PPWR Declaration of Conformity and Technical Documentation: What Companies Must Submit from August 12, 2026

From 12 August 2026, no packaging may be placed on the EU market unlessit is supported by a valid Declaration of Conformity (DoC) and completetechnical documentation. This is the point at which the PPWR (Packaging andPackaging Waste Regulation, Regulation (EU) 2025/40) becomes operational forcompanies — shifting the burden of proof from a one-off check to a permanent,audit-ready documentation process across the entire supply chain.

This article explains what the Declaration of Conformity is from a legal standpoint, which mandatory elements are prescribed by Annex VIII, how the technical documentation required under Annex VII must be structured, and how responsibilities are divided between the producer, importer, and distributor.This is followed by the operational section: how companies can obtain conformity evidence from suppliers at scale, which common mistakes occur in practice, and what additional considerations apply in the German legal context.

What is the Declaration of Conformity (DoC)?

The EU Declaration of Conformity is the producer's written, self-certified statement that a specific packaging item meets the requirementsof Articles 5 to 12 of the PPWR. The legal basis is Article 39 of Regulation (EU) 2025/40; the model structure is set out in Annex VIII. By signing the DoC, the producer assumes full legal responsibility for the conformity of thepackaging (Article 39(4)).

The requirements covered range from substance restrictions (Article 5, inparticular heavy metals and PFAS) to recyclability (Article 6), minimumrecycled content (Article 7), bio-based plastics (Article 8), compostability(Article 9), packaging minimisation (Article 10), and reuse and refill(Articles 11 and 12). The DoC is therefore not a quality mark or a testcertificate — it is a legally binding self-declaration based on technicaldocumentation.

One important point to understand: the PPWR deliberately does not use CEmarking for packaging. Recital 109 explains that a CE mark on packaging couldbe confused with product-related CE markings. PPWR conformity is insteaddemonstrated exclusively through the DoC and the underlying technical documentation.

Mandatory contents of the DoC according to Annex VIII

Annex VIII of the PPWR specifies ten mandatory elements that every Declaration of Conformity must contain. If any of these elements are missing, the declaration is invalid, and the packaging is considered not to have been placed on the market in conformity – with corresponding sanction and distribution risks.

1. Unique identification number of the declaration, which allows traceability to the producer's internal system (e.g., SAP material number, internal item number).
2. Name and address of the producer, or authorized representative if applicable. This clearly identifies who bears legal responsibility.
3. Declaration that the DoC is issued under the sole responsibility of the producer.
4. Unique identification of the packaging, including type, batch, serial number, or other traceability elements. A general statement ("all our packaging") is explicitly not sufficient.
5. Description of the packaging, including materials and essential characteristics.
6. Declaration of Conformity with explicit reference to Regulation (EU) 2025/40 and Articles 5 to 12.
7. Reference to harmonised standards or common specifications used. Where harmonised standards do not yet exist in 2026, the technical specifications or internal methods applied must be stated.
8. Details of the notified body, if relevant. For the standard Module A procedure (internal production control), no notified body is required, which applies to the majority of all packaging.
9. Supplementary information relevant to the declaration of conformity.
10. Signature, place and date, provided by the producer or on their behalf. Without a valid signature, the DoC has no legal effect.

The language requirement is an often-overlooked point: the DoC must be provided in a language that is easily understood in the Member State where the packaging is placed on the market. For companies with EU-wide distribution, this means having the documents available in the relevant official languages or at least making them translatable at short notice.

What is mandatory by 12 August 2026 – and what applies later?

The DoC obligation itself takes effect immediately from 12 August 2026, but not all requirements of Articles 5 to 12 are effective at that time. A DoC issued in 2026 will only refer to the articles that are legally applicable at that time. The list in the DoC and the underlying technical documentation will expand with further deadlines – a DoC issued in 2026 will need to be expanded and updated in content in 2030 and 2038.

