How to Write a Declaration of Conformity (DoC) under the EU PPWR Regulation

Who Needs a Declaration of Conformity under the PPWR Regulation?

Under the EU PPWR regulation, every economic operator who places packaging on the EU market must be able to provide a DoC for their packaging. This applies to:

• Manufacturers of packaging
• Importers bringing packaging into the EU
• Authorized representatives of non-EU manufacturers
• Fulfillment service providers placing packaging on the market

The DoC must be kept up to date and made available to market surveillance authorities upon request.

The 8 Required Sections

A DoC for packaging under the PPWR must contain the following sections, as defined in Annex VII:

1. Packaging Identification

Identify your packaging with the following details:

• Packaging type: Sales packaging, grouped packaging, or transport packaging
• Name: A clear, descriptive name for the packaging
• External ID: Your own reference number or article number
• Internal ID: An additional internal identifier (e.g., SKU)

This section ensures the packaging can be uniquely identified and traced.

2. Producer Information

Provide the full details of the economic operator (producer/manufacturer):

• Company name
• Full address including street, postal code, city, and country

3. Responsibility Statement

Include a statement confirming that the DoC is issued under the sole responsibility of the producer. This is a mandatory legal declaration.

4. Subject of the Declaration

This is the core of the DoC. You must provide a detailed description of the packaging:

• Restate the packaging type, name, and identifiers
• Provide a comprehensive description of the packaging composition, including the materials used and their respective weights

The description should be thorough enough for authorities to understand the packaging's construction and material composition. This typically means listing all materials involved and specifying their weight contributions.

5. EU Legislation

Reference the applicable EU harmonization legislation. For packaging, this typically includes:

• Regulation (EU) 2025/40 (PPWR) – the primary regulation for packaging and packaging waste
• Regulation (EC) No 1907/2006 (REACH) – for chemical substance restrictions

In this section, you must also confirm compliance with the substance restrictions laid out in Article 5 of the PPWR:

Heavy Metals (Article 5(2)–(3))

The sum concentration of lead, cadmium, mercury, and hexavalent chromium must not exceed 100 mg/kg in the packaging.

PFAS Restrictions (Article 5(4))

Packaging must be free from per- and polyfluoroalkyl substances (PFAS) above the thresholds specified in the PPWR.

REACH Compliance

No substances banned or restricted under REACH may be used in the packaging.

This assessment should be based on available technical documentation, including supplier declarations, safety data sheets (SDS), and where applicable, analytical test reports.

6. Declaration

Include a formal declaration statement confirming that the packaging complies with all applicable requirements of Regulation (EU) 2025/40, in particular the substance restrictions under Article 5.

7. Notified Body Certificates

If applicable, reference any certificates from notified bodies. For most standard packaging, this section can state "Not applicable."

8. Additional Information

Complete the DoC with:

• Signatory: Name and position of the authorized person
• Place of issue: The address where the DoC is signed
• Date of issue: The date the DoC is created
• Signature: The handwritten or electronic signature of the authorized person

Technical Documentation (Annex VII)

In addition to the DoC itself, you must maintain technical documentation that supports the declarations made. This may include:

• REACH compliance declarations from material suppliers
• Safety data sheets (SDS) for materials used
• Analytical test reports for heavy metal concentrations (if available)
• PFAS test results or supplier declarations
• Any other documentation demonstrating compliance

This documentation must be kept available for at least 5 years (single-use) and 10 years (reusable) after the packaging was placed on the market.

Common Mistakes to Avoid

1. Incomplete packaging descriptions: The packaging description must be detailed enough for authorities to assess compliance.
2. Missing substance assessments: Heavy metal and PFAS assessments are mandatory, not optional.
3. Outdated supplier declarations: Ensure your REACH and material declarations are current.
4. No signatory: The DoC must be signed by an authorized person with their name and position.
5. Confusing packaging with product: The DoC covers only the packaging, not the product inside.

Official EU Template

The European Union provides an official template for the Declaration of Conformity in Annex VIII of the PPWR regulation. You can use this template as a starting point for your own DoC:

Annex VIII – Model for the EU Declaration of Conformity (EUR-Lex)