"What on earth do they want from me now with this packaging?"
That's the question thousands of business owners in Germany and across the EU are asking themselves right now. You've heard of PPWR, of LUCID, maybe of the authorised representative requirement — and now another term shows up: EU Declaration of Conformity. This guide doesn't walk through the legal paragraphs in order. It answers the questions that actually come up when you first deal with this — including the ones where the obvious answer turns out to be wrong.
TL;DR - The Declaration of Conformity is not a lab certificate — it's your own documented statement that you have checked conformity. - You do not need a separate declaration for every product — it applies per packaging specification, not per SKU. - You do not need to run your own lab tests — you rely on the information from your packaging supplier. - Heavy metal limits did not start with PPWR — they have existed since 1994. - Retention period: 5 years for single-use packaging, 10 years for reusable packaging.
Official sources: Regulation (EU) 2025/40 (PPWR), Annex VIII, Gesetze im Internet — VerpackG, Zentrale Stelle Verpackungsregister (LUCID)
Question 1: What even is this new declaration?
The EU Declaration of Conformity is not a new "packaging licence" and not a certificate issued by a lab. It's an official statement by the manufacturer that conformity of the packaging with the applicable PPWR requirements has been established.
The legislator isn't only saying "your packaging must meet the requirements" — it's adding: "you must be able to document why you consider it compliant." That's the actual change compared to before: not suddenly new substantive requirements out of nowhere, but a more formalised system of requirement → conformity assessment → technical documentation → declaration of conformity.
Question 2: Does this only affect foreign companies?
No — and this matters, because it's an easy thing to get muddled. The declaration of conformity itself applies to anyone placing packaging on the German or EU market, regardless of where the company is based. Foreign companies without an establishment in Germany additionally face the requirement to appoint an authorised representative (see our VerpackDG 2026 guide for more) — but that's a separate topic, not a precondition for the declaration of conformity itself.
Question 3: Do I need to send my packaging to a lab now?
Not automatically. PPWR provides for internal production control for most packaging — not mandatory third-party lab testing of every individual packaging item. Conformity assessment does not automatically mean a lab requirement.
Question 4: So do I have to check myself whether there's mercury in it?
No — and this question is a good illustration of where the line actually sits. Chemical composition can't be determined by looking at something. Where evidence is needed for a specific chemical or technical property, it has to be backed by appropriate information or evidence — but you as a business owner don't have to run your own lab analysis just because you're signing a declaration.
Question 5: Can I just trust my supplier?
Here the answer is a bit more nuanced: you may rely on supplier information — but not blindly. Your packaging supplier must provide you with the information you need, such as:
- material and composition
- technical properties
- weight
- information on relevant substances (heavy metals, PFAS)
- existing declarations
- test results, where available
The flow is: supplier information → your own assessment → documentation → declaration. You take responsibility for using that information sensibly and keeping it on file — not for generating it yourself in a lab.
Question 6: Are the heavy metal limits new?
No, not at all — and that's reassuring to know. The restriction on lead, cadmium, mercury and hexavalent chromium in packaging has existed since the EU Packaging Directive 94/62/EC of 1994. The 100 mg/kg limit (combined for all four substances) has applied in its current form since 2001. PPWR carries this limit over unchanged (Art. 5(4)) — packaging manufacturers are not starting from zero in August 2026.
Question 7: So what actually is new?
The novelty isn't that packaging was completely unregulated yesterday and suddenly regulated today. The core is that PPWR introduces a more formalised system — requirement → conformity assessment → technical documentation → declaration of conformity. Conformity now has to be systematically documented and officially declared, not just "somehow" met.
Question 8: Do I have to attach all supporting documents to the declaration?
No. This distinction matters, especially for our generator:
The declaration of conformity is a short, standalone document. The technical documentation — supplier information, specifications, assessments, test reports where applicable — stays on file with you and is not attached page by page to the declaration.
| Declaration of Conformity | Technical Documentation | |
|---|---|---|
| What it is | Short, formal document (Annex VIII) | Collection of evidence (Annex VII) |
| Who sees it | Can be shown to authorities/customers | Stays with you, only on request |
| Contains | Statement of conformity, references | Supplier data, specifications, test reports |
Question 9: Do I definitely need lab reports?
No, not automatically for every declaration. Test reports are listed as evidence in the technical documentation "where applicable" — not as a blanket requirement for every single packaging item. The right way to put it isn't "everyone needs a lab certificate" but: you need to have sufficient evidence to demonstrate conformity. What counts as sufficient evidence depends on the specific requirement and the packaging in question.
