PPWR Insights 9: Declaration of Conformity for every packaging type

A declaration of conformity or Declaration of Conformity (DoC) is an official written document with accompanying technical documentation, by which you as a manufacturer prove that packaging meets the European requirements for packaging and packaging waste. The template for this document is set out in Annex VIII of the PPWR. The declaration of conformity is based on the underlying technical documentation, the requirements for which are set out in Annex VII of the PPWR.

The manufacturer is the natural or legal person who makes packaging or packaged products. This is not necessarily the entity that physically produces the packaging, but the one that has decision-making power over its design and production. Note: there is always only one manufacturer per packaging unit throughout the entire supply chain.

2 criteria determine who is the manufacturer:

1. Is there a name or trademark on the packaging or packaged product? If so, the owner of that name or mark is the manufacturer.
2. Is there no name or mark? Then the manufacturer is the one who places the order and determines the design specifications.

For sales packaging and grouped packaging, the manufacturer is the party that fills the packaging. This is usually the brand owner.

For service packaging in its final form, it is different: the manufacturer is the company that makes the service packaging (the supplier). Think of a cup that is filled with coffee at the point of sale — unless the user applies their own name or brand to it, such as a hospitality business. In that case, the user is the manufacturer.

For transport packaging, similar principles apply, although the Commission's recent FAQ contains additional nuances that are still being clarified.

Importers and distributors can also be considered as manufacturers under the conditions of Article 21 of the PPWR, for example when they place packaging on the market under their own name or brand.

There is an exception for micro-enterprises: if the company that has the packaging designed under its own name or brand is a micro-enterprise and the packaging supplier has an establishment in the same Member State, that supplier is the manufacturer.

You draw up a declaration per packaging type, not per stock keeping unit (SKU). The conformity assessment and declaration apply to the complete packaging unit (e.g. the bottle, cap and label together). You therefore do not need to draw up a separate declaration per component. The declaration must, however, contain information about each of those individual components.
How far the underlying analysis per component must go remains unclear. The legislation does not specify whether that analysis must go down to the level of the paper, glue and ink of the label.

1. Unique number per declaration of conformity
    
2. Identification number of the packaging type 
   For example a serial or type number. That number must appear on the packaging or on an accompanying document.
    
3. Manufacturer's details
    
4. Legally required statement
   Please copy the following sentence into your document: "This declaration of conformity is issued under the sole responsibility of the manufacturer."
    
5. Description of the packaging
   ●    Format, material, function, purpose of the packaging
   ●    Type of packaging: sales packaging, grouped packaging, transport packaging, service packaging or e-commerce packaging?
   ●    Is it reusable packaging?
   ●    Is it single-use packaging?
    
6. Do you comply with the legal requirements of the PPWR?
   ●    Requirements for substances in packaging  (article 5) - August 2026 
   ●    Recyclable packaging  (article 6) - 2030 
   ●    Minimum recycled content in plastic packaging (article 7) - 2030. 
   ●    Bio-based raw materials  (article 8) - 2028 
   ●    Compostable packaging (article 9) - 2028 
   ●    Packaging minimisation (article 10): how to comply is set out in Annex 4 of the PPWR - 2030 
   ●    Reusable packaging (article 11): the label for reusable packaging is only mandatory from 2029.
   ●    Labelling (article 12) - 2027-2030 (depending on label type) 
    
7. (where applicable) Standards and specifications 
   State any harmonised standards applied, common specifications used, or other technical specifications.
    
8. (where applicable) Notified body  
   Currently, as a manufacturer you assess the conformity of your packaging yourself. There is no prior external inspection body. National authorities can, however, request and verify the technical documentation. 
   
   If you do have conformity established by an external auditor, you can list the certificates in this section.
    
9. (where applicable) Additional information 
   Every declaration of conformity must be signed, stating the place, date, name and position of the signatory.
   
   For more information on the declaration of conformity, you can contact your sector federation or the FPS Public Health, Food Chain Safety and Environment..