Mandatory to demonstrate by 12 August 2026:

• Conformity assessment according to Module A (Article 38, Annex VII) for each packaging placed on the market
• Complete technical documentation according to Annex VII
• Signed Declaration of Conformity according to Article 39 and Annex VIII
• Compliance with limits for substances of concern (Article 5): Heavy metals (lead, cadmium, mercury, hexavalent chromium) with a total maximum value of 100 mg/kg, as well as PFAS limits for food contact packaging (max. 25 ppb per individual substance, 250 ppb in total; 50 ppm for PFAS including polymeric PFAS)
• Minimization of packaging weight and volume (Article 10) – the qualitative assessment will be part of the technical documentation from 2026, but the specific 50 percent empty space rule for group, transport, and e-commerce packaging will only apply from 2030
• Requirements for reusable packaging (Article 11) for packaging placed on the market as reusable
• Identification and traceability obligations of economic operators (Arts. 15–22)
• Verification and retention obligations for importers and distributors

Practical consequence: A DoC issued by August 12, 2026, primarily refers to Article 5 (substance restrictions), Article 10 (minimization – qualitative), and, where applicable, Article 11 (reusability). The technical documentation must fully substantiate these points. Later requirements – particularly regarding recyclability by class and recycled content – will be incorporated into the DoC as soon as they become legally effective.

The technical documentation according to Annex VII

The DoC is the apex of the documentation pyramid – the foundation is the technical documentation according to Annex VII. This undergoes the so-called Module A – internal production control, which is regulated in Article 38 and Annex VII of the PPWR. An examination by an external notified body is not foreseen in the standard case; the producer assesses conformity internally and bears full responsibility for this assessment.

The technical documentation must contain at least:

• a general description of the packaging and its intended use,
• design and construction drawings, as well as plans of components, parts, and layers,
• material composition of all components,
• list of applied harmonized standards or other specifications,
• qualitative assessment of recyclability, minimization, and, where applicable, reusability in accordance with Articles 6, 10, and 11,
• results of calculations for recycled content (Article 7), and
• test reports and evidence concerning substances of concern in accordance with Article 5.

The EU Commission clarified in its final guideline of March 30, 2026, that the technical documentation must be made fully available to the market surveillance authority upon request within ten days. For companies with portfolios of several hundred or thousand packaging variants, this is not feasible without structured, digital storage at the product and bill of material level.

A DoC without supporting technical documentation is legally ineffective – technical documentation without a DoC means that the producer has not made a formal statement of conformity. Both documents are part of an inseparable package of evidence.

Who creates the DoC – and who verifies it?

The roles defined by the PPWR clearly delineate responsibilities, but in practice, they are often conflated. The crucial distinction is between the producer (Article 15) and the downstream actors: importer (Article 18) and distributor (Article 19).

Producer (Article 15): The producer is the company that manufactures the packaging or has it manufactured under its own name or brand. They carry out the conformity assessment, prepare the technical documentation according to Annex VII, sign the DoC according to Annex VIII, and retain both documents for five years (single-use packaging) or ten years (reusable packaging) after placing them on the market. Non-EU producers must also appoint an authorized representative in the EU to handle conformity tasks.

Importer (Article 18): Before placing packaging on the market, the importer must verify whether the producer has carried out the conformity assessment, prepared the technical documentation, and signed the DoC. They must keep a copy of the DoC themselves (Article 18, paragraph 7), make it available to market surveillance authorities upon request, and are responsible for ensuring that storage and transport do not compromise the packaging's conformity. In case of signs of non-conformity, the importer must immediately take corrective measures.

Distributor (Article 19): The distributor verifies whether the producer and importer have fulfilled their labeling and identification obligations. They are not required to keep the DoC themselves but must not place or make available any visibly non-compliant packaging on the market.

Reclassification according to Article 21: An importer or distributor becomes a producer within the meaning of the PPWR if they place packaging on the market under their own name or brand, or if they modify packaging already on the market in such a way that its conformity may be affected. In this case, the full producer obligations apply to them, including the preparation of the technical documentation and the DoC. This scenario is typical for private-label approaches and store brands.

For companies that both purchase packaging and process it further under their own name, this means: The role must be assessed individually for each product and each Member State. A blanket assignment of roles at the company level is not possible under the PPWR.

Retention Periods and Market Surveillance in Germany

The PPWR prescribes differentiated retention periods: five years for single-use packaging and ten years for reusable packaging, each calculated from the date the packaging was last placed on the market. This applies to both the DoC and the underlying technical documentation and equally to producers, importers, and – within the scope of their reduced obligations – distributors.

In Germany, market surveillance is expected to be carried out by the state authorities (trade supervisory offices, environmental authorities) in coordination with the Federal Environment Agency (UBA) and the Central Agency Packaging Register Foundation (ZSVR). The specific responsibilities will be clarified within the framework of the Packaging Implementation Act (VerpackDG), which supports the national implementation of the PPWR. Even though the Packaging Act (VerpackG) remains in force, key documentation requirements will henceforth be derived directly from the PPWR – in particular, the DoC is a PPWR instrument that did not previously exist in German law.

