PPWR declarations of conformity: the paperwork you can't outsource

Since 12 August 2026, no packaging type may go on the EU market without a signed declaration of conformity backed by a technical file. It sounds like a formality. In practice it is turning into the compliance task that exposes how little structured data most packaging portfolios actually have.

This explainer sets out what the declaration of conformity covers, who has to sign it, how it differs from the separate and currently unsettled authorised representative obligation, and what a packaging or regulatory team should be doing with it right now.

What a declaration of conformity is

The declaration of conformity is defined in Article 39 with the model structure detailed in Annex VIII. Its scope covers compliance with Articles 5 through 12: minimisation, recyclability, recycled content, reuse, substance restrictions and innovative packaging. It is a self-declaration: the manufacturer states, under its own legal responsibility, that a specific packaging type meets those requirements. There is no notified body in the normal case and no CE-style mark on the pack.

Behind the declaration sits the technical documentation, the evidence file that backs up every claim, and both are mandatory and must be available to market surveillance authorities on request. The declaration is short. The file behind it is where the real work sits: material composition, recyclability assessment, substance testing, minimisation calculations, and whatever the specific format needs to support its claims under Articles 5 to 12.

Who signs it

PPWR uses “manufacturer” in a specific sense that doesn’t map neatly onto who physically makes the pack. The practical test is that if your brand is on the packaging, you’re likely the manufacturer. A contract packer or converter can produce the item, but the company whose name and brand appear on it generally carries the conformity obligation, including the signature on the declaration and the duty to hold the technical file.

That has a direct consequence for private label and co-packed products: the retailer or brand owner, not the factory, usually ends up legally responsible for a document it may not have the underlying data to complete without asking the supplier for it.

One declaration per packaging type, not one blanket document

The obligation applies per packaging type: each format, each material, each configuration needs its own declaration, so a company with fifty packaging formats will need fifty declarations, each with its own supporting documentation. Batch level identification stays in production records and, where relevant, in the technical documentation; the declaration itself is not reissued per batch but versioned per change.

Six elements are required under Annex VIII: a unique identification number for tracking, the manufacturer’s name and address, a sole responsibility statement, a packaging identification section covering type, material, and batch or serial number, the conformity statement referencing Articles 5 through 12, and the signature with place and date. Treating this as a single generic certificate that covers “our packaging” rather than a specific format is one of the most common ways companies get this wrong.

A supplier letter is not a declaration

A frequent assumption is that a supplier’s compliance letter, an EPR registration number, or a material spec sheet marked “PPWR compliant” can stand in for the manufacturer’s own declaration. Under Article 16, suppliers must provide the information and documentation manufacturers need to demonstrate conformity, but an EPR registration number, a generic material specification or a statement saying “PPWR compliant” is not a substitute for the required assessment and declaration. The manufacturer has to run its own conformity assessment and sign its own declaration, using supplier data as an input rather than a finished answer.

Two “representatives”, two different jobs

PPWR creates genuine confusion by using “representative” for two unrelated roles, and it is worth being precise about which one applies where.

The Article 17 representative deals with conformity documentation, the Article 45 representative deals with waste management costs, and a company can need one, both or neither; a mandate for one covers nothing of the other. The Article 17 role is optional: a manufacturer can appoint someone in the EU to hold documents and liaise with authorities. Even where an Article 17 representative is appointed, the manufacturer retains responsibility, and Article 17 expressly excludes the conformity obligation and the duty to draw up technical documentation from the representative’s mandate. The paperwork can be delegated. The liability cannot.

The Article 45(3) role is a different matter and currently unsettled. It requires producers who sell into a member state where they have no establishment to appoint a national representative there for extended producer responsibility. In December 2025 the European Commission proposed, under COM(2025) 982, suspending this requirement for EU-established producers until 1 January 2035, during which time they would not be required to appoint a national representative in markets where they are not established, though they could still do so voluntarily. That proposal has not been adopted. The European Parliament’s environment committee rapporteur published a draft report with sixteen amendments in May 2026, reshaping the Commission’s proposal in several directions, including, according to other reporting on that draft, narrowing any suspension to the smallest enterprises rather than all EU-established producers.

