PPWR, all producers who place packaging on the market are obliged to draw up a declaration of conformity. This obligation applies regardless of the type of packaging.

The obligation may also apply to distributors, for example, if they manufacture and distribute products under their own brand name. In this case, the producer obligations apply to them.

 

What must be included in the declaration of conformity?

For the declaration to be valid, it must contain certain minimum information. This includes, among other things:

• A clear identification of the packaging components
• Information about the responsible company
• A formal confirmation of PPWR compliance
• A reference to the technical documentation
• Information on applied standards or test procedures

IMPORTANT: The PPWR declaration of conformity must be retained for five years (ten years for reusable packaging) and must be available for presentation to the authorities upon request. This also includes the technical documentation.

What role does technical documentation play?

The declaration of conformity is only as good as the documentation behind it. All relevant information about the packaging is collected in the technical documentation, for example: material composition, recyclability, substances used, test reports, limit values and other technical evidence.

Requirements may vary depending on the type of packaging. It is important that the documentation clearly demonstrates why the packaging is considered PPWR-compliant.

When does the declaration of conformity become mandatory?

The PPWR came into force in 2025, and the new obligations it stipulates – including the declaration of conformity – will take effect on 12 August 2026.

IMPORTANT: The PPWR must be transposed into national law. EU countries are progressing at different speeds in this regard. Therefore, please keep a close eye on how the legal situation is developing in your export countries so that you do not miss important deadlines and decisions.

Companies therefore still have time to check their packaging, set up internal processes, collect data and define responsibilities. Especially for larger product portfolios, it is worth starting preparations early. Even though the PPWR applies directly in all EU countries, national regulations will not disappear. The declaration of conformity according to PPWR is therefore an additional requirement. In future, companies will have to meet both national and EU-wide requirements.

 

Our recommendations for a smooth implementation

Starting early means less stress later on. The following are particularly helpful:

• systematic recording of all packaging,
• the creation of clear technical documentation,
• clearly defined responsibilities,
• well-documented processes
• and external support if required.

 

And: As a manufacturer, if you are not the producer yourself, you should ensure that the producer of the packaging has a declaration of conformity when purchasing packaging and packaging materials.

The PPWR declaration of conformity is an important component of the new EU Packaging Regulation. It ensures greater transparency, uniform standards and better controls. Although it involves additional effort, it also means greater legal certainty and clarity.