PPWR Declaration of Conformity: What It Is and How to Get One
From August 2026, every packaging type placed on the EU market needs a Declaration of Conformity – a document proving it meets PPWR requirements. The manufacturer creates it. Importers must keep a copy. Distributors verify compliance but don't need to hold one.
What is a Declaration of Conformity?
The Declaration of Conformity (DoC) is a legal document where the packaging manufacturer declares that their packaging meets PPWR requirements. It's a self-declaration backed by technical documentation – not a certificate issued by a third party.
The manufacturer shall draw up an EU declaration of conformity... and keep the EU declaration of conformity and the technical documentation for 10 years after the reusable packaging has been placed on the market, or for 5 years after the single-use packaging has been placed on the market.
Required from 12 August 2026. One DoC per packaging type (not per SKU). Signed by the manufacturer. Kept for 5 years (single-use) or 10 years (reusable).
It's not a CE marking – the PPWR explicitly avoids CE marks to prevent confusion with product-level markings. And it's not a test certificate from a lab.
What must it contain?
The DoC must follow the structure in Annex VIII of the PPWR:
The EU declaration of conformity shall contain the following information: a unique identification number, the name and address of the manufacturer, a statement that the declaration is issued under the sole responsibility of the manufacturer...
| Element | What it means |
|---|---|
| 1. Unique ID number | Manufacturer's internal reference (e.g., DoC-2026-00123) |
| 2. Manufacturer details | Name and address of who takes legal responsibility |
| 3. Sole responsibility | Statement that this is issued under manufacturer's sole responsibility |
| 4. Packaging identification | What packaging this covers – type, materials, description |
| 5. Conformity statement | Confirms compliance with PPWR Articles 5-12 |
| 6. Standards used | How you assessed compliance (RecyClass, ISO tests, etc.) |
| 7. Notified body | Usually N/A for packaging |
| 8. Additional info | Recyclability grade, recycled content %, etc. |
| 9. Signature, place, date | Required for legal validity |
Who is the "manufacturer"?
This is the key question. Only the manufacturer issues the DoC.
Under Article 3(13), "manufacturer" means:
- The entity that physically manufactures packaging, or
- Any entity that has packaging designed or manufactured under its own name or trademark — even if they don't make it themselves
'manufacturer' means any natural or legal person that manufactures packaging or a packaged product; however... where a natural or legal person has packaging or a packaged product designed or manufactured under its own name or trademark, regardless of whether any other trademark is visible on the packaging or on the packaged product, 'manufacturer' means that natural or legal person.
If your brand name or trademark appears on the packaging, you are the manufacturer. You must issue the DoC yourself.
Exception: If you're a micro-enterprise and your packaging supplier is in the same EU Member State, the supplier is considered the manufacturer instead (Article 3(13)(b)).
What do I need to do?
Your obligations depend on your role in the supply chain:
| I'm a... | Then I need to... | Legal basis |
|---|---|---|
| Manufacturer (I make packaging, or my name/trademark is on it) | Create, sign, and issue the DoC. Keep technical documentation for 5 years (single-use) or 10 years (reusable). | Art. 15(2), 15(3) |
| Importer (I bring packaging from outside the EU into the EU market) | Verify the manufacturer has created the DoC before placing on market. Keep a copy for 5–10 years. | Art. 18(2), 18(7) |
| Distributor (I resell packaged products within the EU) | Verify labelling is correct and manufacturer/importer met identification requirements. No DoC copy required. | Art. 19(2) |
| Supplier (I supply packaging or materials to a manufacturer) | Provide documentation to enable the manufacturer to create the DoC. | Art. 16(1) |
What if I'm a brand that buys packaging?
This is the most common question — and the regulation covers it in two ways.
Route 1: You commission custom packaging
If you have packaging designed or manufactured under your own name or trademark, you are the manufacturer from the outset — regardless of who physically produces it.
Where a natural or legal person has packaging or a packaged product designed or manufactured under its own name or trademark, regardless of whether any other trademark is visible on the packaging or on the packaged product, 'manufacturer' means that natural or legal person.
