The PPWR declaration of conformity is not a form to download, fill in and file away: it is a body of evidence to build before you sign it. Regulation (EU) 2025/40 requires the packaging manufacturer to draw up an EU declaration of conformity attesting that the applicable requirements are met. But a declaration is only as good as what supports it: material composition, recycled content, substances of concern, test results, component conformity. And this information comes, for the most part, from your suppliers.
By Gautier VeyssetIndustry specialist writer at Tracklab · LinkedInUpdated 13 Oct 202614 min read5 sources citedThis guide is aimed at Quality, Regulatory, Purchasing and R&D teams. It describes what a declaration contains, the evidence to gather, the errors that invalidate it and how to collect that evidence across a whole packaging portfolio.
The PPWR declaration of conformity (or EU declaration of conformity) is the act by which the packaging manufacturer declares, under its own responsibility, that a packaging meets the applicable requirements of Regulation (EU) 2025/40. It comes before the placing on the market of the packaging or the packaged product.
The Regulation organises the conformity assessment upstream of the declaration: the manufacturer checks that the packaging meets the applicable requirements, documents this assessment in technical documentation, then draws up the declaration. It also provides a model declaration and the identification elements it must contain. The precise article and annex references should be checked directly in the official text, as implementing acts may specify the detailed arrangements.
Remember the general logic: a declaration always rests on a documented assessment. It is not a stand-alone document, but the visible conclusion of evidence-gathering work.
Three common confusions distort the preparation of a file:
The PPWR declaration of conformity is a declaration under the manufacturer's responsibility, based on a documented assessment. It is neither a certificate, nor a CE marking, nor a technical data sheet.
To place this document within the overall framework, see the PPWR Regulation: packaging compliance guide.
The declaration is drawn up by the operator that places the packaging on the market as a manufacturer, that is, the one that designs it or has it designed and markets it under its own responsibility.
| Operator | Role regarding the declaration |
|---|---|
| Packaging manufacturer | Draws up and signs the declaration; keeps the technical documentation |
| Material / component supplier | Provides the data and evidence (data sheets, certificates, reports) |
| Importer | Checks the conformity of the imported packaging; may be treated as a manufacturer |
| Distributor / private label | Becomes responsible when it markets under its own name |
| Company placing the packaged product on the market | Ensures it holds the declarations covering its packaging |
When packaging or a packaged product comes from a non-EU country, the importer that places it on the Union market assumes obligations comparable to those of the manufacturer. In practice, this means obtaining the necessary evidence from sometimes distant suppliers: a point at which document collection becomes critical.
If a distributor markets a packaged product under its own brand, it may be considered the manufacturer and have to draw up the declaration, even if it did not design the packaging. Subcontracting does not transfer regulatory responsibility: it shifts the production of evidence, not responsibility for the declaration.
The question is not “who makes the packaging?” but “who places it on the market under its own responsibility?”. Importers and private labels may have to draw up the declaration as a manufacturer.
The Regulation governs the content of the declaration and provides a model. The table below links each type of entry to its information source and to the operator that provides it: it is this chain that determines whether the declaration holds up.
| Entry | Information source | Who provides it |
|---|---|---|
| Packaging identification (reference, type, use) | Product specification | Manufacturer / packaging supplier |
| Identity and contact details of the manufacturer (and any authorised representative) | Administrative data | Manufacturer |
| Object of the declaration and applicable Union acts | Regulatory analysis | Regulatory team |
| Requirements covered (sustainability, substances, other) | Conformity assessment | Manufacturer, supported by the evidence |
| Material composition and recycled content | Technical data sheet, material certificate | Material supplier / manufacturer |
| Substances of concern (including PFAS) | Safety data sheet, analysis report | Laboratory / supplier |
| References to standards or technical specifications | Harmonised standard, calculation method | Manufacturer / laboratory |
| Date, place, identity and signature of the signatory | Act of commitment | Manufacturer (authorised signatory) |
The key point: a good share of the entries depend on external data. Writing the declaration is easy; basing it on up-to-date evidence linked to the right packaging is much less so.
Each entry in the declaration is linked to an identifiable source. If you cannot name the supplier, the date and the version of a piece of data, the corresponding entry is not proven.
What a declaration of conformity rests on
Writing the declaration is easy; basing it on up-to-date evidence is much less so.
Never write the declaration first. Gather the evidence first: the declaration is only the summary of what you can demonstrate.
Proof of conformity does not concern “the packaging” as a whole, but each material and each component. A single undocumented component is enough to weaken the file.
The declaration does not exist on its own: it relies on technical documentation and must be kept available to the authorities. The “packaging technical file” therefore brings together:
The Regulation sets a retention period for the written declaration and the technical documentation, which differs according to the type of packaging: a longer period for reusable packaging than for single-use packaging. The precise period and its starting point should be checked in the official text of the Regulation and any further clarifications, as they determine your archiving policy.
“Manufacturers shall keep the technical documentation referred to in Annex VII and the EU declaration of conformity as follows: (a) in the case of single-use packaging: for 5 years from the date the packaging was placed on the market; (b) in the case of reusable packaging: for 10 years from the date the packaging was placed on the market.”Regulation (EU) 2025/40, Article 15, paragraph 3 · EUR-Lex, official text
Keeping a PDF is not enough. At audit, the question is not “do you have the document?” but “can you prove that this evidence really covers this packaging, at this date, in this version?”. A technical file without source traceability is an incomplete file.
