đź“ŚThe PPWR's August 12 2026 implementation deadline is fast approaching, and ESG researcher Rosaida Brahim addresses one of the most important elements of compliance: the EU declaration of conformity.
The Packaging and Packaging Waste Regulation (PPWR) came into force in 2025, and the first application deadlines will go into play from 12 August 2026 onwards. That means that there is very little time for businesses who are affected by this regulation to prepare for those first steps towards compliance.
This article explores the EU declaration of conformity (EU-DoC). This document is the cornerstone of the regulation; it states that the packaging meets the PPWR requirements, and without a fully complete and accepted declaration, the packaging is not allowed on the EU market.
In this article:
1: A brief reminder of what the PPWR is
2: An overview of the EU declaration of conformity
2.1: Critical points to keep in mind
2.2: Who is responsible for it
2.3: What needs to be included
3: What happens when it is incomplete or hasn’t been accepted
4: How MasterSustainability.today will make you compliant
Most businesses will already have experience with EU packaging regulations under the PPWR's predecessor, the Packaging and Packaging Waste Directive. Both aim to reduce packaging related waste, but there is one defining difference. Under the Directive, EU Member States were asked to tackle waste reduction goals using their own measures. Under the PPWR these regional strategies are replaced by an EU-wide framework.
This requires business to undergo an initial overhaul in packaging practices. Once in place, the PPWR will ensure a European-wide standardized framework that will make it easy to track and ensure the recyclability, minimization, and quality of packaging entering the EU market.
The first PPWR deadline hits on 12 August 2026. By this date all packaging entering the EU market must conform to the first phase of PPWR requirements, including:
Limitations to PFAS concentrations in food-contact packaging
Limitations to heavy metals
EU-DoC for every packaging type
Extended Producer Registration (EPR) in every relevant Member State
If you want to know more about the PPWR, read our FAQ or our full breakdown of the PPWR and what you can expect from 2026 onwards.
It is difficult to name a business who isn't affected by the PPWR. Its scope and measures are so comprehensive that if you have any product on the EU market, it is likely to fall under it. Because of this, it is important to take a closer look at one of the main means of evaluating compliance: the EU declaration of conformity.
The EU declaration of conformity (EU-DoC) is a legal document declaring that a product complies with Articles 5-12 of the PPWR. An incomplete or inaccurate EU-DoC means that packaging won't be allowed on the market, or that it will be recalled or removed.
A new EU-DoC is necessary for every packaging type and format
It needs to be maintained; if changes are made to the packaging, changes must also be made to the EU-DoC.
The Packaging and Packaging Waste Regulation (PPWR) identifies five main roles: the manufacturer, the supplier, the importer, the distributor, and the producer.
The manufacturer is any natural or legal person that manufactures packaging or a packaged product.
The supplier is any natural or legal person that supplies packaging or packaging material to a manufacturer.
The importer is any natural or legal person established within the Union that places packaging from a third country on the market
The distributor is any natural or legal person in the supply chain, other than the manufacturer or importer, that makes packaging available on the market.
The producer (or producer responsibility organizations) is any manufacturer, importer or distributor who makes a packaging available in an EU Member State for the first time.
Of these, it is the manufacturer who is responsible for gathering the information and technical documentation necessary for the EU-DoC. By written mandate, a manufacturer is allowed to appoint an authorized representative who keeps track of the EU-DoC's, makes them available for authorities upon request, and acts as a main contact point.
As is to be expected, these clearly defined roles sometimes overlap in real life:
If an importer or a distributor places packaging on the market under its own name or trademark, they shall be considered a manufacturer.
Likewise, if an importer or a distributor modifies packaging already placed on the market in a way that could affect compliance, they shall also be considered a manufacturer.
Example -- a clothing brand who buys in already made, PPWR compliant packaging but adds their brand to it becomes a manufacturer and must write up a new EU-DoC.
Attention! Even if your business does not fall under the role of manufacturer, this does not mean that you get to ignore the EU-DoC.
Importers and distributors need to ensure that the EU-DoC has, in fact, been carried out satisfactorily. If there is any doubt, then they are not allowed to place the packaging on the market until the packaging has been brought into conformity.
This is also valid for what the regulation refers to as economic operators from third countries (meaning non-EU Member States). It is important for all businesses with packaged goods on the EU Market to assess what role they play in PPWR compliance.
In Annex VIII of the PPWR an overview is provided of what needs to be included in a successful EU declaration of conformity (EU-DoC). It might seem confusingly... minimalistic. That's because the EU-DoC is just that, a declaration that the manufacturer has carried out all the compliance processes. The accompanying technical documentation must also be readily available for auditing.
1. No. ... (unique identification number of the packaging):
2. Name and address of the manufacturer and, where applicable, the manufacturer's authorized representative:
3. This declaration of conformity is issued under the sole responsibility of the manufacturer.
4. Object of the declaration (identification of the packaging allowing traceability): description of the packaging:
5. The object of the declaration referred to point 4 is in conformity with the relevant Union harmonization legislation: .... (reference to the other Union acts applied)
6. References to the relevant harmonized standards or the common specifications used or references to the other technical specifications in relation to which conformity is declared:
7. Where applicable, the notified body … (name, address, number) … performed … (description of intervention) … and issued the certificate(s): … (details, including the date of the certificate(s), and, where appropriate, information on the duration and conditions of validity).
8. Additional information:
Signed for and on behalf of:
(place and date of issue):
(name, function) (signature):
Take care to note that the EU-DoC's exist to facilitate traceability. This means that specifics are a must - specify what material group and what material type the packaging falls under. When referencing other Union Acts and declarations of conformity relevant to the packaging, use the official codes.
Generalizations are the enemy of a successful EU-DoC!
The EU declaration of conformity (EU-DoC) is an integral part of compliance. If the EU-DoC hasn't been drawn up properly (if it is incomplete, if it is incorrect, or if it is no longer reflective of the packaging), the packaging is not allowed on the EU market. Measures will be taken to keep it from being made available on the market, or to recall or remove it.
This is already painful in and of itself, but non-compliance also carries the risk of further, undefined penalties. These penalties are for each respective Member States to determine, and they have until 12 February 2027 to do so. All we can do till then is to quote the regulation itself, which states that the penalties “shall be effective, proportionate and dissuasive”.
Compliance with Packaging and Packaging Waste Regulation (PPWR) is vital for businesses with packaged goods on the EU market. It is also much easier said than done.
MasterSustainability.today offers an automated beginning-to-end solution for companies struggling to meet their compliance requirements.
For more information on how to be audit ready in three months, explore our PPWR solution and request a brochure or demo.
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