Declaration of conformity for packaging for Ireland: sample and generator

It is the manufacturer’s written confirmation that a given packaging meets the requirements of Regulation (EU) 2025/40 — restrictions on substances, recyclability, minimisation and labelling. By drawing it up, the manufacturer takes responsibility for the conformity of the packaging. Authorities do not approve or register the declaration in advance: it is the company’s own document. It is based on the technical documentation — a description of the packaging, the supplier’s material data and test results. Keep these together with the declaration: without them, the declaration is just a signature on paper. Source: Regulation (EU) 2025/40, Article 39

Since 12 August 2026, the date from which the Packaging Regulation applies. What counts is when the packaging is placed on the market: if you place a packaged product on the market after that date, the declaration must exist, even if the product itself is not new. As an EU regulation it applies directly in Ireland; the competent authorities for Ireland were designated by S.I. No. 541 of 2025. Further requirements follow later: harmonised labelling of packaging from 12 August 2028 at the earliest, recyclability and minimisation from 2030. When new requirements apply, the declaration must be updated. Source: Regulation (EU) 2025/40 Source: S.I. No. 541 of 2025

The manufacturer — the company that manufactures the packaging, or has it designed or manufactured, and places it on the market under its own name or trademark. Example: if you buy jars outside the EU and sell honey in them under your own brand, you are the manufacturer, not the jar supplier. A retailer with its own brand (private label — products sold under the retailer’s brand) is usually a manufacturer. If you sell another brand’s product in its original packaging, you are usually a distributor, and the manufacturer draws up the declaration. The importer must make sure that a manufacturer outside the EU has drawn up the declaration. Source: Regulation (EU) 2025/40, Article 3

The unique identification of the packaging, the name and address of the manufacturer and, where applicable, of the authorised representative, the statement that the declaration is issued under the sole responsibility of the manufacturer, the description of the packaging, the confirmation of conformity, the standards applied, where applicable the notified body, additional information, and the place and date of issue with the name and function of the signatory. The generator produces all 8 points following the model in Annex VIII — you only enter the data. Under point 5 you can also confirm compliance with individual articles, for example the restrictions on heavy metals and PFAS (Article 5). Only tick articles whose compliance you have actually checked. Source: Regulation (EU) 2025/40, Annex VIII

The Regulation refers to the language or languages required by the Member State in which the packaging is placed on the market or made available. Under the Constitution of Ireland, Irish is the first official language and English is recognised as a second official language. We have not found a specific Irish rule on the language of the declaration of conformity for packaging in the official information (as of 28.09.2026) — English is therefore a safe choice. The generator produces the declaration for Ireland in English. Source: Regulation (EU) 2025/40, Article 39(2) Source: Constitution of Ireland, Article 8

The declaration does not have to be submitted or registered in advance. The competent authorities receive a copy on request, for example during an inspection or after a complaint. Keep the PDF and the technical documentation so that you can send both quickly. Source: Regulation (EU) 2025/40, Annex VII

Five years after placing on the market for single-use packaging and ten years for reusable packaging. Keep not only the declaration but also the technical documentation: description of the packaging, the supplier’s material data and test results. If you sell the same product in the same packaging for several years, you may only discard the old declaration once five (or ten) years have passed since the last batch. Source: Regulation (EU) 2025/40, Article 15

The declaration is drawn up per type of packaging, not per product. If several products use exactly the same packaging, one declaration naming all the products is enough. Example: three teas in identical 100 g tins can be in one declaration; if one of them comes in a tin of a different size or material, it needs its own. Sales packaging, grouped packaging and transport packaging (for example an e-commerce shipping box) are different types of packaging, and each needs its own declaration. Source: Regulation (EU) 2025/40, Article 3

The declaration for each country must be in the language that country requires. In the generator, tick every country where you sell the packaging — you get one PDF with a declaration in the official language of each country (all 27 EU countries). Each country gets its own page with the correct heading and, if you enter it, that country’s registration number (for example the LUCID number in Germany, the Repak membership number in Ireland). You enter your data only once.

Yes. The obligation does not depend on the sales channel: what matters is that you place the packaging on the EU market as its manufacturer. The same applies to Amazon, Etsy, your own online shop and in-store sales. The platform does not draw up the declaration for you. Producer responsibility in Ireland is a separate obligation: under the European Union (Packaging) Regulations 2014, “major producers” — more than 10 tonnes of packaging a year and an annual turnover of more than €1 million — must be members of an approved body; since 1 January 2023 self-compliance is no longer possible. Repak operates Ireland’s only approved body for packaging. Source: S.I. No. 282 of 2014 Source: gov.ie, packaging rules 2022

They are two different documents. The declaration under Regulation (EC) No 1935/2004 and, for plastics, Regulation (EU) No 10/2011 confirms that the material is safe in contact with food: migration limits, temperature, contact time. The EU declaration of conformity for packaging confirms the requirements of the Packaging Regulation: substances, recyclability, minimisation, labelling. If the packaging is in contact with food, you need both declarations — one does not replace the other. In addition, PFAS restrictions have applied to food contact packaging since 12 August 2026. Source: Regulation (EU) 2025/40, Article 5(5)

Not as your own. If you sell the product under your name or brand, you are the manufacturer, and your company signs the declaration. The supplier’s documents are still very important: material specification, evidence on heavy metals and PFAS, test results. They form the basis of your technical documentation. Request them from the supplier in writing and keep them with the declaration. Source: Regulation (EU) 2025/40, Annex VII

The declaration must always be kept up to date. If you change the material, size, supplier or construction of the packaging, draw up a new declaration with a new number. Keep the old one until the end of the retention period, because it covers packaging already placed on the market. The generator saves your company data in the browser: a new version takes only a few minutes. Source: Regulation (EU) 2025/40, Article 39(2)