PPWR Declaration of Conformity: What It Is and How to Get One
From August 2026, every packaging type sold in the EU needs a Declaration of Conformity – a document proving it meets recyclability, safety, and labelling requirements. The packaging manufacturer creates it. Everyone else in the supply chain needs to collect and keep it.
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 |
What do I need to do?
Your obligations depend on your role in the supply chain:
| I'm a... | Then I need to... |
|---|---|
| Packaging manufacturer (I make the packaging) | Create, sign and issue the DoC. Maintain technical documentation for 5 – 10 years. |
| Importer (I bring packaged goods into the EU) | Verify DoC exists before placing on EU market. Keep a copy. |
| Packaging supplier (I sell packaging to brands) | Provide DoC and supporting documentation to your customers. |
| Distributor (I resell packaged products within EU) | Verify packaging is compliant and manufacturer has met obligations. |
| Brand / Producer (I fill packaging and sell products) | Collect DoC from your packaging suppliers. Keep on file for 5 – 10 years. |
Supplier won't provide a DoC? From August 2026, packaging without a valid DoC cannot be placed on the EU market. We can help you find alternatives through our supplier network.
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
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.
What language does it need to be in?
It must be available in a language understood by end users 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 country – from sales bans to significant fines. The good news: 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.