How to Fill In a PPWR Declaration of Conformity: Step by Step Through All 8 Points

Since 12 August 2026, packaging placed on the EU market needs an EU Declaration of Conformity under Article 39 of Regulation (EU) 2025/40 (PPWR). Its structure is fixed by Annex VIII: eight points in a set order.

This guide goes through every point: what to write, where the information comes from and where mistakes typically happen. Every legal statement links to the official text of the regulation on EUR-Lex. The examples come from our fully completed sample declaration, so you can compare line by line.

Before You Start: Two Things to Clarify

1. How many declarations you need. One declaration covers one packaging, not one product and not one order. A typical example:

• Honey jar + lid + label — together they form one packaging (sales packaging) → declaration 1. If 80 flavours of honey are sold in exactly this jar, it is still one declaration; all SKUs are listed in it.
• Shipping box + bubble wrap + tape — a second, separate packaging (transport packaging) → declaration 2.

Same order, two packagings, two declarations. A different jar, a different box size or a different lid means a new packaging and a new declaration. How many declarations do I need?

2. Where your product is sold. Packaging is rarely sold on its own — you buy it (often in China) and sell your product in it. What counts is where the product in this packaging is placed on the market: the declaration must be available in the language required by each of these EU countries (Art. 39(2)). The regulation does not provide for one general English version for the whole EU. Countries and languages explained

The 8 Points at a Glance

1. No. (unique identification of the packaging)
2. Name and address of the manufacturer and, where applicable, the authorised representative
3. Sole responsibility statement
4. Object of the declaration
5. Relevant Union harmonisation legislation
6. Harmonised standards, common or other technical specifications
7. Notified body
8. Additional information, place, date, signature

Header: The Declaration Number

An internal reference number for the document itself. There is no prescribed format; it only has to be unique so you can find the document again. Many businesses use year + sequential number.

Point 1: No. (Unique Identification of the Packaging)

No authority issues this number — you assign it yourself as an internal code for this packaging. It is not your product SKU: it identifies the packaging. A meaningful abbreviation helps you recognise later which packaging is meant. Different packaging means a different number and a separate declaration.

Point 2: Name and Address of the Manufacturer (and Authorised Representative)

The full company name as registered and an address where post can be served — a P.O. box is not enough. Under PPWR (definitions in Art. 3), the manufacturer is whoever places the packaging on the market under their own name or trademark, even if a third party physically produced it.

If you have appointed an authorised representative, their name and address go here as well. Businesses selling to end customers in Germany without an establishment there must appoint one. Authorised representative for packaging in Germany

Point 3: Sole Responsibility Statement

A fixed sentence from Annex VIII. It is copied word for word and never changed — nothing to fill in. Our PPWR generator inserts it automatically in the language of each country.

Point 4: Object of the Declaration

This is the most common weak spot in practice. The description must be precise enough for an authority to identify the packaging unambiguously: material, dimensions, construction, intended use. “Box” on its own is not enough.

You also state the type of packaging (Art. 3) — one of four:

• Sales packaging — surrounds the product when sold to the end customer (the honey jar with lid and label)
• Grouped packaging — bundles several sales units, e.g. a multipack
• Transport packaging — for shipping, e.g. the box with bubble wrap
• Service packaging — filled at the point of sale, e.g. a bakery bag

Important: the description is written in the language of every country where your product is sold. Our generator shows a separate field for each language.

Point 5: Relevant Union Legislation and Requirements Met

Here you name Regulation (EU) 2025/40 and tick only the requirements that actually apply to your packaging:

• Art. 5 — substances (heavy metals; PFAS only for food contact): practically always, applies since 12 Aug 2026
• Art. 6 — recyclability: applies only from 1 Jan 2030 — do not tick yet
• Art. 7 — recycled content: only if the packaging contains plastic
• Art. 9 — compostability: only if you claim the packaging is compostable
• Art. 10 — minimisation: applies only from 1 Jan 2030 — do not tick yet
• Art. 11 — reusable packaging: only for genuine reuse systems
• Art. 12 — labelling: harmonised label from 12 Aug 2028 at the earliest — do not tick yet

Ticking everything is a mistake: confirming Art. 9 for packaging that is not compostable is a false statement.

Point 6: Standards and Technical Specifications

Harmonised standards under PPWR are still being developed. That is why most businesses state the basis they actually rely on: standards used for orientation, internal checks, dated supplier declarations. For food-contact packaging, add Regulation (EC) No 1935/2004. Never list documents you do not have.

Point 7: Notified Body

For packaging, PPWR provides for conformity assessment under Module A (Annex VII): the manufacturer checks conformity itself, and no notified body is involved. Point 7 therefore normally reads “not applicable”.

Point 8: Additional Information, Place, Date, Signature

• Additional information (optional): your role (manufacturer, importer), registration number (LUCID in Germany, a national register elsewhere), contact, SKUs.
• Signature: a person authorised to sign for the company. By signing, the company takes full responsibility for conformity.
• Date: must not be later than the date the packaging is placed on the market.
• A typed name is sufficient — a handwritten signature is not required.

