The requirements for the PPWR Declaration of Conformity are demanding!

Under the EU Packaging Regulation (Regulation 2025/40, “PPWR”), producers will be required to issue an EU declaration of conformity in accordance with Annex VIII for each packaging unit starting August 12, 2026. Many trading partners and distributors are already requesting the necessary supporting documentation for the declaration of conformity in order to ensure their product ranges are compliant in a timely manner.

The requirements for the PPWR Declaration of Conformity are demanding: Each declaration must be supported by complete technical documentation in accordance with Annex VII—including evidence of material composition, recyclability, pollutant limits, PFAS, and other criteria from Articles 5 through 12 of the Regulation.

In this masterclass, we will provide you with all the knowledge you need to develop a well-founded declaration of conformity for your packaging portfolio.

The requirements for the PPWR Declaration of Conformity are demanding!

The EU Declaration of Conformity under the PPWR – Understanding and Meeting the Requirements

The EU Packaging Regulation (PPWR) entered into force on February 11, 2025, and will apply directly in all member states as of August 12, 2026, following an 18-month transition period. Until then, the Packaging Act (VerpackG) remains the governing law in Germany—however, preparations for the declaration of conformity under the PPWR must begin now, as retailers and distributors are often already requiring proof of compliance as early as mid-2026.

A producer within the meaning of the PPWR is anyone who has packaging developed or manufactured under their name or brand. Responsibility for the accuracy of the declaration of conformity therefore generally lies with the brand owner—even if the packaging is sourced from external suppliers.

The EU Declaration of Conformity under the PPWR – Understanding and Meeting the Requirements

What the PPWR Declaration of Conformity Covers

The Declaration of Conformity confirms that the packaging in question meets the requirements of Articles 5 through 12 of the PPWR. These include, in particular:

  • Material restrictions (Article 5) – Limit values for heavy metals and PFAS
  • Recyclability (Article 6) – Design requirements and assessment methodology
  • Recycled content in plastic packaging (Article 7)
  • Compostable packaging (Article 9)
  • Packaging minimization (Article 10)
  • Reusable and refillable packaging (Article 11)
  • Labeling requirements (Article 12)

Every statement in the declaration of conformity must be substantiated by corresponding technical documentation in accordance with Annex VII. These documents must be retained for five years for single-use packaging and ten years for reusable packaging.

What the PPWR Declaration of Conformity Covers

Masterclass Content: Step-by-Step Guide to the Declaration of Conformity under the PPWR + An Overview of the Training Content

The masterclass “PPWR & Packaging Compliance in Practice” is an intensive training course featuring concrete practical examples. You will gain the technical expertise needed to subsequently draft the declaration of conformity for your packaging independently within your company.

Creating an EU Declaration of Conformity in accordance with Annex VIII of the PPWR We will walk you through the mandatory information, structure, and formal requirements of the Declaration of Conformity step by step. You will learn which details are mandatory, how declarations differ for various types of packaging, and where common sources of error lie.

Technical Documentation According to Annex VII of the PPWR What evidence belongs in the technical dossier that forms the basis of the Declaration of Conformity? We explain the requirements for material specifications, recyclability assessments, test reports, and supplier declarations—and demonstrate the format in which these must be available to withstand an audit.

Articles 5 through 12 of the PPWR in Practice We translate the legal requirements into concrete testing criteria for your packaging. The focus is on substance restrictions (particularly PFAS and heavy metals), recyclability, recycled content, minimization requirements, and labeling.

 

Data Collection in the Supply Chain What data do you need from suppliers to support the declaration of conformity—and how do you request it in a legally compliant manner? We will cover how to establish a robust request and verification process, as well as how to evaluate the information received.

Roles and Responsibilities Within the Company Which departments are involved in preparing the PPWR declaration of conformity—Purchasing, Quality Management, Product Development, Sales? We discuss typical organizational models and a RACI framework that allows responsibilities to be clearly assigned.

Case study analysis of specific packaging Using real-world packaging examples, we work through together which supporting documents are required in each specific case and how the declaration of conformity is derived from them.

Outlook: PPWR Roadmap through 2030 The PPWR includes further stages—such as reusable quotas and increasing recycled content. We provide an overview of which requirements take effect when and how you can align your packaging strategy accordingly.

More about the masterclass: Target audience, format, and schedule

The PPWR Declaration of Conformity Masterclass is designed for specialists and managers who are responsible for or involved in implementing PPWR requirements and preparing the declaration of conformity within their companies. Prior knowledge of the Packaging Act (VerpackG) is helpful but not required—the training begins with the regulatory fundamentals and builds systematically upon them.

Typical Participant Profiles

  • Packaging Development and Packaging Management
  • Quality Management and Quality Assurance
  • Purchasing and Supplier Management
  • Product Management and Marketing (for private labels)
  • Sustainability and Compliance Officers
  • Management of small and medium-sized enterprises with packaging responsibilities

Format and Schedule

The masterclass is designed as a one-day intensive training course and combines technical instruction with case studies. Each content block is followed by a practical session in which the topics related to the declaration of conformity are explored in greater depth using concrete packaging examples. Questions regarding participants’ own packaging can be raised during the training.

