PPWR Declaration of Conformity Guide 2026

The EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, applies from 12 August 2026. For businesses placing packaged products on the EU market, one of the most important changes is that packaging compliance is becoming a documented conformity process.

A PPWR EU Declaration of Conformity should not be treated as a form that can simply be downloaded, completed and signed. The declaration is the final output of a broader compliance process involving packaging identification, applicability assessment, supplier information, technical documentation, conformity assessment, traceability, and ongoing compliance controls.

EaseCert has prepared a practical PPWR EU Declaration of Conformity (DoC) Template to help manufacturers structure the declaration required under Regulation (EU) 2025/40.

Download the EaseCert PPWR EU Declaration of Conformity (DoC) Template

EaseCert PPWR EU Declaration of Conformity Template

Start With Product Safety Before Packaging Compliance

Before addressing Packaging EPR or PPWR, businesses should first establish whether the underlying product complies with the applicable EU product-safety legislation.

For many consumer products, this means compliance with the General Product Safety Regulation (EU) 2023/988 (GPSR). Other products may instead or additionally fall under sector-specific EU legislation.

Depending on the product, the product-safety assessment may involve:

product risk assessment;
technical documentation;
testing where applicable;
product identification and traceability;
manufacturer and importer information;
EU Responsible Person requirements;
safety warnings and instructions;
marketplace information requirements;
corrective-action procedures;
recalls and withdrawals; and
other product-specific regulatory requirements.

Packaging compliance does not make a non-compliant product legal. Likewise, Packaging EPR registration or a German LUCID number does not demonstrate compliance with EU product-safety requirements.

EaseCert therefore follows the compliance sequence: Product Safety → EPR / WEEE / Batteries → PPWR.

EaseCert provides environmental compliance services for products that have first been certified by EaseCert for the applicable EU product-safety requirements.

GPSR, Packaging EPR and PPWR Are Separate Legal Systems

Businesses often group GPSR, Packaging EPR, LUCID, recycling labels and PPWR together under the general heading of “EU compliance.” Legally, however, they address different obligations.

GPSR and Product Safety

Product-safety legislation addresses matters such as:

whether a product is safe;
risk assessment;
technical documentation;
testing;
warnings and instructions;
traceability;
responsible economic operators;
market surveillance;
recalls; and
withdrawals.

Extended Producer Responsibility

Packaging EPR concerns responsibility for packaging waste in individual EU Member States. Depending on the country and supply chain, obligations can include:

producer registration;
participation in a Producer Responsibility Organisation or recycling system;
packaging quantity reporting;
material classification;
environmental contributions or recycling fees;
national EPR registration numbers;
marketplace verification;
national environmental labelling; and
recordkeeping.

PPWR Packaging Conformity

PPWR establishes EU-level requirements concerning the packaging itself, including requirements relating to:

substances in packaging;
recyclability;
recycled content in plastic packaging;
compostable packaging;
packaging minimisation;
reusable packaging;
packaging labelling;
conformity assessment;
technical documentation;
manufacturer obligations; and
EU Declarations of Conformity.

A company can therefore be correctly registered for German LUCID or another Packaging EPR system while still being non-compliant with GPSR or PPWR.

What Is the PPWR EU Declaration of Conformity?

The EU Declaration of Conformity is the manufacturer’s formal declaration that conformity with the applicable PPWR requirements has been demonstrated for the packaging concerned.

The PPWR conformity framework is established principally through Articles 38 and 39, together with Annex VII and Annex VIII of Regulation (EU) 2025/40.

Annex VII establishes the conformity-assessment procedure based on internal production control. Annex VIII sets out the structure of the EU Declaration of Conformity.

The Declaration of Conformity is therefore not the entire compliance assessment. It is the formal declaration produced after the manufacturer has established and documented the basis for conformity.

Who Is Responsible for the Declaration?

PPWR places responsibility for the EU Declaration of Conformity on the manufacturer.

Businesses should not automatically assume that the factory physically producing an empty carton, bottle, pouch, tray or other packaging component is necessarily the PPWR manufacturer responsible for the finished packaging.

The economic-operator assessment should consider factors including:

who determines the packaging design;
whose name or trademark the packaging is marketed under;
who has the packaging or packaged product manufactured;
whether a specific PPWR exception applies;
whether an importer or distributor modifies the packaging;
where the relevant economic operators are established; and
how the packaging enters the EU market.

A statement such as “our supplier manufactured the carton, so the supplier is responsible for PPWR” should therefore not be accepted without analysing the actual PPWR manufacturer role.

