PPWR Conformity Assessment Procedure Explained


Legal Document Being Signed

What is the PPWR Conformity Assessment Procedure?

The PPWR Conformity Assessment Procedure is a critical requirement under the EU’s Packaging and Packaging Waste Regulation (PPWR). But what does it mean in practice for businesses placing packaging on the EU market?

Under the PPWR, packaging can only be placed on the EU and Northern Ireland market if it complies with sustainability requirements and this compliance is formally demonstrated through the conformity assessment procedure.

This process applies to each unique packaging unit and requires both technical documentation and a declaration of conformity.

For further regulatory context, see guidance from the European Commission.

What does the PPWR Conformity Assessment Procedure cover?

The PPWR Conformity Assessment Procedure ensures compliance with key sustainability requirements set out in Articles 5–12, including:

  • Requirements for substances (Article 5)
  • Recyclability (Article 6)
  • Minimum recycled content (Article 7)
  • Compostable packaging (Article 9)
  • Packaging minimisation (Article 10)
  • Reusable packaging (Article 11)
  • Labelling of packaging (Article 12)

Each of these areas must be assessed and evidenced as part of the conformity process.

What is technical documentation under PPWR?

Technical documentation is a core part of the PPWR Conformity Assessment Procedure and provides the evidence needed to demonstrate compliance.

This typically includes:

  • A description of the packaging
  • Conceptual design, drawings, and materials used
  • Explanations of how the packaging functions
  • Relevant specifications or descriptions of compliance solutions
  • A qualitative assessment of the packaging
  • Test reports

These documents provide the necessary context and evidence to demonstrate that packaging meets the applicable sustainability requirements. The exact requirements will vary depending on which aspects of compliance are being assessed.

What is the Declaration of Conformity?

The Declaration of Conformity is a formal statement confirming that packaging meets PPWR requirements.

It:

  • Summarises evidence of compliance
  • Identifies the party responsible for conformity
  • Must be provided to national authorities within 10 days upon request
  • Must be available in a language easily understood by the authority

Both the Declaration of Conformity and technical documentation must be retained for:

  • 5 years for single-use packaging
  • 10 years for reusable packaging

Who is responsible for the PPWR Conformity Assessment Procedure?

Under the PPWR, responsibility sits primarily with the manufacturer. However, other economic operators also play a role:

  • Manufacturers must carry out the conformity assessment procedure
  • Importers and distributors must ensure compliance has been demonstrated before placing packaging on the market
  • Suppliers must provide the necessary data and documentation to support compliance

This shared responsibility ensures that all packaging placed on the EU market meets regulatory requirements.

Why the PPWR Conformity Assessment Procedure is important

The process is essential for:

  • Demonstrating compliance with EU sustainability requirements
  • Avoiding enforcement action or market restrictions
  • Ensuring transparency across the packaging value chain
  • Supporting the transition to a circular economy

Summary: Key takeaways

  • The PPWR Conformity Assessment Procedure is mandatory for all packaging placed on the EU and Northern Ireland market
  • It requires both technical documentation and a Declaration of Conformity
  • It applies to multiple sustainability requirements, including recyclability and labelling
  • Responsibility is shared across manufacturers, importers, distributors, and suppliers

Need support with PPWR compliance?

Navigating the PPWR Conformity Assessment Procedure can be complex, but you don’t have to manage it alone.

Visit our PPWR web page
Enquire about our PPWR Advisory Service
Enquire about our PPWR Data Service

Written by: Harry Russell

Senior International Account Manager Research Lead

Topics:

Blog, Packaging