PPWR Declaration of Conformity: What Companies Need to Know
The PPWR countdown is on – from 12 August 2026, companies will be required to prepare a Declaration of Conformity for every individual packaging item. In this article, we summarize the key aspects of the PPWR Declaration of Conformity.
What is the PPWR Declaration of Conformity?
The Declaration of Conformity pursuant to Article 39 of the PPWR is a written self-declaration through which manufacturers demonstrate that their packaging complies with all applicable requirements of the new EU Packaging and Packaging Waste Regulation (PPWR). It becomes mandatory for every packaging item from 12 August 2026 onwards.
Other EU regulations also require declarations of conformity. However, these typically relate to product safety or requirements that apply specifically to medical devices or electrical equipment. The PPWR Declaration of Conformity, by contrast, applies exclusively to packaging.
Who Must Prepare the Declaration of Conformity?
All manufacturers within the meaning of the PPWR who place packaging on the market are required to prepare a Declaration of Conformity, regardless of the packaging type. This obligation applies to every packaging item from 12 August 2026, without any transitional period.
The legal role of the manufacturer was newly introduced by the PPWR and must be considered separately from the role of the producer. For more information on the distinction between producers and manufacturers, please see: Producer vs. Manufacturer.
What Does a Declaration of Conformity Look Like?
- Unique identification of the packaging (e.g. type, serial, or batch number)
- Contact details of the manufacturer
- Description and identification of the packaging to ensure traceability
- The statement: “This declaration of conformity is issued under the sole responsibility of the producer.”
- Declaration of compliance with all relevant PPWR requirements
- Additional information as required under Article 39 PPWR
The PPWR itself includes a template outlining the required structure of the declaration. You can access the official model declaration in Annex VIII of the regulation
What Is the Purpose of a PPWR Declaration of Conformity?
The declaration serves as evidence that a company has completed the conformity assessment procedure for its packaging and that the packaging complies with the relevant PPWR requirements.
By issuing the declaration, the manufactruer legally confirms compliance and can provide this proof to authorities, customers, and business partners upon request.
Does the Declaration of Conformity Need to Be Submitted?
No. The Declaration of Conformity does not need to be submitted proactively to any authority. However, it must be available at all times upon request, together with the corresponding technical documentation.
In addition, producers are required to keep the declaration up to date.
Retention periods are:
- 5 years for single-use packaging
- 10 years for reusable packaging
What Is the Difference Between the Declaration of Conformity and the Conformity Assessment Procedure?
- The conformity assessment procedure is the technical evaluation process used to demonstrate that packaging complies with PPWR requirements, such as recyclability, labeling, and traceability.
- The Declaration of Conformity is issued after the assessment procedure has been completed and officially confirms that the packaging is compliant, provided all applicable requirements have been met.
Who Is Responsible for the Declaration of Conformity for Private Label Products?
The company that markets a product under its own brand assumes the obligations as the manufacturer and is therefore responsible for the Declaration of Conformity.
This must be distinguished from the actual manufacturer or packaging producer, whose responsibility is to provide the necessary packaging-related information required to complete the conformity assessment and declaration process.
Which Companies Can Support the Creation of a PPWR Declaration of Conformity?
Noventiz supports companies in preparing PPWR-compliant Declarations of Conformity. To simplify this new obligation, we have developed a dedicated online solution that eliminates the need to manually create and manage individual declarations for each packaging item.
Only
days to go – the PPWR is coming!
The DoC Generator – Your Digital Solution for PPWR Declarations of Conformity
The DoC Generator by Noventiz is a web-based tool for the structured creation of PPWR-compliant Declarations of Conformity. Guided data entry helps you to compile all relevant information, which is then automatically converted into a legally compliant structure.
How the DoC Generator can help you:
- Legally compliant structure fully aligned with PPWR requirements
- Guided entry of all PPWR-relevant packaging data
- Automatic generation of the Declaration of Conformity pursuant to Article 39 PPWR
- GDPR-compliant storage and export via the customer platform
- Secure version control for both current and previous declarations
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Ensure your packaging meets PPWR requirements
The recyclability of packaging plays a central role in the PPWR regulation. This requires recyclable packaging with an increasing proportion of recyclate from 2030. Companies should therefore optimise their packaging design now in order to meet legal requirements and strengthen the circular economy.
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