Violations under Article 62 of the PPWR can lead to the imposition of corrective measures, sales bans, recalls, or market withdrawals. The German penalty frameworks will be specified via the VerpackDG; fines of up to 200,000 Euros are expected for a missing declaration of conformity, incomplete technical documentation, or lack of registration.

The operational challenge: Scalably obtaining and managing DoCs

For manufacturing companies that do not produce their own packaging but purchase it, the effort shifts to supplier communication. The number of packaging variants in a medium-sized industrial portfolio can easily be in the three- to four-digit range – and each individual variant requires its own DoC.

1. Supplier and Packaging Mapping: The first step involves recording the complete packaging portfolio at the product and bill of material level and assigning it to the respective suppliers. A supplier providing three different packaging formats must provide three separate DoCs.

2. Structured Request: In practice, an open request ("Please send us your PPWR documents") often results in ISO 9001 certificates, food contact declarations, or general company confirmations – not a PPWR-compliant DoC. The request should therefore explicitly include: a DoC per packaging type according to Annex VIII, confirmation that the technical documentation according to Annex VII exists and is available upon request, the specific identification of the affected packaging types, as well as the required language and format.

3. Tracking and Gap Management: A simple spreadsheet is not enough: What's needed is a status per packaging type and supplier, including receipt date, expiration date for changes, and an escalation path for missing responses.

4. Audit-Proof Storage with Versioning: If packaging changes – material, recycled content, labeling – the DoC must be updated. Without version history, it's impossible to reconstruct which DoC was valid for which period in the event of an audit.

Common Errors in PPWR Documentation

In the months leading up to its applicability, six common error patterns have emerged that can be avoided with clear processes:‍

• ‍Existing Quality Certificates as a Substitute: An ISO 9001 certificate or a food contact declaration does not replace a PPWR DoC. The DoC must explicitly refer to Regulation (EU) 2025/40.‍
• Blanket DoC for the entire product range: Annex VIII requires the unique identification of each packaging. A general declaration does not meet this requirement.‍
• DoC without underlying technical documentation: If market surveillance requests the technical documentation and the producer or importer cannot provide it within the deadline, conformity is considered not proven.‍
• Missing update process: In the event of material changes, new suppliers, or design modifications, the DoC must be updated. Without a structured process, documents become outdated unnoticed.‍
• Unstructured storage: A five to ten-year retention period in email folders is not audit-proof in practice. Searchable, versioned systems with clear access rights are required.

PPWR Documentation in the Context of Existing German Packaging Regulation

The German Packaging Act (VerpackG) remains in force, with its core focus on Extended Producer Responsibility (EPR) and registration in the LUCID register with the ZSVR. The PPWR complements this regime with a new, clearly distinct level: product-related conformity assessment per packaging.

For companies, this means two parallel sets of obligations in practice. On the one hand, LUCID registration, licensing through a dual system, and quantity reporting to the ZSVR remain in place. On the other hand, from August 12, 2026, the new PPWR level will be added – conformity assessment, technical documentation, and DoC per packaging type. Both levels have different addressees and different verification logics, but should be integrated from a data perspective, as they are based on the same packaging master data.

The Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection (BMUV) and the Federal Environment Agency have announced that they will regulate the German implementing provisions through a Packaging Implementation Act (VerpackDG). Until this law is passed, the immediate obligations of the PPWR will be directly applicable beyond August 12, 2026 – regardless of whether the national sanction provisions have already been fully formulated.

What Companies Should Do Now

1: Clarify your role for each packaging type and Member State. Is the company a producer, importer, distributor – or does it become a producer under Article 21? All further obligations depend on this.

2: Establish a comprehensive packaging master data foundation. Without structured data on material composition, weight, recycled content, recyclability, and supplier, it's impossible to create a DoC or verify the completeness of incoming supplier DoCs. The bill of materials and packaging specification will become the central data source.

3: Initiate dialogue with suppliers early. Producers need time to establish their own conformity assessments. Those who only inquire in July 2026 are highly unlikely to receive reliable DoCs by the deadline.

The PPWR is not a reporting obligation that can be corrected retrospectively. It is a continuous documentation requirement that applies from August 12, 2026, to every packaging placed on the market – and thus directly impacts operational logistics, procurement, and production processes. Companies that centrally consolidate Declarations of Conformity (DoC), technical documentation, and packaging master data at the product and bill of material level create the foundation to scalably meet not only the August 12, 2026 deadline, but also subsequent milestones until 2040.