PPWR Declaration of Conformity: who needs it and why?

The PPWR Declaration of Conformity is a written self-declaration in which a company confirms that a specific packaging meets the requirements of the EU Packaging Regulation. The legal basis is Article 39 of Regulation (EU) 2025/40 (PPWR); the structure of the document is set out in Annex VIII.

One point matters most: it is not a certificate issued by an authority or a testing institute. You issue the declaration yourself and thereby assume sole legal responsibility for the accuracy of what it says (Art. 39(4) PPWR).

In it you confirm that your packaging meets the applicable requirements of Articles 5 to 12 of the PPWR — substance restrictions, recyclability, minimisation and labelling among them. The declaration comes at the end of a conformity assessment procedure and rests on technical documentation that you keep in the background.

From 12 August 2026, packaging without a valid declaration of conformity may no longer be newly placed on the EU market.

It must be issued by the so-called manufacturer. Under Art. 3(1)(13) PPWR, that is whoever first places packaging on the EU market under their own name or brand — regardless of who physically manufactured it.

In practice: if a contract manufacturer produces your folding boxes and you sell the packaged goods under your brand, you are the manufacturer, not the printing company.

If you bring goods into the EU from a non-EU country, you are usually the importer. Importers have their own duties under Art. 14 PPWR: they must satisfy themselves that the manufacturer carried out the conformity assessment and that the declaration exists. Where a third-country supplier is effectively unreachable, the manufacturer's obligations can pass to the EU importer.

Pure distributors (retailers reselling third-party branded goods unchanged) have only limited checking duties under Art. 15 PPWR — they need not declare themselves, but must verify that the required documents exist. As soon as you alter the packaging or sell under your own name, you become the manufacturer yourself.

Usually no — as a pure distributor you do not have to issue your own PPWR Declaration of Conformity. Your duties follow from Art. 15 PPWR and are limited to acting with due care: checking that the packaging is properly labelled and that the required documents exist at the manufacturer.

There are three situations, however, where you do become the manufacturer and need your own declaration: you sell the goods under your own name or brand; you alter the packaging in a way that affects conformity (repacking, bundling, adding your own shipping box); or you import the goods yourself from a non-EU country.

That third point catches many online sellers: anyone buying directly in China and importing themselves is an importer with duties under Art. 14 PPWR — not merely a distributor.

A practical note: even where you need not issue your own declaration, marketplaces and business customers increasingly request the document from suppliers. It pays to ask for it early.

Yes. The obligation to hold a PPWR Declaration of Conformity does not depend on the sales channel but on whether you first place packaged goods on the EU market. Selling via Amazon, your own shop, eBay or a physical store makes no difference.

For Amazon sellers, two packaging levels are usually affected: the product packaging in which the goods are sold, and the shipping packaging in which you send them. Both are packaging within the meaning of the PPWR.

It is worth separating this from obligations you may already know: LUCID registration and packaging licensing remain unaffected and continue in parallel. The declaration of conformity is additional — it replaces nothing.

If you use Fulfilment by Amazon (FBA) and Amazon packs into its own boxes, that Amazon shipping packaging is not covered by your declaration. You remain responsible for the packaging in which your product reaches Amazon and in which it is sold.

In principle yes — the PPWR does not tie the obligation to company size. For microenterprises, however, there is an important special rule that affects many small sellers.

Under Article 3(1)(13)(b) PPWR, the manufacturer role can pass to the company that supplies the packaging where the party placing it on the market under its own name is a microenterprise. Where that rule applies, the microenterprise does not have to fulfil the manufacturer's obligations for that packaging — in particular no conformity assessment, no technical documentation and no declaration of conformity of its own. Those duties then sit with the supplier.

Whether the rule applies to you depends on two things: whether you stay within the microenterprise thresholds of Recommendation 2003/361/EC (broadly: fewer than 10 staff and no more than €2 million turnover or balance sheet total), and where your packaging supplier is established. Note that the geographical condition is worded differently in Art. 3(1)(13)(b) and in Art. 15 — for the declaration of conformity the wording in Art. 15 governs, which refers to a supplier established in the EU.

In practice, for small online sellers: first check whether you fall under the microenterprise rule and whether your supplier is in the EU. If you buy your packaging directly from a non-EU country, the relief will usually not apply and the obligations stay with you. Because the detailed interpretation is still being discussed, it is worth getting a legal view before relying on the exemption.