PPWR Manufacturer and EPR Producer Are Not Necessarily the Same Company

One of the most important concepts for international sellers is the distinction between a PPWR manufacturer and an EPR producer.

The manufacturer is responsible for the conformity of the packaging with applicable PPWR sustainability and labelling requirements.

The producer, by contrast, is the economic operator responsible for Extended Producer Responsibility in the relevant Member State.

Depending on the supply chain, EPR producer status can fall on a manufacturer, importer, distributor, distance seller or another qualifying economic operator.

Producer status should therefore be assessed using factors such as:

manufacturer location;
seller location;
branding;
packaging type;
destination Member State;
B2B or B2C supply;
marketplace sales;
direct-to-consumer sales;
importer and distributor structure; and
whether packaged products are supplied directly to end users.

What Should Happen Before the PPWR Declaration Is Signed?

A practical compliance process should generally follow this sequence:

Identify the packaging.
Identify the PPWR manufacturer.
Determine which PPWR requirements apply.
Identify the relevant application dates.
Collect supplier information and evidence.
Assess the packaging against the applicable requirements.
Prepare the technical documentation required by Annex VII.
Prepare the EU Declaration of Conformity under Annex VIII.
Establish procedures for ongoing conformity and change control.

Skipping directly to the declaration creates significant compliance risk because the manufacturer needs documentary evidence supporting the statements being signed.

Use the EaseCert PPWR EU Declaration of Conformity Template

EaseCert’s PPWR EU Declaration of Conformity Template is designed to help manufacturers structure the declaration and connect it directly with the supporting technical documentation.

The template contains eight principal sections:

Unique identification of the packaging
Manufacturer
Sole responsibility
Object of the declaration
Statement of conformity
Harmonised standards, common specifications and other technical specifications
Notified body
Additional information

Download the EaseCert PPWR EU Declaration of Conformity Template

Section 1: Unique Identification of the Packaging

The first section of the EaseCert template identifies exactly which packaging is covered by the declaration.

The template provides fields for:

packaging identification;
packaging reference or SKU; and
revision or version.

This information is important because the declaration should be traceable to a defined packaging type rather than vaguely covering “all packaging used by the company.”

Section 2: Manufacturer

The EaseCert template asks for the manufacturer’s:

legal name;
trade name or brand, where applicable;
registered address; and
compliance contact details.

It also includes a separate section for the manufacturer’s authorised representative where applicable.

Section 3: Sole Responsibility

The template makes clear that the EU Declaration of Conformity is issued under the sole responsibility of the manufacturer.

EaseCert can assess documentation, structure the compliance process and support preparation of the declaration, but the manufacturer remains responsible for issuing the declaration.

Section 4: Object of the Declaration

The object of the declaration should be described sufficiently to allow the packaging to be traced.

The EaseCert template includes fields for:

GTIN, packaging reference, batch or equivalent identifier;
a concise packaging description;
individual packaging components;
the packaged product where relevant;
technical-documentation reference; and
drawing or image reference.

Think in Terms of the Complete Packaging System

A typical packaged product may involve several packaging components, including:

a bottle, jar, pouch or tray;
a closure;
a printed label or sleeve;
a cardboard sales carton;
an insert;
protective film;
grouped packaging; and
transport packaging.

These elements may need to be assessed individually within the technical documentation even where they form part of one commercial packaging system.

Section 5: Statement of Conformity

The EaseCert template addresses conformity with the applicable requirements laid down in or pursuant to Articles 5 to 12 of Regulation (EU) 2025/40, taking account of the packaging concerned, applicable dates and transitional provisions.

This qualification is important because PPWR applies from 12 August 2026, but individual requirements do not all become applicable on that same date.

Businesses should therefore avoid declaring every future PPWR requirement already applicable simply because PPWR itself has started to apply.

Section 6: Standards, Specifications and Assessment Methods

The EaseCert template provides space for recording:

the technical reference;
the relevant standard, method or specification; and
the PPWR requirement addressed.

Where applicable PPWR harmonised standards or common specifications have not been used, the solutions and assessment methods relied upon should instead be documented in the technical documentation prepared under Annex VII.

Businesses should not simply insert standard numbers into the declaration because they appear relevant. Every referenced standard, method or technical specification should have a defensible relationship to the conformity assessment.

Section 7: Notified Body

The EaseCert template records the notified-body section as not applicable unless notified-body involvement is required under other applicable Union legislation included in the declaration.