Question 10: One declaration per product?
No — and this is probably the most important question of all, especially if you have a large product range.
100 SKUs don't automatically mean 100 declarations. If several products use exactly the same packaging with identical characteristics, it's entirely logical to treat that as one identifiable packaging type.
Example: 7 honey varieties in the same 900g glass jar. You do not need:
Honey 1 → Declaration 1 Honey 2 → Declaration 2 Honey 3 → Declaration 3 ...
One joint declaration is enough, listing all the SKUs it covers.
Question 11: So one declaration per material?
Also no. Not: glass → one declaration, lid → another, label → a third. The declaration relates to the identifiable packaging as a whole, not a single material. "900g glass jar with metal lid and paper label" can be the description of a single packaging type made up of several components.
Question 12: What counts as a "packaging specification"?
Some caution is needed here — honestly, on our side too: PPWR requires a clear identification of the packaging (e.g. via type, batch or serial number), but it doesn't set out a rigid rule like "one packaging type always equals one declaration." The more accurate way to put it: the declaration must make it possible to clearly determine which packaging it relates to. Combining several packaging items into one declaration is possible where their characteristics and applicable requirements allow for such a joint assessment.
Question 13: What if the packaging has several components?
Honey → glass jar → lid → label → protective material → shipping box — for multi-component packaging you can't simply say "everything that physically surrounds the product is automatically one declaration." It's worth distinguishing different roles:
- primary packaging (direct product contact)
- secondary packaging (grouping packaging)
- transport packaging
- shipping/e-commerce packaging
For larger product ranges with several packaging variants, it's worth going through this structure carefully once, rather than lumping everything into one declaration by default.
Question 14: If I switch suppliers, do I have to redo everything?
Not necessarily. A supplier change is a reason to check documentation and conformity — not an automatic requirement to start from scratch. If the new supplier delivers packaging with the same relevant characteristics, it's enough to obtain their documentation and confirm the existing assessment still applies. If the characteristics have changed, the assessment needs to be revised accordingly.
Question 15: When do I need to update the declaration?
Not "create once, forget forever." The declaration has to be kept up to date, especially when there are changes to:
- packaging, material or construction
- supplier, if that affects the characteristics or evidence
- applicable requirements
- other circumstances relevant to conformity
Question 16: How long do I have to keep it?
| Packaging type | Retention period |
|---|---|
| Single-use packaging | 5 years |
| Reusable packaging | 10 years |
Important: this applies not only to the declaration PDF itself but also to the underlying technical documentation.
Question 17: What do I actually do now?
One labelling point we had to correct
While researching this article, we came across a widespread but inaccurate claim: that the LUCID registration number must, under §9 VerpackG, be printed on the packaging itself. That's not correct — §9 VerpackG governs your company's registration obligation with the ZSVR, not printing the number on physical goods. The number doesn't even have to be published in your website's legal notice. What actually has to appear on the packaging is set out in PPWR Art. 15(5) — more on that in our labelling requirements guide.
Frequently Asked Questions
Is the Declaration of Conformity the same as LUCID registration? No. LUCID registration is registering your company in the German packaging register (§9 VerpackG). The Declaration of Conformity is a separate document under PPWR Annex VIII confirming the conformity of a specific packaging item.
Is a rough material description like "cardboard" or "plastic" enough? For a first draft, yes — but for the final declaration you need the precise detail from your technical documentation, not just a rough description.
What if I have several packaging variants with different materials? Then you need a separate packaging ID and, accordingly, a separate declaration for each distinct packaging specification — but within each variant, you can list as many products as you like that use exactly the same packaging.
Where can I fill this out in practice? With our Declaration of Conformity Generator — with explanations for every field and a live preview, free during the trial period.
Conclusion
This declaration is not a chemistry exam you have to run yourself, and not an obligation to create a separate document for every single product. It's a system: you identify your packaging, get the information you need from your supplier, check it, document it — and then officially declare that everything checks out. If you need help with this, contact us or use our generator directly.
About the Author
Nadezda Walz advises Amazon sellers and online retailers on packaging compliance in Germany and across Europe (LUCID, EPR, VerpackG/VerpackDG). Before moving into consulting, she ran her own Amazon FBA business — so she understands the seller's perspective not just from legal theory, but from practice.
