PPWR Declaration of Conformity: The Legal Foundation for Packaging Starting in August 2026

The new EU Packaging Regulation (PPWR) will take effect on August 12, 2026. Without a legally binding Declaration of Conformity (DoC), packaging may no longer be placed on the EU market.

What exactly is this declaration?

It is a written self-declaration by the manufacturer or importer. With it, you officially confirm that a type of packaging meets all sustainability and recyclability requirements set forth in Articles 5 through 12, as well as Articles 24 and 26 of the PPWR.

The most important core requirements include, among others:

  • Prohibitions on hazardous substances: Strict compliance with limit values (e.g., for heavy metals and PFAS).
  • Recyclability: Design in accordance with clear guidelines for recycling (“Design for Recycling”).
  • Material minimization: Reducing packaging weight and empty space to a minimum.
  • Recycled materials & reusable packaging: Evidence of the use of recycled materials and reusability.
  • Supply chain assurance: Documentation requirements for manufacturers and importers to ensure traceability.

Key Points at a Glance:

  • Who is required to take action? The primary responsibility lies with manufacturers and brand owners (including retailers’ private labels), as well as importers who bring in packaging from non-EU countries.
  • What is the foundation? The DoC must be based on complete technical documentation. This must include test reports on materials, hazardous substances, and recyclability.
  • No CE Mark: The PPWR does not require CE marking. Proof of conformity is provided solely through the DoC and the technical documentation.
  • Strict retention requirements: All documents must be archived from the date of placing on the market – 5 years for single-use packaging and 10 years for reusable systems.

Questions about the PPWR?

We’re here to support you so that you can get off to a legally compliant start and begin selling as soon as the regulation takes effect in August.

 

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