These are two entirely different obligations that are frequently confused. LUCID registration is a German registration duty under the Packaging Act: you enter your company in the packaging register and receive a registration number. The PPWR Declaration of Conformity is a European product document under Art. 39 of Regulation (EU) 2025/40 confirming the properties of a specific packaging.

They also differ in what they refer to: LUCID registers your company. The declaration of conformity describes one particular packaging. A company has one LUCID number but possibly twenty declarations of conformity.

And they go to different recipients: you report the LUCID number to the register and to your dual system. The declaration of conformity is filed nowhere — you keep it available and present it to the market surveillance authority on request.

Both obligations exist side by side. Neither replaces the other.

Packaging licensing (extended producer responsibility, EPR) is a financial obligation: you report the volumes of packaging you place on the market and pay a dual system for its later collection and recovery. The PPWR Declaration of Conformity is a document evidencing the nature of the packaging — it carries no licence fee.

Put simply: licensing is about how much packaging you place on the market. The declaration is about what your packaging is like — which materials, which substances, whether it is recyclable and minimised.

The two are connected in that both need the same basic data: material type and weight per component. If your volume reporting is in good order, you already hold much of what the declaration requires.

Here too: both obligations run in parallel. The PPWR does not remove the national licensing duty.

It depends on who first places the packaging on the market. If you buy empty boxes from a packaging supplier and ship your own products in them, you place the filled packaging on the market — and need your own declaration for it.

That does not mean starting from scratch. Many packaging manufacturers already issue their own declarations of conformity for their articles. You can use these as a basis: take the material data, weights and substance confirmations from them into your own declaration for the specific packaging unit.

Ask your supplier specifically for: material type with recycling code per component, weight in grams, written confirmation regarding heavy metals and PFAS under Art. 5 PPWR, and — where plastic is present — the recycled content.

Under Art. 16 PPWR, suppliers are obliged to provide the information needed for the conformity assessment. You are therefore entitled to this data.

Without a valid declaration of conformity the packaging counts as non-compliant and may no longer be newly placed on the EU market from 12 August 2026. That is first and foremost a distribution risk, not only a fines risk.

In Germany the Packaging Implementation Act (VerpackDG) sets the framework for sanctions. For breaches connected with conformity assessment, documentation and retention, § 66 VerpackDG provides for fines of up to €10,000. The actual amount depends on the individual case.

For many sellers a second effect matters more in practice: market surveillance authorities can prohibit making the product available on the market or order withdrawals. Marketplaces and business customers also increasingly ask for the document — failing to supply it can cost you the customer long before an authority becomes involved.

If you have already missed the date: this can be made good. Draw up the declaration now and record the date honestly rather than backdating it.

Ask in writing and be specific, not general. Many sellers find that an open question like "do you comply with the PPWR?" either goes unanswered or comes back as a meaningless "yes, we comply". What works is a request that lists item by item what you need.

Specifically, ask for: material type with recycling code per component (e.g. PAP 20 corrugated board, LDPE 04, ALU 41), the exact weight in grams for each individual component, written confirmation regarding heavy metals and PFAS under Art. 5 PPWR, the recycled content under Art. 7 PPWR where plastic is present, and — if it exists — the supplier's own declaration of conformity plus the technical data sheet.

You are not asking without legal backing: under Art. 16 PPWR, suppliers are obliged to provide the information required for the conformity assessment. You are not requesting a favour but claiming something you are entitled to.

A practical tip from experience: Asian packaging manufacturers respond considerably faster in English or Chinese than in German. And if the supplier does not respond at all, the matter becomes serious for you — if you bring the goods into the EU yourself from a non-EU country, you are the importer under Art. 14 PPWR and carry responsibility for the documents existing.

On our generator page you will find a ready-made request template in English, Chinese and German that asks for exactly these points — copy it and send it.

What matters is the moment of placing on the market — when the individual packaging unit is first made available on the EU market, not when it was produced or put into storage.

For goods already placed on the market before the cut-off date, the new obligation does not apply retroactively. Stock that you first place on the market after that date does fall under the obligation.

In practice this means: warehouse stock you sell off gradually through 2026 and 2027 should be covered by a declaration. Since the packaging itself usually does not change, this is no additional work — it is the same declaration you need for ongoing sales anyway.

It is worth separating this from other PPWR deadlines: some requirements, such as recycled content and harmonised labelling, apply later. The declaration obligation under Art. 39 applies from 12 August 2026.