PPWR declaration of conformity: template, mandatory content under Annex VIII and a step by step guide

Since August 12, 2026 the EU Packaging Regulation has applied, and the first question that has reached us almost daily since then is: is there a template for the declaration of conformity? Yes, there is. It is set out in Annex VIII of Regulation (EU) 2025/40, has eight numbered points and fits on one page. So the form is not the problem. The problem is what you write into it, for which packaging you need it, who is allowed to sign it, and what evidence backs the statement when market surveillance asks.

This article answers exactly those questions. It is aimed at companies that place packaging or packaged products on the market in Germany and the EU, that is fillers, manufacturers, importers and retailers with own brands. At the end you will find a filled-in sample and a template to download.

What is the PPWR declaration of conformity?

The EU declaration of conformity is the document with which the producer of a packaging declares in writing that this packaging meets the requirements of Articles 5 to 12 of Regulation (EU) 2025/40, to the extent that they apply at the time of placing on the market. The legal basis is Article 39, the structure is set by Annex VIII. By issuing it, the producer assumes responsibility for conformity (Article 39(4)).

Important for context: the declaration of conformity is the result of a procedure, not the start of one. Before it comes the conformity assessment under Article 38, and that runs under Annex VII as Module A, that is as internal production control. There is no notified body, no certificate and no external test stamp. The producer assesses, documents and declares by themselves. That makes the matter simpler than for CE-marked products, but also less comfortable, because nobody else carries the responsibility.

There is, by the way, no CE marking for packaging. The regulation expressly excludes it so that nobody confuses the conformity of the packaging with that of the packaged product (recital 109).

Who has to issue the declaration of conformity?

The producer. And only the producer. Who that is in a specific case is answered by Article 3(1)(13), and this is where most mistakes happen, because the regulation uses the term differently from the German Packaging Act. The producer is not the manufacturer in the sense of extended producer responsibility who registers with LUCID. Both roles can coincide, but they do not have to. Anyone who issues the declaration of conformity in the name of the EPR producer may have named the wrong actor.

In its guidance C/2026/3702 the Commission distinguishes three cases:

The packaging carries a name or a brand. Then the producer is whoever has the packaging developed or manufactured under that name, regardless of who physically produces it. For sales and grouped packaging this is usually the filler who fills the packaging with their product and places it on the market. The carton manufacturer who supplies the printed folding carton is a supplier, not a producer.

The packaging is unbranded. For transport packaging, service packaging and primary production packaging, the producer is whoever manufactures it, unless the customer has had it marked with their name or brand. So the unprinted stretch film and the neutral euro pallet are declared by the manufacturer of the film or the pallet respectively. As soon as your logo is on the pallet, it is you.

The brand owner is a microenterprise. If a company with fewer than ten employees and at most two million euros in turnover or balance sheet total has had the packaging manufactured under its own name, and the packaging supplier is based in the same member state, then the supplier is the producer. If the supplier is based abroad, it remains with the microenterprise.

On top of that comes Article 21: importers and distributors are deemed to be producers if they place packaging on the market under their own name or brand, or modify packaging already placed on the market in such a way that conformity could be affected. The mail order company that has its shipping bags printed with its own logo is the producer of those shipping bags.

And one rule that saves a lot of argument: in a supply chain there is always exactly one producer for each packaging. Whoever is not the producer still has something to do. Suppliers of packaging must provide the producer under Article 16 with all information and documents needed to demonstrate conformity. The Commission has clarified in its FAQ that a supplier cannot refuse these documents. Importers must ensure that the producer in the third country has carried out the assessment and drawn up the declaration, and must keep a copy together with the technical documentation for five or ten years respectively (Article 18). Distributors have no obligation to declare, but may only make available packaging that is conform and marked (Article 19).

Anyone unsure about the role assignment will find the decision logic in more detail in our article Producer or manufacturer? Which role you have under the PPWR.

From when must the declaration of conformity exist?

For every packaging placed on the market since August 12, 2026. Placing on the market means the first making available on the EU market. Three constellations regularly cause confusion here:

Packaging that was lawfully placed on the market before August 12, 2026 may remain on the market without a declaration. It does not have to be reworked or recalled, even if it does not meet the new requirements (Commission FAQ, 2nd edition, section X, question 5). For reusable packaging the cut-off date is even February 11, 2025, the date of entry into force (Article 15(9)).