PPWR’s internal-production-control conformity procedure should therefore not be confused with a mandatory third-party certification system.

EaseCert support does not constitute EU approval, government approval or notified-body certification.

Section 8: Additional Information and Applicable-Requirements Record

One of the most useful parts of the EaseCert template is the applicable-requirements record.

It creates a direct connection between the Declaration of Conformity and the manufacturer's supporting technical documentation for Articles 5 to 12.

PPWR Requirement	Status to Assess	Technical Documentation
Article 5 — Requirements for substances in packaging	Applicable / Not applicable / Future requirement	Technical documentation reference
Article 6 — Recyclable packaging	Applicable / Future requirement / Exemption if substantiated	Technical documentation reference
Article 7 — Minimum recycled content in plastic packaging	Applicable / Future requirement / Not applicable / Exemption	Technical documentation reference
Article 8 — Bio-based feedstock in plastic packaging	Applicable status	Technical documentation reference
Article 9 — Compostable packaging	Applicable / Not applicable	Technical documentation reference
Article 10 — Packaging minimisation	Applicable / Future requirement	Technical documentation reference
Article 11 — Reusable packaging	Applicable / Not applicable / Future requirement	Technical documentation reference
Article 12 — Labelling of packaging	Applicable / Future requirement	Technical documentation reference

A requirement should only be recorded as compliant where that conclusion is supported by the manufacturer’s technical documentation.

Where an obligation depends on a future application date, delegated act, implementing act, harmonised standard or other PPWR measure, it should be identified accordingly rather than treated as already applicable.

The Technical Documentation Comes Before the Declaration

The most important part of a PPWR compliance system is the evidence supporting the signed declaration.

Annex VII requires technical documentation that makes it possible to assess conformity with the applicable requirements. The documentation also needs to address the risk of non-conformity.

Depending on the packaging concerned, the technical documentation may include:

general description of the packaging;
packaging specifications;
material composition;
component structure;
drawings and technical descriptions;
supplier declarations;
substance information;
recycled-content information;
recyclability assessments;
packaging-minimisation assessments;
reuse assessments where applicable;
relevant standards and specifications;
analytical methods;
test reports;
exemption assessments where applicable; and
records supporting the final conformity conclusion.

Supplier Declarations Alone Are Not the Technical File

Packaging and material suppliers are important sources of PPWR compliance information. Manufacturers may need information concerning:

material composition;
polymers;
recycled content;
coatings;
inks;
adhesives;
barrier layers;
additives;
substances;
food-contact properties;
technical specifications; and
test results.

However, receiving a supplier document titled “PPWR Declaration” does not automatically complete the manufacturer’s legal assessment.

What Should Be Checked?

Exactly which packaging does the document cover?
Which material revision was assessed?
Does it correspond to the finished packaging configuration?
Is supporting evidence available?
Is the cited legislation correct?
Are cited standards and methods appropriate?
Is the information current?
Could components supplied by other companies affect conformity?

Supplier evidence feeds into the manufacturer’s technical file. It does not automatically replace the manufacturer's conformity assessment.

Assess Articles 5 to 12 Correctly

Article 5: Substances in Packaging

PPWR includes requirements concerning substances present in packaging, including restrictions affecting specified heavy metals and requirements relating to certain PFAS in food-contact packaging.

Appropriate supporting evidence may include supplier specifications, chemical declarations, test reports, food-contact documentation and other relevant analytical evidence.

PPWR compliance does not replace separate obligations under applicable EU food-contact materials legislation.

Article 6: Recyclable Packaging

Recyclability is one of PPWR’s central requirements. Companies should avoid relying solely on broad claims such as “100% recyclable” when preparing the regulatory assessment.

The actual packaging configuration may require consideration of:

base material;
multilayer structures;
labels;
sleeves;
closures;
adhesives;
inks;
barriers;
coatings;
additives;
component separation; and
compatibility with relevant recycling processes.

Article 7: Minimum Recycled Content in Plastic Packaging

PPWR introduces minimum recycled-content requirements for specified plastic packaging categories according to the dates established in the Regulation.

Companies using plastic packaging should begin establishing reliable information covering:

polymer type;
component weight;
recycled material content;
post-consumer recycled content;
supplier evidence;
relevant exemptions;
food-contact restrictions; and
traceability.

Article 8: Bio-Based Feedstock in Plastic Packaging

Article 8 should also be included in the PPWR applicability review for plastic packaging. The EaseCert Declaration of Conformity template includes a dedicated Article 8 line so that its status can be linked to the relevant technical documentation.

