Articles · 2026-09-17
PPWR declaration of conformity: the eight points of Annex VIII
The PPWR declaration of conformity (Art. 39, Annex VIII) has eight points, is drawn up per packaging type by the manufacturer and kept for 5 or 10 years.
From 12 August 2026 packaging placed on the EU market needs an EU declaration of conformity. Guides online disagree even on how many items it has. Below are the short answers, from the Regulation's own articles.
What is the PPWR declaration of conformity?
A written self-declaration by the manufacturer that the packaging meets the requirements of Articles 5 to 12 of Regulation (EU) 2025/40. It is drawn up under Article 39, follows the model in Annex VIII, and by drawing it up the manufacturer takes responsibility for the packaging's compliance. It is not a certificate and there is no CE mark.
Who draws it up?
The manufacturer of the packaging — not always the company that physically made it:
- Branded — the company whose name or trademark is on it.
- Unbranded, generic — normally the company that makes it.
- Custom-made and unbranded — the company that orders it and sets the specification.
An authorised representative may draft it. The technical documentation behind it cannot be delegated, and no contract moves the responsibility. More in what is PPWR.
What comes first?
The order is set by Article 15(2):
1. Carry out the conformity assessment (Article 38 — Annex VII, "Module A", internal production control; normally no notified body).
2. Draw up the technical documentation of Annex VII.
3. Only then draw up the declaration.
The declaration rests on the documentation, not the other way round.
What must it contain?
Annex VIII has eight numbered points, followed by a signature block:
1. The unique identification of the packaging.
2. The name and address of the manufacturer and, where applicable, of the authorised representative.
3. A statement that it is issued under the manufacturer's sole responsibility.
4. The object of the declaration — identification of the packaging allowing traceability, and a description.
5. A statement that the object conforms, with references to other Union acts applied.
6. References to the harmonised standards, common specifications or other technical specifications used.
7. Where applicable, the notified body and its certificate.
8. Additional information.
Then place and date of issue, name and function of the signatory, and the signature. It is the same eight-point shape as other EU product declarations (Decision 768/2008/EC).
One declaration per what?
Per packaging type, not per shipment and not per company. A range of fifty formats means fifty declarations. Where the packaged product also needs an EU declaration under another act, one combined declaration — or a dossier of them — may be drawn up (Article 39(3)).
What goes into the technical documentation?
Wherever applicable, at least:
- a general description of the packaging and its intended use;
- conceptual design, manufacturing drawings and materials of components;
- a list of standards and specifications applied;
- how the assessments under Articles 6, 10 and 11 were carried out;
- test reports — for example heavy metals, where lead, cadmium, mercury and hexavalent chromium together may not exceed 100 mg/kg.
How long is it kept?
Both the declaration and the technical documentation (Article 15(3)):
- 5 years for single-use packaging;
- 10 years for reusable packaging.
An importer keeps a copy too.
When must it be updated?
The declaration is kept up to date. When the packaging design or characteristics change, or the standards it refers to change in a way that could affect conformity, the manufacturer re-assesses (Article 15(4)). The declaration must be in, or translated into, a language the member state requires, and authorities check a share of declarations every year (Article 39(5)).
Can a supplier refuse to give the data?
No. A supplier must give the manufacturer all information and documentation needed to demonstrate conformity, including for the materials (Article 16(1)).
What a spreadsheet cannot do here
A declaration signed today must still match its documentation in five or ten years. A spreadsheet that is overwritten when the box changes no longer shows which materials, weights and supplier answers the old declaration rested on.
What Tarafex does
One row per component with its material and weight, the supplier's answer recorded with who gave it, and the weight frozen on the shipment line on the day it ships — so each declaration is drawn from a copy that does not change afterwards. Tarafex does not sign your declaration and is not a conformity assessment body.
Sources: Regulation (EU) 2025/40, Articles 15, 16, 38, 39, Annexes VII and VIII; Commission PPWR FAQ, 2nd edition, August 2026. Checked 17 September 2026. This is information, not legal advice.