The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, better known as PPWR, applies since 12 August 2026. Unlike the old Packaging Directive it replaces, PPWR applies directly in every member state, and it makes one document central to enforcement: the Declaration of Conformity, or DoC.
Key takeaways
- Since 12 August 2026, every packaging type placed on the EU market needs a Declaration of Conformity (Annex VIII model) backed by a technical file (Annex VII).
- Importers must hold the DoC for 5 years (single-use) or 10 years (reusable packaging) and answer authority requests within 10 days (Article 18).
- Importers selling under their own brand inherit manufacturer-level obligations (Article 21); distributors must verify a DoC exists (Article 19).
- The practical work is a component-level packaging registry. The DoC itself should be an export of that data, not a hand-assembled document.
What is the PPWR Declaration of Conformity?
The DoC is a formal, signed statement that a specific packaging type complies with the applicable requirements of Articles 5-12 of the PPWR: substance restrictions, recyclability, recycled content, minimisation, and reuse where relevant. It follows the model structure set out in Annex VIII of the regulation and must be backed by technical documentation prepared under Annex VII.
In practice the DoC is one page; the work lives in the technical file behind it. That file has to show, per packaging type, the data that proves each claim: materials and weights per component, recyclability assessment, recycled-content evidence, and test or supplier documentation for restricted substances.
Who must hold one, and for how long
ManufacturerDraws up the DoC and the technical file before placing packaging on the market.
ImporterVerifies the manufacturer's conformity assessment, holds a copy of the DoC: 5 years for single-use, 10 years for reusable packaging (Article 18).
Own brandImporters selling under their own brand take on manufacturer-level obligations (Article 21).
DistributorChecks that a DoC exists before making packaging available (Article 19).
Market surveillance authorities can request the DoC and technical documentation, and importers must be able to respond within ten days. That deadline is where email-and-folders systems fail: the document exists somewhere, but nobody can assemble the evidence trail in time.
What the Annex VIII model contains
The DoC identifies the packaging type and manufacturer, lists the PPWR requirements the packaging meets, references the harmonised standards or technical specifications used, and carries the signature of the responsible person. Every claim in it must trace to something in the technical file: a material specification, a recyclability grade, a supplier certificate, a test report.
How to prepare, step by step
- Build a component-level packaging registry: material, weight, format, recyclability, and recycled content for every component of every packaging type, not one row per SKU.
- Collect supplier evidence against each claim. A supplier's bare self-declaration is rarely enough on its own; PPWR expects documented proof behind it.
- Assess recyclability per item. PPWR grades recyclability from A to E, and the grade will also drive eco-modulated EPR fees.
- Generate the DoC and technical file from the registry, so the declaration is an export of your data rather than a document assembled by hand the week before an audit.
- Keep the evidence linked. When an authority asks, the answer should be one export, not a reconstruction project.
Your 30/60/90-day plan
30 daysRun the scope assessment, list every packaging type you place on the EU market, start the component-level registry for your highest-volume items.
60 daysSend structured supplier evidence requests, complete recyclability grading, close the biggest data gaps the registry reveals.
90 daysGenerate Declarations of Conformity and technical files from the registry, set retention (5/10 years), rehearse the 10-day authority response with one export.
Frequently asked questions
Does every packaging unit really need its own DoC?
Each packaging type placed on the market needs a DoC backed by a technical file. Identical packaging used across many products can share one DoC; materially different packaging cannot.
We import packaged goods. Is this our problem or the manufacturer's?
Both. The manufacturer draws up the DoC; as importer you must verify it exists, hold a copy for 5-10 years, and answer authority requests within 10 days. If you sell under your own brand, you inherit manufacturer obligations.
What happens if we don't have a DoC now that PPWR applies?
The packaging should not be placed on the EU market. Enforcement intensity will vary by member state, but the obligation has applied since day one, 12 August 2026, and retailers and marketplaces are asking suppliers for conformity documentation.
Next steps
Sources
The DoC as an export, not a project
Regtrue's PPWR module works exactly this way: a component-level registry, a rule engine that grades recyclability and checks recycled content and restricted substances, and a Declaration of Conformity plus technical file generated from your data with every claim tied to its evidence.
PPWR compliance software
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