Article 9: Compostable Packaging

PPWR introduces specific compostability requirements for certain packaging categories. This should not be interpreted as a general requirement that all packaging become compostable.

Businesses need to determine whether their packaging falls within the categories addressed by Article 9 and whether any Member State flexibility is relevant.

Article 10: Packaging Minimisation

PPWR moves packaging minimisation toward a documented technical requirement. Businesses should be able to explain why packaging weight, volume and protective components are necessary.

Relevant considerations can include:

product protection;
safety;
hygiene;
logistics;
transport;
manufacturing requirements;
mandatory information;
packaging functionality; and
other legitimate performance criteria.

Article 11: Reusable Packaging

Describing packaging as “reusable” does not by itself establish PPWR compliance. The technical assessment should consider the packaging design, intended use and relevant reuse-system requirements.

Article 12: Packaging Labelling

PPWR introduces harmonised EU packaging-labelling requirements, but individual obligations apply according to their specified application dates and implementing measures.

Businesses should determine:

which labelling requirement applies;
the packaging category concerned;
the relevant application date;
whether required implementing measures have been adopted;
whether digital information is permitted or required; and
whether separate national environmental-labelling requirements remain applicable.

PPWR packaging labelling should not be confused with national obligations such as French Triman and Info-Tri requirements.

Be Ready to Produce the Technical Documentation

PPWR is not designed around a declaration that exists in isolation. Companies should maintain their supporting documents in a controlled compliance repository so that information can be retrieved efficiently when requested by a competent authority.

Technical evidence spread across supplier emails, former employees’ folders, laboratories, design agencies and packaging factories may be difficult to produce during a regulatory request.

Each packaging reference should therefore be linked to a controlled technical file.

The Declaration of Conformity Must Be Maintained

A Declaration of Conformity should not be treated as a document that is signed once and forgotten.

Packaging specifications can change through modifications to:

resin supplier;
paper grade;
recycled-content percentage;
ink;
coating;
adhesive;
barrier layer;
label;
closure;
dimensions;
material weight;
manufacturing site; or
packaging supplier.

Any change capable of affecting conformity should trigger a review of the technical assessment and, where necessary, the Declaration of Conformity.

Importers Also Have PPWR Responsibilities

An EU importer should not assume that its obligations end because a non-EU manufacturer has supplied a Declaration of Conformity.

Before placing packaging on the EU market, importers need to address the PPWR obligations applicable to them, including relevant verification of the manufacturer’s conformity documentation and traceability information.

Where packaging is believed to be non-compliant, a signed declaration should not be treated as sufficient evidence to disregard that concern.

PPWR Does Not Replace Packaging EPR

Once product safety has been established, businesses should separately analyse national Packaging EPR obligations.

EPR remains connected to national producer registration, reporting, recycling and financing systems.

Germany

Businesses supplying packaged products in Germany may need to address LUCID registration and German packaging-system obligations.

LUCID Registration Support for Packaging Compliance in Germany (€400,00 EUR)

France

French requirements can include Packaging EPR as well as national consumer sorting information such as Triman and Info-Tri requirements.

France EPR Packaging Compliance & Triman (Info-Tri) Labelling Guidance (€400,00 EUR)

Italy

Businesses supplying packaged products into Italy should assess the applicable CONAI and packaging EPR obligations.

Italy Packaging EPR / CONAI Compliance Service (€400,00 EUR)

Spain

Businesses selling packaged products in Spain should separately assess Spanish Packaging EPR obligations.

Spain Packaging EPR Compliance Service (€400,00 EUR)

Other EU Member States

EaseCert can also support Packaging EPR compliance in other Member States, including Poland, Hungary, Czechia, Romania, Sweden, the Netherlands and Portugal.

EU Packaging EPR Compliance Service (€400,00 EUR)

EaseCert is not a Producer Responsibility Organisation, recycling company, waste collector, dual-system operator or government authority.

Where a customer must register directly with an authority, enter into a recycling or PRO contract, file statutory reports, or pay recycling contributions, environmental fees or authority charges, those obligations remain with the customer unless expressly included within the relevant EaseCert service.

Electrical Products May Also Require WEEE Compliance

If the packaged product is electrical or electronic equipment, Packaging EPR and PPWR may only be part of the environmental compliance picture.

Separate WEEE obligations can include:

producer registration;
national representation;
reporting;
financing obligations;
marking;
take-back arrangements; and
marketplace requirements.