Route 2: You place packaging on the market under your name
Even if you didn't commission the packaging — say you buy generic stock boxes and add your own label — Article 21 catches you. If you place packaging on the market under your name or trademark, you become the manufacturer and take on all manufacturer obligations, including the DoC.
Where an importer or a distributor places packaging on the market under its own name or trademark or modifies packaging already placed on the market in a way that could affect compliance with the relevant requirements of this Regulation, that importer or distributor shall be considered to be a manufacturer for the purposes of this Regulation and shall be subject to the obligations of the manufacturer under Article 15.
Recital 82 confirms the intent:
Any importer or distributor that either places on the market packaging under their own name or trademark or modifies packaging already placed on the market in a way that could affect compliance with this Regulation should be considered to be the manufacturer and should assume responsibility for the manufacturer's obligations.
Example
You buy plain kraft mailer boxes from a supplier
No branding on the packaging itself. The supplier is the manufacturer and issues the DoC. You collect it as an importer or distributor.
You buy those same boxes but print your logo on them
Your trademark is now on the packaging. Under Article 21, you are the manufacturer. You must issue the DoC yourself.
You commission a supplier to produce custom packaging with your brand
You had it "designed or manufactured under your name." Under Article 3(13)(a), you are the manufacturer. You must issue the DoC yourself.
Micro-enterprise exception
Both Article 3(13)(b) and Article 21 include the same relief: if you're a micro-enterprise (fewer than 10 employees and under €2M turnover) and your packaging supplier is EU-based, the supplier becomes the manufacturer and takes on the DoC obligation.
"Manufacturer" vs. "Producer" — they're different roles
These two terms look similar but mean different things under PPWR:
- Manufacturer (Art. 3(13)) — issues the DoC and ensures packaging is compliant before it reaches the market
- Producer (Art. 3(15)) — handles Extended Producer Responsibility: waste reporting, EPR fees, and registration in each market
You can be both. Many brands are. The important thing is knowing which obligations fall on you and when.
Not sure who should issue your DoC? We can help you work through the specifics of your supply chain and make sure you're set up correctly before August 2026.
Example Declaration of Conformity
See what a completed DoC looks like. Use this as a reference when requesting documentation from your suppliers or when creating your own.
Download example (PDF)What's the technical documentation?
The DoC is just the declaration. Behind it sits the technical documentation (Annex VII) that proves the claims are true:
The technical documentation shall contain... a general description of the packaging and its intended use, design and manufacturing drawings, descriptions of the procedures to ensure conformity...
- General description of the packaging and intended use
- Design drawings and material specifications
- Recyclability assessment (how you determined the grade)
- Recycled content certificates
- Substance test reports (PFAS, heavy metals)
- Minimisation assessment (why the packaging isn't oversized)
The manufacturer keeps this documentation. As a brand, you don't need to hold it – but you should know it exists and can be produced if authorities ask.
Common questions
Who issues the DoC — me or my supplier?
If your name or trademark is on the packaging, you issue it. If you're buying generic packaging without your branding, your supplier issues it. The key is Article 3(13): whoever's name is on the packaging is the manufacturer.
Do I need a separate DoC for each SKU?
No. One DoC per packaging type. If you have 50 SKUs using the same bottle, one DoC covers all of them.
What if my packaging has multiple components?
The DoC covers the complete packaging unit. Your technical documentation should detail each component.
Do distributors need to keep a copy of the DoC?
No. Article 19 requires distributors to verify labelling and that the manufacturer/importer met identification requirements — but not to hold DoC copies. Only importers must keep copies (Article 18(7)).
What language does it need to be in?
It must be available in a language understood by authorities in the member state where the packaging is placed on the market.
What happens if I don't have one?
The packaging cannot legally be placed on the EU market. Penalties vary by member state. There's still time to get this sorted before August 2026.
Your options
You can manage DoC collection manually – requesting documents from each supplier, tracking versions, and storing them for audits. Or you can let Circulate handle it as part of your packaging compliance workflow.
We collect and verify Declarations of Conformity from your suppliers, flag gaps in your portfolio, and keep everything audit-ready. It's one less thing to manage.
References
Last updated: May 2026. This page provides general guidance and should not be considered legal advice.