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EU declaration of conformity for packaging under PPWR (Annex VIII)

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Packaging that you place on the market under your own brand needs a document in which you take responsibility for it. It is called the EU declaration of conformity, and its form is not up to you: the Packaging and Packaging Waste Regulation (PPWR) prescribes eight points it must contain.

What is the EU declaration of conformity?

It is a written document in which the manufacturer confirms, under its sole responsibility, that the packaging meets the requirements of Regulation (EU) 2025/40. The obligation to draw it up comes from Article 15(2); its content and model are set by Article 39 and Annex VIII. The declaration on its own proves nothing. It is a statement, and the evidence behind it is the technical documentation under Annex VII. During an inspection, the market surveillance authority asks for both, and a declaration without supporting documents is not enough.

Who issues the declaration?

The manufacturer. Under Article 3(1), point (13), this is not only the company that physically makes the packaging, but also the one that has it designed or manufactured under its own name or trademark and places it on the market. In practice: if a printing house produces boxes with your logo, you are the manufacturer of that packaging, not the printing house. The printer supplies input for the technical documentation, but you sign the declaration.

Note that alongside the manufacturer, the regulation also uses the term producer (Article 3(1), point (15)), which belongs to extended producer responsibility. These are two different roles with different obligations, and one company can be both at the same time.

Exception for micro-enterprises

Article 15(12) contains a rule worth knowing. If you are a micro-enterprise (fewer than 10 employees and an annual turnover or balance sheet total of up to EUR 2 million), you have packaging made under your own name, and your supplier is located in the Union, the supplier is considered the manufacturer for the purposes of Article 15. The obligation does not disappear, you just do not carry it. A similar rule appears in the definition of manufacturer itself, in Article 3(1), point (13)(b), but with a stricter condition: the supplier must be located in the same Member State. The two conditions are not interchangeable, so check which one applies to you.

The eight points of Annex VIII

Annex VIII contains the model declaration with eight numbered points. It is not a recommended outline but a prescribed structure.

  1. Unique identification of the packaging. A number under which you can find the packaging in your own records.
  2. Name and address of the manufacturer and, where applicable, its authorised representative.
  3. A statement that the declaration is issued under the sole responsibility of the manufacturer. This sentence is copied into the document word for word. In practice it is the one most often left out, yet it is exactly what turns the document into a declaration.
  4. Object of the declaration: a description of the packaging that allows traceability.
  5. Conformity with the relevant Union harmonisation legislation. This is not a list of PPWR articles, but references to other Union acts that apply to the packaging.
  6. References to the harmonised standards or common specifications used, or to other technical specifications.
  7. The notified body, where one was involved. Under module A this point stays empty, but it remains in the document.
  8. Additional information, signature, place and date of issue.

Annex VIII has no separate field for a reference to the technical documentation. Templates that include one add it on top. That is not a mistake, but it is not required either.

In which language?

Under Article 39(2), the declaration must be drawn up in, or translated into, the language or languages required by the Member State in which the packaging is placed on the market or made available. If you sell the same packaging in several EU countries, you need the declaration in each of their languages. Where the packaging or packaged product falls under more than one Union act requiring an EU declaration of conformity, a single declaration covering all of them is drawn up (Article 39(3)).

Keeping and providing the declaration

Under Article 15(3), the manufacturer keeps the declaration and the technical documentation for 5 years for single-use packaging and 10 years for reusable packaging, counted from the date the packaging was placed on the market. The same applies to importers under Article 18(7). You do not send the declaration anywhere automatically. Upon a reasoned request from a national authority, however, you must make it available within 10 days, in a language that authority can easily understand (Article 15(10)).

When to update the declaration

It is not a one-off document. Article 39(2) requires it to be continuously updated. An update is due whenever the packaging changes (material, dimensions, print, supplier) and also when the Commission adopts a delegated or implementing act that specifies the requirements further. The practical solution is versioning: declaration v1.0, v1.1 and so on, with the version history kept.

Sample EU declaration of conformity

See what a complete declaration following Annex VIII looks like: download the sample PDF (DoC-OB-001). The matching sample technical documentation shows the evidence behind it.

Frequently asked questions

Who signs the EU declaration of conformity?

The manufacturer of the packaging, meaning the company that places it on the market under its own name or trademark. If a printing house produces boxes with your logo, you are the manufacturer, not the printing house.

How long do I have to keep the declaration?

5 years for single-use packaging and 10 years for reusable packaging, from the date the packaging was placed on the market. This follows from Article 15(3) of the regulation.

Do I have to send the declaration to anyone?

Not automatically. Upon a reasoned request from a national authority, however, you must make it available within 10 days in a language that authority can easily understand.

In which language must the declaration be?

In the language or languages required by each Member State where the packaging is placed on the market or made available (Article 39(2)). Selling in three countries can mean three language versions.

Is there an exception for micro-enterprises?

Under Article 15(12), the supplier is considered the manufacturer if the company that has the packaging made under its own name is a micro-enterprise and the supplier is located in the Union. So the obligation does not disappear, it is carried by the supplier.

How ELO handles it

The PPWR module in ELO guides the manufacturer through a structured form based on Annex VII and generates both the technical documentation and the EU declaration of conformity from the data entered, in English and 21 other EU languages. For every line of the assessment, it records whether it was carried out internally or externally and by whom, which is exactly what you need to prove during an inspection.

Try ELO for free on your first packaging →

Related

Sources

Regulation (EU) 2025/40 of the European Parliament and of the Council, English version on EUR-Lex: Article 3(1), points (13) and (15), Article 15(2), (3), (10) and (12), Article 18(7), Articles 38 and 39 and Annex VIII. This text is for information only and does not replace legal advice. The current wording of the regulation always prevails.