Do I need a separate declaration of conformity for each type of packaging?

A written declaration of conformity must be issued for each type of packaging; it must indicate the packaging to which it applies (Annex VII No. 4 PPWR).

Must the PPWR declaration of conformity be in German?

For the German market, the declaration may be issued in either German or English at the choice of the producer (Section 62 VerpackDG). For other Member States, their respective language requirements apply (Article 39(2) PPWR).

From when are fines threatened for missing declarations of conformity?

The obligations have applied since 12 August 2026. The German penalty provisions for infringements of the PPWR obligations will not apply until 12 February 2027 (Section 66(2), Section 68(17) of the German Packaging Act (VerpackDG)).

PPWR Knowledge As of: 12 August 2026

PPWR compliance declaration: Who needs it, what goes into it – and from when

Q: Is there an official template for the PPWR declaration of conformity?

Yes. Annex VIII to the PPWR contains the binding eight-point template on which the structure and content of the EU declaration of conformity must be based (Article 39(2), Annex VIII PPWR).

Since 12 August 2026, the EU Packaging Regulation (PPWR) has applied. Anyone who manufactures and places packaging on the market must assess and document its conformity – and issue an EU declaration of conformity. This article explains and contextualises the requirement, mandatory contents according to Annex VIII, language, retention, and the important question of when violations become subject to fines in Germany.

Content

What is the EU Declaration of Conformity?
Who has to issue it?
When does the requirement come into force – and when do fines apply?
Mandatory content in accordance with Annex VIII
Language and storage
What happens if the explanation is missing?
Frequently Asked Questions

What is the EU declaration of conformity under the PPWR?

The EU Declaration of Conformity serves as proof that packaging meets the requirements of Articles 5 to 12 of the PPWR – including, amongst other things, the provisions on substance restrictions, recyclability, the proportion of recycled content, minimisation and labelling Article 39(1) PPWR. It marks the end of a three-stage process:

Conformity assessment following the procedure set out in Annex VII (internal production control, „Module A“) Article 38 PPWR
Technical documentation draw up in accordance with Annex VII Art. 15(2) PPWR
EU Declaration of Conformity issue – in accordance with the model in Annex VIII, kept constantly up to date Article 39(2) PPWR

Important: This declaration is not a certificate issued by a public authority or testing body. By issuing it, the producer assumes full responsibility for ensuring that the packaging complies with the requirements of the Regulation. Article 39(4) of the PPWR.

Who has to issue the declaration of conformity?

The person required to exhibit is the Manufacturer – so the economic operator who manufactures the packaging, or has it manufactured, and places it on the market under their own name or trademark. They carry out the conformity assessment procedure before placing it on the market and then issue the declaration Art. 15(2) PPWR. A written declaration of conformity must be issued for each type of packaging. Annex VII No. 4 PPWR.

Warning: semantic pitfall: The PPWR distinguishes between the Manufacturer (conformity obligations, English „manufacturer“) from producer (extended producer responsibility, English „producer“). The German version thus partially reverses the conceptual logic familiar from the Packaging Act. Who has which role depends on the actual activities – this can vary per product line. Importers and distributors also have their own verification and cooperation obligations regarding the declaration. Art. 18, 19 PPWR.

When does the requirement come into force – and when do fines apply?

The PPWR has been in force since 12 August 2026. This means that there is an obligation for conformity assessment, technical documentation, and EU declaration of conformity for packaging placed on the market from this date onwards.

For enforcement in Germany, it is worth taking a close look at the Packaging Law Implementation Act (VerpackDG): infringements of the PPWR obligations regarding conformity assessment, documentation and declaration are classified as administrative offenses there Section 66(2)(3) and (4) of the Packaging Act (VerpackDG) – however, these offences are only punishable by a fine from 12 February 2027 Section 68(17) of the German Packaging Act (VerpackDG).

Classification: This is a breathing space, not a free pass. The obligations themselves have been in force since 12 August 2026 – market surveillance authorities can already object to missing or incorrect declarations and demand corrections (see below). Anyone who uses the six months to cleanly set up their portfolio, roles and documents will be on the right side by the date penalties become applicable.

What applies to Your Packaging – today and from 2027? The free impact check provides an initial assessment in 5 questions.

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Mandatory content: The template in Annex VIII

The structure and content of the declaration must comply with the model set out in Annex VIII to the PPWR and contain the elements of the relevant module from Annex VII. Article 39(2) PPWR. The pattern provides for eight points Annex VIII PPWR:

Number of the declaration and unique packaging identifier
Name and address of the producer – and where applicable of his authorised representative
Reference to the sole responsibility of the manufacturer for the exhibition
Subject of the declaration: Identification for traceability and description of the packaging
Reference to the relevant Union harmonisation legislation, whose requirements are met
Specification of the underlying harmonised standards, common specifications or other technical specifications
If applicable: Details of notified body and issued certificates
Additional information as well as location, date, name, position and signature

If packaging is subject to several EU legal acts, each of which requires a declaration of conformity, a single one is sufficient. only explanation for all affected legal acts – specifying the respective references in the Official Journal Art. 39(3) PPWR.

Language and storage

The declaration shall 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) PPWR. For Germany: The declaration can, at the producer's choice, in German or English be issued Section 62 of the Packaging Act.

Technical documentation and declaration of conformity must be kept: five years upon placing single-use packaging on the market, ten years with reusable packaging Article 15(3) PPWR. One copy is to be made available to the competent authorities upon request. Annex VII No. 4 PPWR.

What happens if the declaration is missing or incorrect?

A missing or incorrectly issued EU declaration of conformity is considered formal non-conformanceThe Member State shall first request the economic operator to take corrective action Art. 62 para. 1 lit. a, b PPWR. If the defect persists, all appropriate measures must be taken – up to and including a ban on making the product available, recall or withdrawal from the market. Art. 62(2) PPWR. From 12 February 2027, the stated fine offences will be added in Germany.

Frequently asked questions about the PPWR declaration of conformity

Is there an official template for the PPWR declaration of conformity?

Yes. Annex VIII of the PPWR contains the mandatory eight-point template upon which the structure and content of the declaration must be based Article 39(2), Annex VIII PPWR. The specific details – identifier, specifications, standard references – must be drawn up individually for each type of packaging.

Do I need a separate declaration for every piece of packaging?

For each Packaging type a written declaration of conformity must be issued; it must be clear from it which packaging it applies to Annex VII No. 4 PPWR.

Must the explanation be in German?

For the German market, the declaration may be issued in German or English at the choice of the producer. Section 62 of the Packaging Act. For other Member States, their respective language requirements apply Article 39(2) PPWR.

Can the authorised representative take over the declaration?

The authorised representative may fulfil the obligations relating to the drawing up of the technical documentation on behalf of and under the responsibility of the manufacturer, provided this is specified in the mandate Annex VII No. 5 PPWR. Responsibility for the conformity of the packaging remains with the producer Article 39(4) of the PPWR.

From the legal text to the finished draft

PPWR Radar explains, classifies and prioritises – for your roles and your packaging portfolio. From your compliance profile, the document generator creates pre-filled drafts of your EU Declaration of Conformity following the structure of Annex VIII, as well as the framework for your technical documentation – complete with reference, legal status date and an update notice should the legal situation change.

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5 questions, no registration – initial assessment of what the PPWR means for your packaging.

This article provides an explanation and overview; it does not constitute legal advice and is no substitute for an assessment of the individual case. Sources: Regulation (EU) 2025/40 (PPWR, OJ L of 22 January 2025), Packaging Law Implementation Act (VerpackDG, Federal Law Gazette 2026 I No. 207). Legal status: 12 August 2026.