PPWR Declaration of Conformity step by step

The Declaration of Conformity decides whether a packaging item may legally reach the European Union market. It is not paperwork to tidy up afterwards — without it the packaging is non-compliant from the first day of sale, and an authority can order the product off the shelf.

Below is the practical path: who is liable, what the document contains, and in what order to gather the data so you do not stall at the point where one supplier figure is missing.

Who issues the Declaration of Conformity

The declaration is issued by the entity placing the packaging on the market — whoever first makes it available in the Union. In practice that is the beverage producer, the brand owner or the importer, not the manufacturer of the board or the closure.

That distinction causes expensive misunderstandings. A packaging supplier provides data and its own material documentation, but liability for the declaration sits with whoever places the finished product on the market. If the supplier is outside the EU, the burden passes entirely to the importer.

What the declaration contains

PPWR sets out the template in Annex VII. The typical structure of an EU conformity document covers:

• unambiguous identification of the packaging concerned, precise enough to reconstruct it from the document
• name and address of the entity placing it on the market
• a statement that the packaging meets the requirements of the regulation
• reference to the standards and technical specifications applied
• place and date of issue, and the signature of an authorised person

Behind the declaration there must be technical documentation that justifies it: material composition, weight, restricted-substance test results and a recyclability assessment. A declaration without documentation is an assertion with nothing behind it.

Step 1: inventory your packaging

You cannot issue a single declaration without a list. Start by compiling every packaging item you place on the market, including the grouped and transport packaging that is easy to forget.

For each item you need: material, weight in grams, supplier, function (sales, grouped, transport) and the markets it reaches. This is usually the most laborious stage and the one that cannot be skipped — every later step rests on this list.

Step 2: supplier data

With the list in hand you go to your suppliers. You need material data sheets, information on restricted substances (lead, cadmium, mercury, hexavalent chromium) and confirmation that food-contact packaging is free of PFAS.

This is where the process usually stalls. Suppliers answer late or send documents in a format that adds little. It pays to prepare one form and send it to everyone at once rather than running dozens of separate email threads.

Step 3: conformity assessment

Here you check whether the packaging meets the requirements: restricted substances within limits, recyclability grade at the required level, and from 2030 also the empty-space cap and recycled content in plastic packaging.

The material decides how much of this applies to you at all. Packaging made from a single cellulose fibre stream is not subject to the recycled-content thresholds set for plastics, because it returns to the paper stream — for which PPWR sets design requirements rather than feedstock quotas.

Step 4: issue and retain

An authorised person signs the declaration, and the document is retained together with the technical documentation for the period the regulation requires. During an inspection the authority asks for both at once — the declaration alone will not do.

The declaration must be updated whenever the packaging changes: a different supplier, a different grammage, a modified structure. In practice that means the process does not end when the documents are first issued.

The most common mistakes

• Skipping grouped and transport packaging. A shipping case and pallet wrap are packaging under the regulation too.
• Relying on the supplier's declaration. The supplier's document covers their component, not your packaging as a whole.
• A declaration with no technical documentation. The most common reason an inspection fails.
• No update after a supplier change. A change of material invalidates the earlier assessment.

Questions and answers

Related material

Informational material. Not legal advice — verify the facts of your own packaging before acting.
← All PPWR material