For products that EaseCert has first certified for the applicable EU product-safety requirements:

WEEE Registration Service for EU Compliance (€500,00 EUR)

Products containing batteries may also trigger separate EU and national battery obligations.

Common PPWR Declaration of Conformity Mistakes

Signing Before Completing the Conformity Assessment

The declaration should document a conformity conclusion already supported by evidence.

Identifying the Wrong Manufacturer

The physical packaging factory is not automatically the manufacturer responsible for the finished PPWR declaration.

Using One Vague Declaration for an Entire Product Catalogue

The packaging covered by the declaration needs to be identifiable and traceable.

Having No Supporting Technical Documentation

A signed declaration without supporting evidence is not a complete conformity system.

Treating Supplier Documentation as the Entire Technical File

Supplier information is evidence used in the manufacturer’s assessment. It does not automatically replace that assessment.

Applying the Wrong Legal Dates

PPWR applies from 12 August 2026, but individual requirements may have later application dates.

Confusing PPWR With Packaging EPR

A PPWR Declaration of Conformity does not replace producer registration, PRO participation, reporting or national environmental fees.

Ignoring Product Safety

PPWR packaging conformity never substitutes for GPSR or applicable sector-specific product-safety compliance.

PPWR Declaration of Conformity Readiness Checklist

Has the underlying product’s EU product-safety status been established?
Have all relevant packaging types been identified?
Has the PPWR manufacturer been correctly determined?
Have importer and authorised-representative roles been assessed where relevant?
Have the applicable Articles 5 to 12 requirements been identified?
Have future application dates been recorded?
Has the necessary supplier information been obtained?
Are controlled packaging specifications available?
Are all relevant packaging materials and components identified?
Have substance requirements been assessed?
Has recyclability been considered according to the applicable PPWR framework?
Have relevant exemptions been documented?
Are supporting test reports available where applicable?
Have standards and technical specifications been correctly identified?
Has the risk of non-conformity been assessed?
Does the declaration clearly identify the packaging it covers?
Does the declaration follow the Annex VIII structure?
Can the supporting technical documentation be retrieved quickly?
Is there a packaging change-control procedure?
Have national Packaging EPR obligations been separately assessed?
Have WEEE and battery obligations been assessed where relevant?

How EaseCert Helps With PPWR Compliance

EaseCert provides practical regulatory assessment and implementation support for companies placing products and packaging on the EU market.

Step 1: Product Safety

EaseCert first assesses the applicable EU product-safety requirements, including GPSR or applicable sector-specific legislation.

Step 2: EPR, WEEE and Batteries

For products first certified by EaseCert for the applicable EU product-safety requirements, EaseCert can then support relevant environmental compliance, including:

Packaging EPR;
Germany LUCID;
France Packaging EPR and Triman / Info-Tri;
Italy CONAI;
Spain Packaging EPR;
other national Packaging EPR systems;
WEEE; and
battery compliance where applicable.

Step 3: PPWR

EaseCert can then support the PPWR conformity process through the:

PPWR Compliance Service (€500,00 EUR)

Depending on the packaging and supply chain, support can include:

PPWR manufacturer assessment;
economic-operator assessment;
packaging classification;
Articles 5 to 12 applicability assessment;
application-date assessment;
supplier-documentation review;
technical-documentation structure;
conformity-assessment implementation support;
EU Declaration of Conformity preparation and review;
traceability review;
packaging-labelling review;
packaging-minimisation planning;
recyclability preparation;
recycled-content preparation;
EPR producer-status assessment; and
coordination between PPWR and national Packaging EPR obligations.

The EaseCert PPWR EU Declaration of Conformity Template can be used as part of this structured compliance process.

Download the EaseCert PPWR EU Declaration of Conformity (DoC) Template

The Declaration Is the Last Page of the Process, Not the First

The most important practical lesson is simple: do not begin with the signature; begin with the evidence.

A defensible PPWR conformity process should establish:

who is responsible;
which packaging is being assessed;
which requirements apply now;
which requirements apply later;
what evidence supports conformity;
where that evidence is retained; and
how conformity will be reassessed when the packaging changes.

Only once those questions have been addressed should the EU Declaration of Conformity be finalised and signed.

For businesses selling products across multiple EU Member States, the strongest approach is to coordinate product safety, EPR and packaging conformity while maintaining the legal distinction between each compliance system.

EaseCert's compliance sequence:
Product Safety → EPR / WEEE / Batteries → PPWR

Need Help Preparing for PPWR?

EaseCert helps businesses build a practical PPWR compliance system around their actual products, packaging, suppliers and EU sales structure.