PPWR Declaration of Conformity: countries, languages and representatives

Under Art. 39(2) PPWR, the declaration must be drawn up in, or translated into, the language or languages required by the Member State in which the packaging is placed or made available on the market.

Expert sources differ on the interpretation, however. Some read the provision as requiring the declaration to be issued in the local language from the outset. Others understand it as a translation obligation on demand – meaning you must be able to produce the declaration in the required language, but need not issue multiple versions in parallel.

In practice both readings lead to the same safe approach: keep a version in the official language of each market you sell into. Then you are covered whichever interpretation an authority follows.

That is precisely why our generator produces the declaration in the language of every target country you select, from a single set of data – without you having to enter the information more than once.

Not in substance – the technical statements about your packaging are the same across Europe. As a regulation, the PPWR applies directly in all Member States; there are no nationally differing conformity requirements for the packaging itself.

What differs is the language: under Art. 39(2) PPWR the declaration must be available in the language required by the respective Member State. In practice you therefore need a linguistically appropriate version of the same substantive declaration per target market.

This must be kept strictly separate from EPR registration: for extended producer responsibility – registration and contributing to waste management costs – you genuinely do need a separate registration in each country's national register. That is a separate obligation, not a question of the declaration of conformity.

In short: one substantive declaration, several language versions – but separately from that, one registration per country.

For the declaration of conformity: one substantive declaration per packaging type, in five language versions – one for each target market. The content is identical; only the language differs.

If you also have several packaging types, that multiplies accordingly: three box sizes across five countries means fifteen documents – but only three different data sets, which you need to collect once.

Separate from this are the EPR obligations: for each of the five countries you will generally need your own registration in that country's national packaging register and participation in a take-back scheme. This has nothing to do with the declaration of conformity but is frequently confused with it.

In practice: the effort for the declarations themselves is manageable once the material data exists. The greater effort sits in the national registrations.

Only up to a point. English is an official language in Ireland and Malta – for those markets an English version is unproblematic. For Germany, France, Italy, Spain or Poland, an authority may require the respective national language.

Some authorities accept English in practice, but they are not obliged to. Relying on that is an avoidable risk – particularly when you may have only ten days to produce documents.

English still has its place in the supply chain: business customers, marketplaces and international partners often work with it. An English version alongside the local language is therefore rarely wrong.

Our recommendation: the local language as the primary version for authorities, English optionally as a reference version for business partners. That exact combination can be produced with a single tick box in our generator.

You can generally issue it yourself – the manufacturer role does not require an EU establishment. In practice, though, the immediate question is who is reachable for authorities in the EU and can produce the documents there.

The PPWR provides for the authorised representative: under Art. 17, the manufacturer may appoint in writing a representative established in the EU who, among other things, keeps the declaration of conformity and technical documentation available for market surveillance authorities.

In addition: anyone importing goods into the EU from a third country is an importer with their own obligations. If the third-country supplier is effectively unreachable for authorities, the manufacturer's obligations can pass to the EU importer – in which case your European buyer carries the responsibility, not you.

For sellers from China, Türkiye or the UK this means concretely: clarify early whether you appoint an authorised representative or whether your EU importer takes on the role. Unclear responsibility is the most common mistake in this setup.

For the declaration of conformity under Art. 17 PPWR, one authorised representative established in the EU is generally sufficient – they do not need to be based in every single Member State you sell into.

It is different for extended producer responsibility: many Member States require companies without an establishment in that country to appoint their own representative for EPR obligations in that specific country. That is a different role with a different purpose.

This duplication is one of the most common confusions in practice: the PPWR authorised representative under Art. 17 handles conformity documents. The EPR representative handles registration and waste management contributions in the respective country.

Candidly, the national requirements here are still developing. If you sell into several countries, check the position per target market rather than assuming a single uniform rule.

In substance, yes. The PPWR is an EU regulation and applies directly in all Member States – Austria has no differing conformity requirements for the packaging itself. The technical statements in your declaration are the same there.

Since German is also an official language in Austria, the language question is unproblematic too: a German-language declaration satisfies the requirement of Art. 39(2) PPWR for the Austrian market.

What you do need separately are the Austrian EPR obligations. Anyone making packaging available in Austria for the first time must register there and participate in a collection and recovery system – regardless of the declaration of conformity staying the same.

The general rule of thumb: the declaration of conformity is European, the registration and waste obligations are national.

Switzerland is not an EU Member State; the PPWR does not apply there directly. For packaging you ship from Switzerland into the EU it very much does apply, though – you are then placing packaging on the EU market and need a declaration of conformity for it.

The UK has been a third country since Brexit. British sellers shipping into the EU are therefore in the same position as Chinese or Turkish ones: manufacturer obligations, an authorised representative where relevant, and EPR registration in the respective target market.

Northern Ireland is a special case. Under the Windsor Framework certain EU rules continue to apply there for goods. Whether and to what extent the PPWR applies there is a question we honestly cannot answer conclusively – this warrants a targeted check for your specific case.

The same applies to all three: what matters is not where you are based, but whether you place packaging on the EU market.

No, these are two entirely different obligations – and confusing them is the most common error in cross-border selling.

The declaration of conformity under Art. 39 PPWR is a European product document about the properties of a packaging. It is filed nowhere; you keep it available and produce it on request.

Registration in the national packaging register, by contrast, is a national obligation under extended producer responsibility. Every EU country has its own register, and you must actively register there, participate in a take-back scheme and report volumes.

Both exist side by side. A perfect declaration of conformity does not replace registration, and registration does not replace a declaration of conformity.

Yes, considerably – but mainly for the EPR obligations, not for the declaration of conformity.

In cross-border direct sales to end consumers, you count in the destination country as the party first making the packaging available there. The registration and waste obligations in that country therefore fall on you directly – not on your customer and not on the marketplace.

For the declaration of conformity nothing changes in substance: it remains the same declaration for the same packaging. What is added is the appropriate language version for each target market you ship to.

In practice, for an online seller shipping into several EU countries: the declarations are quick to produce once the data exists. The real effort sits in the national registrations – and you should not wait until a marketplace prompts you.