Packaging declaration of conformity: how to issue it

A packaging declaration of conformity is a one-page document in which the manufacturer states, under its own sole responsibility, that a specific piece of packaging meets the requirements of Articles 5 to 12 of Regulation (EU) 2025/40. Article 39 is the legal basis; Annex VIII sets out the structure of the model. Since 12 August 2026, packaging without a declaration and without technical documentation should not reach the market — the obligation already applies.

The most common misunderstanding runs: we have a declaration, therefore we have conformity. It works the other way round. The declaration is a conclusion, not evidence. The evidence is the technical documentation drawn up under Annex VII and the internal production control procedure, meaning an assessment the manufacturer runs itself, without a notified body. A market surveillance authority will ask for the declaration first and for what stands behind it second — and the second request is the one that settles the matter.

What the declaration of conformity must contain#

The Annex VIII model is short, but every field carries evidentiary weight:

Building the declaration step by step#

1. Define the unit you are declaring. You declare a specific piece of packaging, not a category. If the same carton exists in three sizes and two print versions, establish whether the differences affect the material composition. If they do not, one declaration can cover them all provided the variants are listed; if they do, split them.
2. Break the packaging down into materials (BOM). Every component: board, film, adhesive, ink, label, closure, insert, tape. Give a weight for each. The component weights must add up to the weight of the packaging — the first consistency check, and the one that catches omitted parts.
3. Attach evidence to every material. A test report, a supplier statement with a batch number, a technical data sheet with an unambiguous material designation. A material with no document attached is missing evidence, not "probably zero".
4. Calculate what has to be calculated. The sum of the four heavy metals, taken together for the whole packaging and weighted by the mass fractions of the components. The method is set out in the post on the Article 5 limits.
5. Check the remaining requirements in Articles 5 to 12 that already bind you, and record in the documentation why the others do not yet apply — that reasoning is itself part of the assessment.
6. Complete the technical documentation under Annex VII before you generate the declaration. The order matters: a declaration summarises a closed assessment; it does not announce one that will be carried out later.
7. Sign and archive together with a snapshot of the data the assessment was based on.

Declaration versus technical documentation: what sits where#

The declaration is an external document: you show it to customers, retail chains, importers and authorities. The technical documentation is internal — you make it available on a reasoned request from a market surveillance authority, usually within a deadline counted in days.

Under Annex VII, the technical documentation contains at least a general description of the packaging and its intended use, a list of materials and components with their weights, a description of the design solutions, the results of calculations and tests, a list of the standards applied and the source documents from suppliers. It has to be detailed enough for an outsider to reconstruct your reasoning without talking to you. That is the practical completeness test: if understanding the documentation requires a conversation with the packaging engineer, the documentation is incomplete.

Who signs and what they answer for#

The signatory is a person authorised to represent the manufacturer: a board member, or an employee holding an explicit authorisation that covers making statements of this kind. Keep that authorisation in writing and store it alongside the documentation — authorities do ask for it.

Responsibility for the content of the declaration rests with the company. Under the Commission guidance on the PPWR, outsourcing the drafting does not move that responsibility: it stays with the party placing the packaging on the market under its own name. The signatory answers internally and, in extreme cases, under the general rules of national law, personally as well. Hence the working rule: do not sign a document whose evidence you have not seen. No tool, PPWR24 included, takes on that responsibility or guarantees that the packaging is compliant — it keeps the data complete and shows the gaps, but a human being makes the statement.

How long to keep it#

The declaration and the technical documentation are kept for 5 years from the moment the packaging is placed on the market, and 10 years for reusable packaging. What counts is the date the batch was placed on the market, not the date the product left the catalogue — the clock keeps running after sales stop. On imports, the importer keeps a copy of the declaration as well.

What to do when evidence is missing#

The Regulation makes no provision for a conditional declaration. The signature is unconditional and cannot be qualified with a footnote. There are, however, three honest ways out of a situation where one material has no test yet:

• Other admissible evidence. The assessment does not require every component to be tested. A supplier statement citing the Article 5 limit and identifying the batch or heat number can be sufficient, provided the technical documentation records what the conclusion rests on, why the evidence was considered reliable and what the residual risk is. That is the right place for the reasoning — not the body of the declaration.
• Worst-case assessment. For a material of a known type you can adopt a conservative value and show that even that value does not exhaust the limit. The assumption has to be documented and defensible, not merely convenient.
• Hold. If the material accounts for a significant share of the mass and there is no evidence at all, the packaging is not placed on the market until the documents arrive. Keep a working version of the declaration internally, listing the gaps and a deadline — that is a management document, not a market document, and it must never be sent to customers.

Each of these routes depends on a complete path back to the supplier. How to frame the request so that what arrives is usable in the documentation is covered in the post on supplier documents.

Versioning and checksums#

A declaration describes the state of knowledge on a particular day. A change of film supplier, a change of grammage, a new print, a new test report — each creates a new set of facts. The operating rule: a new version, never an overwrite. The old version stays in the archive, because it covers batches that are already on the market and have their own retention clock running.

A SHA-256 checksum is not an electronic signature and does not replace one. It answers a different question: is the file a customer or an authority holds today exactly the file you generated on the day of signature? In a dispute over the content of a document from two years ago, that is the difference between an argument and proof. Print the hash on the document and keep it in the register alongside the date and the signatory.

Before you sign#

A declaration is only as good as the data underneath it, and data falls apart in two places above all: unassigned components and an empty value masquerading as zero. To see how that looks on your own items, break one pack down into materials and count how many rows end up with no document.

If you are not yet certain that your company is the one that should be issuing the declaration, go back to the post on who the PPWR applies to and who signs.