Packaging and Packaging Waste Regulation · EU-wide

PPWR declaration of conformity, built from your packaging data

Since 12 August 2026 the manufacturer of any packaging placed on the EU market must assess it, draw up its technical documentation and sign an EU declaration of conformity. One file serves every EU country. Our platform builds it from the packaging data you already keep with us and the evidence your suppliers send.

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By Razvan Toma · Founder · Last checked 22 October 2026 · Sources below

What the regulation requires

Before placing packaging on the market, the manufacturer carries out the conformity assessment, draws up the technical documentation and, where conformity is shown, an EU declaration of conformity (Art. 15(2)). The assessment may be carried out on its behalf.
The procedure is internal production control, module A of Annex VII: no notified body and no certificate. The technical documentation describes the packaging, its materials and components, the standards or methods used, and the test reports and evidence.
The declaration follows the model of Annex VIII, is kept up to date, and is drawn up in, or translated into, the languages required by each Member State where the packaging is sold (Art. 39(2)). It is issued under the manufacturer's sole responsibility.
Kept for 5 years after the packaging is placed on the market, or 10 years if reusable (Art. 15(3)). An authorised representative appointed under Article 17 can keep both and answer the authorities, who may ask for documents within 10 days.
Suppliers of packaging and packaging materials must give the manufacturer all the information and documentation it needs (Art. 16).

Who is the manufacturer

The company that makes the packaging or the packaged product, or has it designed or made under its own name or trademark (Art. 3). If your brand is on the product, that is usually you, wherever your company is based. One exception: a micro-enterprise whose packaging supplier is in the same Member State; then the supplier is the manufacturer.

What the declaration covers today, and later

Requirement	From	Evidence
Heavy metals: lead, cadmium, mercury and hexavalent chromium together ≤ 100 mg/kg, per component (Art. 5(4))	12 August 2026	Supplier declaration or test report
PFAS in food-contact packaging: 25 ppb single, 250 ppb sum, 50 ppm total fluorine (Art. 5(5))	12 August 2026	Supplier declaration; test report for high-risk materials
Substances of concern minimised (Art. 5(1))	12 August 2026	Supplier information
Reusable packaging, where you place it on the market as reusable (Art. 11)	12 August 2026	Reuse assessment
Harmonised sorting label (Art. 12)	12 August 2028 at the earliest	Label
Recyclability, recycled content, minimisation, most other requirements	Mostly from 2030, once the implementing rules apply	Updated in the file as they apply

The manufacturer assesses only the requirements that apply when the packaging is placed on the market, and updates the declaration as new ones start to apply. Until 31 December 2029 the minimisation requirements of the old Packaging Directive still apply.

How it works in the platform

Your packaging, already thereThe materials and grams per product you entered for your EPR figures become the packaging description and component list of each file.
Your suppliers' evidenceFor each packaging we prepare the Article 16 request for your supplier: heavy metals, PFAS where it touches food, substances of concern, change notices. You record what comes back, with its date.
Checked against what appliesEach packaging shows what is missing before it can be signed: food contact without PFAS evidence, a reusable claim without its assessment, a component without a supplier.
Declaration and technical fileThe EU declaration in the Annex VIII model, in the languages of the countries you ship to (German, French, Spanish, Italian, Dutch and Polish from the official text; other languages translated on request), with its technical documentation, ready to print or save as PDF.
You sign, we keepYou check and sign. Where we are your authorised representative, we keep the file and answer the authorities for you. When a new requirement starts to apply, the file shows what to add.

What we do not do

We do not test packaging and we do not sign for you: the declaration is yours. Where a supplier cannot provide a declaration or a test report, we tell you which test is needed so you can order it from an accredited laboratory, or we arrange one and quote it first.

Price

The declaration and file builder is part of your EPR EU Rep account. Our review of your files, keeping them as your authorised representative, and translations into further languages are on quote.

Selling only into France? Our French site covers the PPWR with the French eco-organismes and mandataire in mind. PPWR on eprfrancerep.com ↗

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Tell us what you sell and how many packaging types you have. We reply within one working day.