Effective August 12, 2026, the EU Packaging Regulation (PPWR) will apply directly. In addition to EPR compliance (such as LUCID registration), a legally binding EU Declaration of Conformity (DoC), including technical documentation, will be mandatory for all packaging.
Who needs to take action?
- Producers: Anyone who manufactures packaging or places packaged goods on the market under their own brand (and determines the design) must issue and sign the DoC.
- Importers: Anyone who imports packaged products from non-EU countries must obtain a copy of the DoC and keep the technical documentation available for authorities.
- Retailers & Distributors: They have monitoring obligations and must verify that the Declaration of Conformity and required markings are present.
What additional steps are required?
Responsible companies must demonstrate, before placing any packaging on the market, that it meets all PPWR requirements (e.g., regarding hazardous substances, recyclability, or minimization). This is done in four steps:
- Conduct a conformity assessment:
The packaging is systematically tested and evaluated against the statutory PPWR criteria. - Prepare technical documentation:
A comprehensive dossier must be created. It contains evidence regarding materials, composition, limits for hazardous substances (such as PFAS), and recycling performance levels. - Issue an EU Declaration of Conformity:
Upon successful verification, the manufacturer issues the formal, legally binding EU Declaration of Conformity (DoC) and keeps it up to date at all times. - Archiving documents:
The technical documentation and the DoC must be retained in a legally compliant manner from the date of the last placing on the market; 5 years for single-use packaging, 10 years for reusable and transport packaging
What can an existing compliance partner handle?
An existing partner can help companies align their EPR obligations with PPWR requirements.
- Portfolio Analysis: Assessing exactly which of your packaging items and packaging types are affected.
- Role Identification: Clearly determining who in your supply chain is legally liable as a “manufacturer” or “producer.”
- Data & Supplier Coordination: Obtaining and reconciling the necessary technical evidence from upstream suppliers.
- Document Management: Structuring, legally compliant preparation, and archiving of technical documentation and the DoC.
- Intermediary Role: Facilitating and coordinating between manufacturers, brand owners, and packaging suppliers.
Important: German LUCID registration and participation in a dual system remain mandatory. However, they only cover waste disposal financing (EPR) and in no way replace the new product-specific PPWR conformity assessment.
Are you still looking for a compliance partner? Contact us!
www.ecopv-eu.com/en/contact/ | 
E-Mail: info@ecopv-eu.com
Supported over 20,000 customers with EPR compliance
Rated 5.0 on Google
Contact
We look forward to your message!