This is the heart of the matter: the evidence comes from outside, and this is where most projects get bogged down. Four levers make collection sustainable.
Standardise the request: one form per type of evidence (technical data sheet, food-contact declaration of conformity, recycled content attestation, analysis report). A well-defined request reduces back-and-forth and unusable answers.
State what is acceptable: signed PDF, laboratory report with method and date, material certificate, attestation on letterhead. The supplier must know the expected format before sending.
Three triggers structure updates:
Each piece of evidence must show: who issued it, when, for what scope, and which version replaces the previous one. Without this, expired evidence can coexist with valid evidence without anyone noticing.
The supplier portal is the channel that replaces the mailbox; regulatory document management sets the rules.
Collection cannot be improvised email by email. It has to be managed: standard request, defined format, known frequency, traced version.
None of these errors stems from poor drafting: all stem from data that is not centralised, not dated or poorly linked. The declaration is the revealer, not the cause.
The PPWR and the EUDR (European deforestation regulation) both require documents, and for wood or paper packaging they converge on the data. But they are two distinct frameworks.
| Criterion | PPWR declaration of conformity | EUDR due diligence statement |
|---|---|---|
| Purpose | Conformity of the packaging with PPWR requirements | Deforestation-free status and legality of products |
| Authority / framework | European framework of Regulation (EU) 2025/40 | Regulation (EU) 2023/1115 and national competent authorities |
| Evidence | Composition, recycled content, substances, tests | Origin, geolocation, legality, due diligence |
| Retention period | Per the Regulation, differs by packaging type (to be checked) | Per the provisions of the EUDR (to be checked) |
The point of convergence remains supplier data: for cardboard or wood packaging, the origin required by the EUDR overlaps with the PPWR documentation. Handling both on a common foundation avoids double collection. The specific case of pallets and crates is detailed in the EUDR wood packaging guide.
PPWR and EUDR are not the same thing, but a single product sheet can feed both. Do not duplicate supplier requests: pool the data.
A one-off declaration can be managed by hand. A portfolio of packaging, across several deadlines and several versions, cannot. Four building blocks make the difference.
Link each packaging to its supplier, its components, its documents and their expiry dates. The goal: find the evidence for a given packaging in a few minutes.
A piece of conformity evidence has a date. Tracking deadlines and following up before expiry avoids declarations based on outdated data.
A single channel to request, receive and update evidence, with a record of who provided what and when.
A spreadsheet does not natively manage a document's version, its expiry dates, the link between packaging, component and product, or the extraction of data buried in heterogeneous PDFs. A mailbox, for its part, guarantees neither traceability nor completeness.
Tracklab follows this approach: centralising supplier and product data, automating document collection, tracking deadlines and making use of documents through AI. It is not an ERP, nor a production or inventory management tool, nor a regulatory monitoring tool.
The declaration is produced once; its evidence must live continuously. It is the tracking of versions and deadlines that distinguishes a solid file from a fragile one.
The PPWR declaration of conformity is not a drafting exercise: it is an exercise in proof. Three decisions make it sustainable:
The concrete next step: pick a packaging at random and check whether you can find, in a few minutes, its composition, its recycled content, its test reports and the declaration that covers them - with dates and versions. If the answer is no, that is the first project to open, before the Regulation's deadlines make it mandatory.
This data foundation will also support your compliance under EPR for commercial packaging (the French REP emballages professionnels scheme) and, for wood and paper packaging, your EUDR approach. The logic is the same: centralising the evidence once is better than reconstructing it under pressure.
The EU declaration of conformity relies on solid technical documentation. The collection kit helps you obtain each piece of evidence from your suppliers.
The step-by-step method to obtain PPWR evidence from your suppliers (PFAS, substances, recyclability, recycled content), with the questionnaire and evidence matrix ready to send.
All the deadlines of Regulation (EU) 2025/40 on a single timeline, and the checklist of actions to start now, article by article.
Enter your details to access the download immediately.
The files open in Google Drive. For the spreadsheet, Google offers to make a copy in your own Drive.
It concerns packaging within the scope of Regulation (EU) 2025/40 placed on the Union market. The exact scope, specific categories and any derogations should be checked in the text and its implementing acts for your case.
As a general rule, the packaging manufacturer, that is, the one that places the packaging on the market under its own responsibility - including an importer or a private label depending on the situation. The signature commits the signatory to the declared conformity.
Not systematically. The declaration is most often drawn up under the manufacturer's responsibility, without third-party involvement. A body is only involved if the applicable assessment module requires it - to be confirmed according to the packaging category.
The authorities may request the declaration and the technical documentation (see also our PPWR FAQ). The PPWR provides for a penalty regime defined and implemented by the Member States; amounts and arrangements therefore vary by country, to be checked for your jurisdiction.
The Regulation applies in a harmonised way across the 27 Member States, without national transposition. The declaration may, however, need to be drawn up in or translated into the language required by the Member State concerned: validity is European, the language form may be local.
“Packaging conformity attestation” often refers, in everyday language, to the same document or to a declaration provided by a supplier. The EU declaration of conformity within the meaning of the PPWR, on the other hand, follows a content and model defined by the Regulation. Always distinguish the regulatory act from a mere commercial attestation.
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