Whether you have to issue a declaration of conformity under the EU Packaging Regulation, register in LUCID and join a scheme, or only check your suppliers’ details depends on four things: what you do with the packaging, which type it is, what it is made of and where it is placed on the market. The check asks exactly that and shows your roles, your obligations by deadline and the matching guides.
Step 1 of 4: Activity
Regulation (EU) 2025/40 assigns obligations to roles that apply per packaging. The manufacturer under Article 3(1)(13) makes the packaging or has it made under its own name (Article 21) and is responsible for substance limits, conformity assessment, technical documentation and the declaration of conformity. The producer under point 15 first makes the filled packaging available in a member state and carries extended producer responsibility, in Germany registration, scheme participation, data reports and the declaration of completeness under the VerpackDG. Importers check under Article 18, distributors under Article 19, fulfilment service providers and platforms under Article 45(4).
Packaging type and material decide the individual obligations: food contact brings the PFAS limits, plastic the minimum recycled content from 2030, grouped, transport and e-commerce packaging the empty-space limit from 2030, single-use beverage containers the deposit. In Germany, transport packaging is not subject to scheme participation but to take-back. The market decides the register obligations: for Germany the VerpackDG applies, in every other member state its producer register.
The check works per packaging with one main material; the substance limits, however, apply per component, including inks, coatings and adhesives. Whether a specific packaging falls under an exemption, for example as reusable packaging with a functioning take-back system, as packaging for hazardous contents or under the reliefs for micro-enterprises, has to be checked case by case. And the check is not legal advice.
For choosing software, the comparison of 25 vendors with a requirements catalogue is available; the declaration of conformity itself is explained in the guide with template and completed sample.
The manufacturer under Article 3(1)(13) makes the packaging or has it made under its own name and is responsible for substance limits, technical documentation and the declaration of conformity. The producer under point 15 first makes the filled packaging available in a member state and carries registration, scheme participation and volume reporting. A filler with private-label packaging is both.
Yes. Pallets, stretch film, strapping and cartons are packaging within the meaning of the Regulation and have needed a declaration of conformity from the manufacturer since 12 August 2026. In Germany they are not subject to scheme participation but to the take-back obligation under § 39 VerpackDG; the harmonised labelling from 2028 does not apply to them, the empty-space limit from 2030 does.
For your own shipping boxes and mailers you are the producer: registration in LUCID, scheme participation, data reports and, from 2030, an empty-space ratio of at most 50 per cent. For the sales packaging of the goods you trade you are a distributor and check that markings and the declaration of conformity exist and that the producer is registered.
Substance limits for heavy metals and, for food contact, PFAS; conformity assessment, technical documentation and declaration of conformity per packaging type; identifier, name and address of the manufacturer on the packaging; checking duties for importers and distributors; in Germany registration and scheme participation under the VerpackDG. Labelling from 2028 and design requirements from 2030 come later.
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