The PPWR Declaration of Conformity (DoC) is a legally required document used to demonstrate that packaging complies with applicable Packaging and Packaging Waste Regulation (PPWR) requirements before it is placed on the EU market. Understanding who is responsible for the declaration, what information it must contain and how supporting evidence should be maintained is essential for businesses preparing for PPWR compliance.
The PPWR Declaration of Conformity (DoC) is a mandatory document used to demonstrate that packaging complies with the applicable requirements of the EU Packaging and Packaging Waste Regulation (PPWR). This article explains who is responsible for the DoC, what information it must contain and how businesses can prepare.
The PPWR Declaration of Conformity (DoC) is a legally binding statement confirming that packaging complies with the applicable PPWR requirements before being placed on the EU market.
Before placing packaging on the market, the manufacturer must complete the Conformity Assessment Procedure (CAP) and compile the relevant technical documentation. Where conformity has been assessed in accordance with the applicable requirements, the manufacturer must draw up the Declaration of Conformity.
The conformity assessment procedure generally applies from 12 August 2026. Where a specific PPWR provision does not specify a different implementation date, the general application date applies.
By drawing up and signing the Declaration of Conformity, the manufacturer assumes responsibility for the compliance of the packaging.
Under PPWR, a manufacturer is the business or person that manufactures packaging or has packaging or packaged products manufactured under its own name, trademark or design specifications.
The manufacturer must demonstrate that packaging placed on the EU market complies with the relevant PPWR requirements by completing the Conformity Assessment Procedure. This includes preparing the technical documentation and issuing the Declaration of Conformity where required.
The manufacturer remains responsible for these obligations regardless of whether they are established inside or outside the EU.
A manufacturer may appoint an authorised representative through a written mandate. The authorised representative may carry out certain tasks specified within that mandate, including holding documentation and liaising with authorities, but the manufacturer remains responsible for meeting its obligations under the Regulation.
PPWR Annex VII outlines the requirements for the Conformity Assessment Procedure.
This includes the technical documentation required to assess conformity with the applicable PPWR requirements and to support the Declaration of Conformity.
The technical documentation provides the evidence underpinning the manufacturer’s declaration and should be maintained as part of an auditable compliance record.
PPWR Annex VIII provides the model structure and required content for the PPWR Declaration of Conformity.
The declaration includes:
Annex VII and Annex VIII work together. The Declaration of Conformity must be supported by the technical documentation prepared as part of the Conformity Assessment Procedure.
Manufacturers must retain the Declaration of Conformity and the supporting technical documentation for defined periods following placement on the market.
Before publication, the exact retention periods should be confirmed against the latest PPWR legal text and technical guidance to ensure they reflect the current regulatory position.
To support businesses with these requirements, Valpak provides a structured PPWR Data Service designed to help gather, manage and maintain the data and documentation required for PPWR compliance.
Valpak supports the collection, organisation and management of conformity data and supporting records. Valpak does not determine or certify compliance.
Using supplier-provided information, Valpak structures packaging component data in line with PPWR conformity assessment requirements.
This includes:
Valpak can help businesses generate structured documentation including:
Documentation can be stored and accessed through Valpak’s Members’ Area.
Producing and maintaining PPWR Declarations of Conformity requires accurate packaging data, supplier evidence and robust documentation processes.
Valpak’s PPWR Data Service helps businesses collect, structure and maintain the information needed to support conformity assessments and documentation requirements. For organisations looking to understand how the wider Regulation affects their packaging portfolio, the PPWR Advisory Service provides guidance on implementation requirements, obligations and upcoming regulatory developments.
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A PPWR Declaration of Conformity is a legally binding statement confirming that packaging complies with the applicable requirements of the Packaging and Packaging Waste Regulation before it is placed on the EU market.
The manufacturer is responsible for issuing the Declaration of Conformity and maintaining supporting technical documentation.
Annex VII sets out the Conformity Assessment Procedure and supporting technical documentation requirements. Annex VIII specifies the format and required content of the Declaration of Conformity.
Current PPWR guidance indicates that the conformity assessment procedure and associated Declaration of Conformity are required for each distinct packaging unit. Similar packaging units may be assessed using the same approach where appropriate.
The conformity assessment procedure generally applies from 12 August 2026 unless a specific PPWR provision states otherwise.
Businesses should establish accurate packaging datasets, identify data gaps, collect supplier evidence, maintain auditable records and ensure technical documentation can support future conformity assessments and declarations.