Packaging that was produced before August 12, 2026 but is still in stock needs a declaration of conformity when it is placed on the market. In August 2026 the Commission clarified that nobody has to destroy, rework or relabel their stock. The identifier and the producer details required under Article 15(5) and (6) may be provided for old stock via an accompanying document (FAQ X, question 5). If supplier data is missing for such stock because the supplier no longer exists or does not respond, the Commission requires demonstrable efforts and, if necessary, your own assessments (FAQ X, question 6). Document these efforts, because in case of doubt that is your argument towards the authority.

Packaging manufactured after August 12, 2026 must carry the identifier and the producer details directly. An accompanying document is only permitted if affixing is not possible because of the size or nature of the packaging.

Which requirements must the declaration cover in 2026?

This is the point where many templates on the internet become imprecise. Article 39 requires evidence of the requirements of Articles 5 to 12. But not all of those articles apply yet. The declaration of conformity only covers what is applicable at the time of placing on the market (Commission FAQ, section XV, question 1). Anyone who writes recyclability performance grades or recycled content quotas into their declaration today is declaring something for which the assessment method does not yet exist.

As of September 2026 the picture is as follows:

Concretely, for a printed folding carton without food contact this means: you need evidence that the sum of the four heavy metals is below 100 mg/kg, a comprehensible statement on the minimisation of substances of concern and on recyclability in the previous sense, plus the marking with identifier and producer details. For food packaging the PFAS values are added, for a reusable crate the requirements of Article 11.

What is coming in 2028 and 2030 you should already provide for in your data model today. It does not yet belong in the declaration. More on this in our article PPWR labelling obligation: what applies since August 12, 2026 and what only comes in 2028.

For which packaging do I need a separate declaration?

Annex VII requires one declaration per packaging type. What is meant is not the material category from Annex II, but the individual packaging format or the series (Commission FAQ, section XV, question 2). Three rules of thumb from the FAQ that help in everyday work:

One packaging unit, one declaration. Bottle, closure and label together form one packaging unit. One assessment and one declaration is sufficient for that, but the declaration must list the components. It is not declared per component.

The same packaging in several sizes may be combined in one declaration if the size has no influence on meeting the requirements and the same product is contained. As soon as the packaged product differs, a joint declaration is no longer permitted (FAQ XV, question 10). The reason is simple: the assessment of minimisation depends on the product, the assessment of recycled content on the weight.

Transport packaging is not exempt. Pallet, pallet collar, stretch film and strapping band are different packaging types and need separate assessments and separate declarations (FAQ XV, question 11). Anyone who buys them in and uses them unbranded obtains the declarations from the manufacturer. Anyone who has them made under their own brand issues them themselves. What this looks like in B2B practice is described in Does the PPWR apply to B2B? Transport packaging, pallets, stretch film and used cartons.

If your packaged product also falls under other legal acts with a declaration of conformity, such as Regulation (EU) 10/2011 for plastics in food contact, you may issue a single EU declaration of conformity for all the legal acts concerned. It must name the legal acts with their Official Journal reference and clearly separate packaging and packaged product. A dossier made up of several individual declarations is also permitted (Article 39(3), FAQ XV, question 4).

Is there an example of a declaration of conformity under the PPWR?

Yes. The following sample follows Annex VIII point by point. The producer is fictitious, the structure is the official one.

A few notes on the fields that raise questions in practice:

On points 1 and 4: the regulation does not define the unique identifier. The Commission understands it to be the type, batch or serial number that identifies the packaging itself (FAQ XV, question 3). Your article number plus a batch reference is sufficient if it assigns the packaging beyond doubt. An illustration is not mandatory, but useful.

On point 5: name the articles whose fulfilment you have actually demonstrated, not a blanket "Articles 5 to 12". That is more honest and protects you when the labelling obligation arrives in 2028 and somebody reads your declaration from 2026.

On point 6: harmonised standards for the PPWR are not yet listed in the Official Journal. The old standards of the Packaging Directive, such as EN 13428, no longer create a presumption of conformity (recital 58, Commission FAQ section XV). You may name them as orientation, but should then describe which solution you have chosen, as required by Annex VII number 2 letter d.

On point 7: under Module A there is no notified body. Do not leave the field empty, but write "not applicable" and the reason. An empty line looks like an omission.

On point 8: this is where the number of the technical documentation, the end of the retention period and, where applicable, the note on which previous version is replaced belong.