Industry groups want the obligation lifted or softened. EUROPEN has called for temporary suspension of the authorised representative obligation as a pragmatic step towards simplification and a stronger single market. Businesses operating on the EU market currently face separate registration in each country they export to, which can cost over €500 per country, and SMEunited has pressed Parliament and member states on the point directly. Its president, Davide Galli, has said Parliament and Member States should approve the suspension of the obligation to appoint authorised representatives in each Member State.

A plenary vote on the Parliament’s position is provisionally scheduled for 19 October 2026. Until any change is published in the Official Journal, the Article 45(3) obligation applies as adopted law. Treat it as live, and build any representative contract with a termination clause in case the law changes under it.

The data problem underneath the signature

The declaration itself is one page. What makes it hard is that most companies don’t hold the data behind it in a form that can produce fifty, five hundred, or five thousand accurate, format-specific documents without manual rework.

The depth and breadth of data required is changing: companies have already had to compile information on PFAS and heavy metals as supporting technical documentation, and future requirements will extend to packaging composition detail including metallisation, barriers, inks, colours, and separability of components. A spreadsheet can work for a small portfolio and manual processes can hold for a while, but there is no shortcut to structured packaging data at any scale beyond that.

This is why the declaration of conformity is best understood as a reporting output of a data system, not a standalone legal form. If packaging specifications, material composition, substance data and recyclability assessments live in scattered PDFs and supplier emails, generating one accurate declaration is manageable. Generating and maintaining fifty, correctly versioned every time a supplier changes a laminate or an ink, is not.

Tools entering the market

Software vendors are responding to exactly this gap. PackIntelX has developed EasyDoC, a digital solution intended to help smaller businesses complete declarations of conformity in a guided workflow that replaces separate documents, spreadsheets, and manual formatting and translation processes with a single process. Other platforms aimed at larger portfolios focus on centralising supplier data collection and keeping the technical file audit-ready across hundreds of SKUs rather than generating a single document.

None of these tools removes the underlying legal responsibility. A platform can structure the data and assemble the document. The signature, and the liability behind it, stays with the manufacturer.

Role	Core obligation	Can it take on the manufacturer’s conformity liability?	Status, October 2026
Manufacturer (brand owner)	Run the conformity assessment, hold the technical file, sign the declaration per packaging type	n/a, this is the liable party	Mandatory since 12 August 2026
Importer	Verify a valid declaration and supporting documentation exist before placing packaging on the market	No	Mandatory since 12 August 2026
Distributor	Check labelling and documentation are present; refuse to sell non-compliant packaging	No	Mandatory since 12 August 2026
Article 17 representative (conformity, optional)	Hold documents and liaise with authorities under a written mandate	No, conformity obligation stays with the manufacturer	Available now, optional
Article 45(3) representative (EPR, cross-border)	Register the producer in the national EPR register in a market where it has no establishment	Different obligation, not a substitute for the above	Mandatory since 12 August 2026; Commission has proposed suspending for EU-established producers until 2035, not adopted

What to do now

List every distinct packaging type you place on the EU market, by material, structure and format, and confirm who in your organisation or supply chain qualifies as the manufacturer for each one.
Check that a signed declaration of conformity and a matching technical file exist for each packaging type, not a single generic compliance letter covering a whole range.
If you rely on suppliers, ask for the underlying data (material composition, substance testing, recyclability assessment) rather than accepting a one-line “PPWR compliant” statement.
Separate your Article 17 arrangements (conformity documentation) from any Article 45 arrangements (EPR representation) in your contracts; they are not interchangeable and one mandate does not cover the other.
If you sell into a member state where you have no establishment, assume the Article 45(3) authorised representative obligation applies now. Build a termination right into any new mandate in case the suspension proposal is adopted later.
Treat packaging data as structured master data rather than a filing task: centralise it now, because recyclability grading and recycled content reporting due from 2030 will draw on the same records.
For anything uncertain in your specific case, especially manufacturer status in co-packing or private label arrangements, take legal advice or check the official text in the Official Journal rather than relying on a summary.

PPWR declarations of conformity: the paperwork you can’t outsource