More about the masterclass: Target audience, format, and schedule

Frequently Asked Questions About the PPWR Declaration of Conformity

The EU Packaging Directive raises numerous questions regarding its practical implementation—ranging from the delineation of responsibilities and the formal requirements for the declaration of conformity to deadlines and record-keeping obligations. The following answers provide an overview of the key issues we encounter most frequently in our consulting practice. All topics are explored in greater depth in our masterclass.

The Declaration of Conformity under the PPWR is a formal document in accordance with Article 39 and Annex VIII of the EU Packaging Regulation (Regulation 2025/40). In it, the manufacturer of packaging confirms that the packaging meets the requirements of Articles 5 through 12 of the PPWR—including restrictions on materials, recyclability, recycled content, minimization, and labeling. The declaration must be supported by complete technical documentation in accordance with Annex VII.

The preparation of a PPWR Declaration of Conformity involves several steps: First, the relevant packaging is identified and classified. Next, technical documentation in accordance with Annex VII is compiled for each packaging unit, containing information on material composition, recyclability, evidence of hazardous substances and PFAS, as well as other data. Based on this documentation, the formal declaration of conformity in accordance with Annex VIII is drawn up and signed by the manufacturer. In our masterclass, we guide you through this process step by step.

The manufacturer of the packaging is responsible for the PPWR Declaration of Conformity. Under the PPWR, a manufacturer is defined as any entity that develops or has packaging developed, or manufactures or has packaging manufactured, under its own name or brand, and places it on the market within the EU. For private labels, responsibility generally lies with the brand owner—even if the packaging is produced externally. Suppliers and packaging manufacturers are not considered producers in this context, but their data is included in the technical documentation.

The EU Declaration of Conformity pursuant to Annex VIII of the PPWR is a formal document issued by the packaging manufacturer that confirms compliance with Articles 5 through 12 of the PPWR. A supplier’s declaration, on the other hand, is a statement from a supplier regarding material properties, pollutant levels, or recycled content. It is an important component of the technical documentation underlying the Declaration of Conformity—but does not replace it.

Annex VIII of the PPWR specifies the mandatory information to be included in the declaration of conformity. This includes, among other things, the identification of the packaging, a reference to the relevant articles and requirements of the PPWR, the underlying harmonized standards or technical specifications, as well as information about the manufacturer and the responsible person, including the date and signature. We cover the exact structure and all required fields in detail in the Masterclass.

The technical documentation required under Annex VII of the PPWR includes all supporting evidence that substantiates the statements made in the declaration of conformity. This includes, in particular, a general description of the packaging, information on materials and design, evidence of compliance with substance restrictions (heavy metals, PFAS), assessments of recyclability, information on the proportion of recycled content, and evidence of packaging minimization. The requirements vary depending on the type of packaging.

Legally, August 12, 2026, is the deadline. As of that date, packaging may only be placed on the market in the EU if it is accompanied by a valid declaration of conformity. In practice, however, many trading partners and distributors request the declaration of conformity months before this deadline in order to ensure their own product planning. Early preparation is therefore strongly recommended.

The PPWR establishes different retention periods: For single-use packaging, the retention period for the declaration of conformity and technical documentation is five years; for reusable packaging, it is ten years—in each case, starting from the date the packaging is placed on the market.

Yes, the declaration of conformity under the PPWR is valid throughout the EU, as the regulation is directly applicable in all member states. However, it must take into account the relevant harmonized standards as well as country-specific requirements—such as national recyclability criteria in individual target markets. A separate declaration for each member state is not required.

As of August 12, 2026, packaging may no longer be placed on the market in the EU without a valid declaration of conformity. In practice, this means that trading partners, importers, and distributors will delist or refuse to accept products without a declaration of conformity. Market surveillance authorities may also impose sanctions. Even today, many retail companies are already taking a restrictive approach to missing documentation.

No. The masterclass is a training course. You will gain a comprehensive understanding of the structure, content, and requirements of the Declaration of Conformity and the underlying technical documentation. You will then draft the specific declarations for your packaging in-house, using the knowledge gained during the training. If needed, we can provide further support through a separate consulting engagement.

A basic understanding of the Packaging Act (VerpackG) or packaging materials is helpful but not required. The masterclass begins with the regulatory fundamentals of the PPWR and builds systematically on that foundation, so that even participants without in-depth prior knowledge can fully grasp the material.

Registration for the "PPWR Declaration of Conformity" Masterclass

Select your preferred date and secure your spot in the Masterclass on the PPWR Declaration of Conformity. Space is limited for each session.

Once we receive your registration, you will receive a confirmation with all further details.

Note on in-house training: The PPWR Declaration of Conformity Masterclass is also available as an in-house training session. We will then tailor the content to your packaging portfolio and supply chain situation.

Sonja Bähr
Sonja Bähr
Director Business Development












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