What is the EU PPWR Declaration of Conformity (DoC)?

If your business supplies packaging to customers selling products in the EU, you need to understand the new Packaging and Packaging Waste Regulations (PPWR) now, not later.

The PPWR (Regulation (EU) 2025/40) is one of the most significant changes to packaging legislation in recent years. Its purpose is to reduce packaging waste, improve recyclability, encourage reuse, and create a more consistent approach to packaging compliance across all EU member states.

The previous Packaging and Packaging Waste Directive was implemented differently across countries, whereas the PPWR is a regulation with rules that apply directly across the EU, creating a more uniform framework for businesses.

One of the key requirements that is being introduced by the PPWR is the Declaration of Conformity (DoC). From 12 August 2026, every type of packaging that is placed on the EU market must be covered by a valid DoC. Without it, that packaging can’t legally be sold within the EU.

For manufacturers, brand owners, importers, and distributors, the DoC will become a central part of packaging compliance and documentation processes.

Historically, packaging legislation focused heavily on waste management and recycling targets after packaging had already entered the market. Whereas, the PPWR changes this approach by placing greater emphasis on proving compliance before packaging is sold or distributed.

A Declaration of Conformity (DoC) is a formal written statement confirming that a specific packaging type complies with the PPWR requirements.

Basically, a manufacturer declares that the packaging has been assessed and meets the relevant sustainability, recyclability, material, and design requirements set out within the regulation.

The DoC is a self-declaration rather than a certificate issued by an independent third party.

However, that does not make it any less important. By signing the document, the organisation issuing it accepts legal responsibility for the packaging’s compliance.

It is also important to understand what the DoC is not – it’s not a CE marking, nor is it a test certificate. The PPWR specifically separates packaging compliance from product CE marking requirements to avoid confusion.

Behind every Declaration of Conformity must be a complete technical file containing evidence, assessments, specifications, and supporting documentation demonstrating compliance.

The Declaration of Conformity relates to compliance with Articles 5 to 12 of the PPWR.

These articles cover many of the regulation’s core sustainability requirements and will increasingly shape how packaging is designed, specified, and manufactured.

The areas that are covered are:

• Restrictions on certain substances and materials.
• Packaging minimisation requirements.
• Reusable and refillable systems.
• Recyclability requirements.
• Recycled content targets.
• Packaging labelling obligations.
• Provisions relating to innovative packaging solutions.

 While some requirements apply from August 2026, others will be phased in over the following years as additional guidance and implementing measures are introduced.

This means that businesses will need processes in place to review and update documentation as packaging specifications and regulatory requirements evolve.

If you are a manufacturer, you are responsible for carrying out the conformity assessment process, preparing technical documentation, and issuing the Declaration of Conformity.

If you are an importer, you must complete these obligations before any packaging is placed on the market, keep any copies of the relevant documentation, and provide them to the authorities upon request.

If you are a distributor, you will have a more limited role but must still verify that packaging has been correctly labelled and that upstream compliance obligations have been met.

If packaging is sold under your company’s name or brand, you might be considered the manufacturer under the PPWR, even if another business physically produces it.

The distinction is important because the compliance responsibility follows the legal definition of manufacturer, not necessarily the company operating the manufacturing equipment.

The PPWR sets out a model structure for the Declaration of Conformity in Annex VIII.

Each declaration must contain sufficient information to clearly identify both the packaging and the organisation taking responsibility for compliance.

Required information includes:

• A unique declaration identification number.
• Manufacturer details and address.
• Details of any authorised representative.
• A statement accepting sole responsibility.
• Clear identification of the packaging concerned.
• A description of materials and packaging characteristics.
• Confirmation of compliance with Regulation (EU) 2025/40.
• References to applicable standards or specifications.
• Any relevant additional information.
• Signature, date, and place of issue.

 The declaration must relate to a specific packaging type. Generic statements covering broad product ranges are unlikely to satisfy the regulation’s requirements.

Each packaging format should be identifiable and traceable through the documentation.

Although the DoC requirement does not apply until 12 August 2026, preparation should begin well in advance.

First, you need to understand your role in the supply chain and identify whether your organisation will be responsible for issuing, obtaining, or retaining declarations.

Next, review your packaging portfolio and identify the different packaging types that will require documentation.

It’s also advisable to engage suppliers early and obtain material data, substance declarations, recyclability information, and technical evidence, which can take time, particularly across complex supply chains.

Many organisations are already creating internal systems to manage packaging specifications, supplier documentation, technical files, version control, compliance reviews, and document retention requirements.

Putting these processes in place now will help avoid significant administrative challenges as deadlines approach.

One of the most frequent mistakes is assuming existing certificates automatically satisfy PPWR requirements. Documents such as ISO certifications or food-contact declarations do not replace a PPWR Declaration of Conformity.

Avoid making broad statements that cover multiple packaging formats without clearly identifying the specific packaging.

Many organisations underestimate the importance of document management. Packaging specifications change regularly, and declarations may need to be updated as materials, suppliers, or regulatory requirements evolve.

The EU PPWR Declaration of Conformity represents a major change in how packaging compliance is managed across the EU. Rather than focusing solely on packaging waste after use, the regulation requires businesses to demonstrate compliance before packaging enters the market.

From August 2026, every packaging type placed on the EU market must be accompanied by a valid Declaration of Conformity and the supporting technical documentation.

Manufacturers, importers, distributors, and brand owners all have responsibilities in this process, making it essential to understand where your business fits within the supply chain.

For businesses supplying products to EU markets, now is the time to review your packaging specifications, engage suppliers, establish documentation procedures, and prepare for the new requirements.

If you would like guidance on the PPWR, sustainable packaging design, or preparing your packaging strategy for future compliance requirements, get in touch with our team of packaging experts at GWP today.