Who signs? The regulation does not prescribe a function. It has to be a person who may sign for the producer and who understands the responsibility they are assuming. Management, quality management or a person authorised in writing are customary. An electronic signature is sufficient.

Which technical documentation sits behind the declaration?

The declaration is one page. The technical documentation under Annex VII is the part that makes the work. It must make it possible to assess conformity, and it must contain an analysis of the risks of non-conformity. Annex VII number 2 names as minimum content, where relevant:

a) a general description of the packaging and its intended use, b) designs, manufacturing drawings and materials of the components, c) explanations needed to understand the drawings and the way it works, d) the list of harmonised standards, common specifications or other technical specifications applied, and where none were applied, the description of the solution chosen, e) a qualitative description of how the assessments under Articles 6, 10 and 11 were carried out, f) test reports.

Article 5(6) says expressly that compliance with the heavy metal and PFAS limits must be demonstrated in this documentation. With what? The regulation does not prescribe a test report per batch. In practice, in 2026 producers rely predominantly on supplier declarations for the individual components, supplemented by test reports where a risk exists, for example with printing inks, recycled material or food contact. Exactly this weighing up is the risk analysis that Annex VII requires: which component could breach the limit, how likely is that, and which evidence is appropriate for it?

One point that is often overlooked: the limit of 100 mg/kg refers to the packaging including printing inks, varnishes and adhesives that the producer places on the market with it. The material data for the carton alone is therefore not enough.

The documentation is a living dossier. If the material, the supplier, the printing ink or a standard changes, the producer must check whether a renewed assessment is necessary (Article 15(4)). The declaration is then to be updated accordingly, because Article 39(2) requires it to be kept up to date at all times. A PDF from 2026 that still names the old suppliers in 2028 is formally present and substantively worthless.

Language, retention and presentation to the authority

The declaration must be drawn up or translated into the language or languages required by the member state in which the packaging is placed on the market or made available (Article 39(2)). For Germany that means a German version. Anyone delivering to France, Italy or Poland needs the language required there. An English version is practical for international supply chains, but does not replace the national language.

The declaration and the technical documentation are kept for five years from placing on the market for single use packaging and ten years for reusable packaging (Article 15(3)). The same periods apply to importers (Article 18(7)). It is not sufficient that the supplier has the documents. You must be able to access them yourself.

On a reasoned request from a national authority, producers must present all documents within ten days, electronically and on request in paper form, in a language that the authority easily understands (Article 15(10)). Ten days is short when the evidence lies scattered across mailboxes and network drives. Under Article 39(5) the authorities are moreover required to check a risk-based selection of the declarations of conformity for accuracy every year. That is not a threat, but the checking mechanism that the regulation puts in place of a notified body.

In Germany the Packaging Implementation Act (VerpackDG, in force since August 12, 2026) implements the sanctions. A producer who does not hand over documents, or does not do so correctly or in time, commits an administrative offence, as does an importer who has not ensured that the assessment and technical documentation exist. Depending on the infringement, the fine framework reaches up to 100,000 euros or 200,000 euros (section 66 VerpackDG). The market surveillance authorities of the federal states are responsible.

The most common mistakes

From the conversations we have been having since the spring with fillers, furniture manufacturers, importers and packaging manufacturers, seven mistakes keep recurring:

1. The wrong issuer. The declaration is expected from the packaging supplier although the filler is the producer. Or the other way round: the filler issues it for an unbranded pallet that they only bought in.
2. One declaration for everything. One document for the entire range, without reference to individual packaging types and without listing the components.
3. Declaring too much. A blanket "Articles 5 to 12", although recyclability grades, recycled content, minimisation and labelling do not yet apply and are not assessable.
4. No basis of evidence. The declaration says "below 100 mg/kg", but the documentation contains neither a supplier declaration nor a test report.
5. Printing inks and adhesives forgotten. Material data sheets only for the substrate, not for what is on it and between it.
6. English only. The declaration of the Asian manufacturer is available in English, a German version is missing.
7. No maintenance. Material change, new supplier, new ink, but the declaration from 2026 remains unchanged in the folder.

How to proceed in practice

1. Record packaging units and components. Break down every packaging format into its components: carton, bag, label, closure, adhesive, ink. Assign a supplier to each component. Without this bill of materials you can neither assess nor declare.

2. Clarify the role per packaging unit. For which units are you the producer, for which the importer, for which only the distributor? The answer determines whether you have to issue, collect or do nothing at all.