Worked Example: Honey Jar with Lid and Label

The box example above is transport packaging. Here is the most common case for food and cosmetics sellers — sales packaging that touches the product:

Because jar and lid touch food, the PFAS limits of Art. 5 apply: have your supplier confirm them with laboratory analysis results (see the request template below). The shipping box for the same order gets its own, second declaration.

Technical Documentation: Why the Declaration Needs It

The declaration states that the packaging complies. You may only draw it up once conformity has been demonstrated in the conformity assessment under Annex VII (Module A) — and that includes drawing up the technical documentation. A declaration without technical documentation behind it has no basis and cannot be defended in an inspection. You keep the documentation and show it on request of the authorities; it is not printed in the declaration.

It typically contains:

• each component of the packaging and its material (jar, lid, label — or box, padding, tape)
• a supplier confirmation on heavy metals (max. 100 mg/kg) and, for food-contact packaging, laboratory analysis results on PFAS (Art. 5) and confirmation of Regulation (EC) No 1935/2004
• the standards and internal checks you refer to in point 6

Our recommendation: request these documents from your packaging supplier before you issue the declaration — ideally already when you place the order. Here is a ready-made request you can copy:

What to do with the answer and how long to keep it: Supplier request for the PPWR Declaration of Conformity: ready-to-send template

Declaration, LUCID and Label: What Is the Difference?

• Declaration of Conformity (PPWR) — confirms that a specific packaging meets EU requirements. One per packaging, in the language of each country of sale.
• LUCID registration (Germany) — registers your company as a producer in the German packaging register before you sell. One per company, not per packaging. LUCID registration help
• Label on the packaging — the identification number and the manufacturer’s contact details on the packaging itself (Art. 15, since 12 August 2026). PPWR labelling explained

You usually need all three — they do not replace each other.

Next Step: the Label on the Packaging

The declaration is only the first half. Since 12 August 2026, Article 15 also requires marking on the packaging itself: the identification number of the packaging (the same number as in point 1) and the manufacturer’s name and postal address. A brand name alone is not enough. What must be on the packaging?

If you create your declaration in our generator, you do not have to type anything twice: after the download, your data is carried over to the label generator, and the print-ready label with packaging number, name and address is created in one click — free of charge.

After Signing

• Keep the declaration together with the technical documentation: 5 years for single-use packaging, 10 years for reusable packaging.
• Update it whenever the packaging or the list of products changes.

Common Mistakes

• One declaration for all packaging — jar and shipping box each need their own.
• Vague description — “shipping box” without material, size and construction.
• All articles ticked — only tick the requirements that apply.
• One language for all countries — each country of sale needs its language.
• No technical documentation — the declaration needs the evidence behind it.
• Not kept — retain for 5 or 10 years.

Frequently Asked Questions

Do I need a separate declaration for every product?

No. One declaration covers one packaging type. If several products use exactly the same packaging, one declaration is enough and all SKUs are listed in it. Different packaging (e.g. the jar with lid and label, and the shipping box with padding) needs separate declarations.

In which language must the PPWR declaration be written?

In the language required by each EU country where the product in this packaging is placed on the market (Article 39(2) PPWR). There is no single English version for the whole EU.

Is the declaration valid without technical documentation?

The declaration may only be drawn up once conformity has been demonstrated in the conformity assessment (Annex VII), and technical documentation is part of it. Without technical documentation the declaration has no basis and cannot be defended in an inspection.

Do I need a notified body or laboratory tests?

For packaging, PPWR provides for Module A (internal production control): no notified body is involved. You rely on data from your packaging supplier; for food-contact packaging, PFAS should be backed by laboratory analysis results from the supplier.

Who signs the declaration and how long must it be kept?

A person authorised to sign for the company; a typed name is sufficient. Keep it with the technical documentation for 5 years (single-use packaging) or 10 years (reusable packaging).

Two Ways to Get Your Declaration

Yourself, with the generator: one form, hints for every field, a finished PDF in the official language of each of the 27 EU countries.

With help: an initial consultation costs €99 — in writing, in your language, reply within 24 hours.

Found that your packaging does not meet the requirements? Packaging not PPWR compliant: what to do?

This article provides general information about Regulation (EU) 2025/40 and is not legal advice. You remain responsible for the content of your declaration.

Official Sources

• Regulation (EU) 2025/40 (PPWR) — full text on EUR-Lex
• Article 39 — EU declaration of conformity
• Annex VIII — structure of the declaration
• Annex VII — conformity assessment (Module A)
• Regulation (EC) No 1935/2004 — food contact materials
• European Commission — PPWR FAQ

Read Also

• PPWR Declaration of Conformity: a fully completed sample
• PPWR Declaration of Conformity, worked through: a real product example
• EU Declaration of Conformity for packaging: what you actually need to know