PPWR declaration of conformity: who must issue it and what it must contain

Direct answer

The EU declaration of conformity is the manufacturer's own statement that its packaging meets the requirements of the PPWR. It is not a document issued by an authority and not a register filing. The manufacturer draws it up, keeps it together with the technical documentation and presents it to the competent authority on request. The Regulation has applied directly in all Member States since 12 August 2026.

If you are already registered under the German Packaging Act (VerpackG) and report quantities, registration does not change. A second obligation is added, and it concerns the packaging itself. The difference between the two is explained in the article on the declaration of completeness.

Manufacturer, producer, importer: who is who

The PPWR separates roles that are often mixed up in daily practice. The definitions sit in Article 3.

A single company can hold both roles at once: as the manufacturer for packaging conformity and as the producer for registration and system participation.

Who the obligation actually applies to

1. Own trademark, own responsibility. If packaging or a packaged product is designed or manufactured under your name or trademark, you are the manufacturer. It does not matter whether other trademarks also appear on the packaging.
2. Trademark holder as a micro-enterprise. If the trademark holder falls within the definition of a micro-enterprise and the supplier of the packaging is established in the Union, that supplier is treated as the manufacturer. The obligation shifts, it does not disappear.
3. Imports from third countries. An importer may place packaging on the market only if the manufacturer has carried out the conformity assessment procedure and drawn up the technical documentation. It has to verify this before placing the packaging on the market. Where an overseas supplier cannot be persuaded to release the documents, IHK Region Stuttgart recommends drawing up the declaration yourself so you can present it to the authority on request.

Suppliers of packaging or packaging material must give the manufacturer all information and documents needed to demonstrate conformity, including the technical documentation. The manufacturer may appoint an authorised representative. Drawing up the technical documentation remains its own task and cannot be transferred.

What the EU declaration of conformity must contain

Article 39 requires the declaration to follow the structure in Annex VIII, to contain the elements of the applicable module set out in Annex VII and to be kept up to date. Annex VIII divides it into eight points:

1. a unique identifier for the packaging,
2. the name and address of the manufacturer and, where applicable, of the authorised representative,
3. a statement that the declaration is issued under the sole responsibility of the manufacturer,
4. the subject of the declaration with a packaging identifier for traceability,
5. references to other Union acts applied,
6. the harmonised standards, common specifications or other technical specifications applied,
7. information on the notified body, where applicable, including the certificates issued,
8. additional information plus place, date, name, function and signature.

The declaration has to show which packaging it covers. Under Annex VII it is issued per packaging type.

The technical documentation under Annex VII

The technical documentation is the basis on which conformity can be assessed. The procedure is Module A, internal production control. Under Annex VII the documentation contains, to the extent relevant:

• a general description of the packaging and its intended use,
• design and manufacturing drawings and the materials of components,
• descriptions and explanations needed to understand those drawings and how the packaging works,
• a list of the harmonised standards, common specifications or other technical specifications applied, with the parts applied and the solutions chosen where a standard is not applied,
• a qualitative description of how the assessments of recyclability, recycled content, re-use and refill were carried out,
• test reports.

The documentation must include an adequate analysis and assessment of the risk of non-conformity.

Retention, evidence and language

• Retention: the technical documentation and the declaration of conformity are kept for five years for single-use packaging and ten years for reusable packaging, counting from the placing of the packaging on the market.
• Language: the declaration is drawn up in, or translated into, the language required by the Member State where the packaging is placed on the market or made available.
• Several acts: where more than one Union act requires a declaration of conformity, a single declaration is drawn up for all of them. It may consist of a dossier of individual declarations.
• Market surveillance: authorities check the conformity of a proportion of declarations each year on a risk basis. On a reasoned request, the documentation is provided within ten days.

According to IHK Region Stuttgart guidance, the declaration is not intended for customers or third parties but is presented to the competent authority on request. That is practical guidance from IHK materials and not the wording of the Regulation.

Why packaging data is the bottleneck

Both obligations, the conformity assessment under the PPWR and quantity reporting under the German Packaging Act, answer the same question: which packaging belongs to which product, made of which material and with which weight. If that mapping lives in separate spreadsheets, it has to be reassembled for the technical documentation, packaging type by packaging type.

That is why it pays to record packaging data once and link it to the product. The same basis is then available for every reporting period, and evidence does not have to be reconstructed from several files. How to set that up is described in how to structure packaging data for LUCID reporting.

Practical next steps

1. Check whether your packaging reaches the market under your own name or trademark. That decides whether you are the manufacturer.
2. Assign materials, components and weights to each packaging type so they can serve as the basis of the technical documentation.
3. Clarify with your packaging suppliers which evidence they can provide and record the answers in writing.
4. Set up your filing so that retention periods for single-use and reusable packaging stay separate.

Frequently asked questions

Is the PPWR binding?

Yes. Regulation (EU) 2025/40 has applied directly in all Member States since 12 August 2026 and replaces Directive 94/62/EC in this area. The article PPWR from August 2026 summarises what else changes.

Is there an official template?

Annex VIII of the PPWR sets out the structure the declaration must follow. A template does not replace the substantive assessment of your own packaging.

Are micro-enterprises exempt from the declaration?

Not in general. If the trademark holder falls within the definition of a micro-enterprise and the supplier of the packaging is established in the Union, that supplier is treated as the manufacturer. The obligation shifts, it does not disappear.