3. Request evidence from the suppliers. Heavy metal values, material composition, and for food contact PFAS data, each with a basis of evidence. Article 16 obliges suppliers to cooperate, but experience shows the answers come in weeks, not days. A ready-made letter with a clear request table speeds this up considerably, see Sample letter to upstream suppliers.

4. Assess risks. Where is a supplier declaration sufficient, where do you need a test report? Record the reasoning in writing, that is the risk analysis under Annex VII.

5. Compile the technical documentation. Along points a to f, with the evidence as annexes. Assign a document number and a date.

6. Issue, sign and file the declaration. Per packaging type, with reference to the documentation, in the required language, with a follow-up on every change.

Anyone with twenty packaging types can manage this with a spreadsheet and a folder structure. Anyone with two hundred and forty suppliers will notice, at the latest with the first request from an authority, that version states, evidence and responsibilities cannot be found in mailboxes.

How Polygon One helps

We built the PPWR module of Polygon One exactly along these six steps, because they are the same in every company. You create articles, packaging units and components or import them from Excel. You determine your role per unit, and the platform derives from that what needs to be done. You request missing evidence from the responsible supplier with one click, and they upload it through a portal of their own. Uploaded test reports and declarations are read out automatically and taken over as a suggestion into the component data, and a human always decides.

From this data Polygon One generates the technical documentation under Annex VII and the declaration of conformity under Annex VIII as a PDF in German and English, per packaging unit, individually or for a hundred units at once with one signature. A readiness check prevents a declaration from being issued without a basis of evidence. Every change to the data marks the existing declaration as outdated, every new issue is versioned, and the retention period runs automatically. Importers collect the declarations of their producers the same way and check them.

What Polygon One does not do: make the conformity assessment in your place or give a legal assessment. The platform structures the data, shows gaps and creates the documents. The responsibility for content and issuance remains with the producer, as Article 39(4) requires, and as it should be.

If you would like to see what this looks like with your own packaging data, book a demo or read on at the product page for the PPWR module.

Download the template

The template contains the sample under Annex VIII with completion notes for every point as well as an outline for the technical documentation under Annex VII including the risk analysis. Both documents are aligned to the state of September 2026 and name only the requirements that apply today.

• Download: PPWR declaration of conformity, template under Annex VIII with completion notes and English version (DOCX)
• Download: Outline of the technical documentation under Annex VII, Module A, with risk analysis and tables (DOCX)

Frequently asked questions

Is the declaration of conformity mandatory?

Yes, for every packaging placed on the market since August 12, 2026. There is no de minimis threshold and no exemption for B2B packaging. The only relief concerns microenterprises, where the producer role passes to the domestic packaging supplier.

Do I need a notified body or a certificate?

No. The conformity assessment runs under Module A as internal production control. You can commission laboratories or consultants, the responsibility remains with the producer.

Does the declaration of conformity have to accompany the packaging?

No. It must be able to be presented within ten days on request from the authority. Many customers do, however, require it contractually, and importers must keep a copy available.

Does this also apply to euro pallets and stretch film?

Yes. Transport packaging is not exempt, and every packaging type needs its own declaration. Anyone buying in neutral pallets or film obtains the declaration from the manufacturer.

Does this also apply to labels?

Labels are components of the packaging unit they are stuck on. They are listed in the declaration of that unit and evidenced in the technical documentation with their substance data, but do not need their own declaration as long as they are not themselves placed on the market as packaging.

Is the template from the chamber of commerce sufficient?

The samples from the chambers of commerce and associations follow Annex VIII and are a good starting point. What is decisive is what you write into it and what you use to evidence it in the technical documentation.

What happens if the declaration is missing?

The packaging may not be placed on the market. Under the VerpackDG fines are possible, and market surveillance can order withdrawal or recall.

Sources and status: Regulation (EU) 2025/40 (OJ L, 22.1.2025), in particular Articles 3, 5, 15 to 21, 38, 39 and Annexes VII and VIII. Commission FAQ on the PPWR, 2nd edition (August 2026), sections X and XV. Commission guidance C/2026/3702 on definitions and labelling (July 2026). Packaging Implementation Act, Federal Law Gazette 2026 I No. 207 of 17.07.2026, section 66. This article describes the legal position as of September 2026 and does not replace legal advice. We will update it as soon as the Commission lists harmonised standards or the implementing acts on labelling enter into force.