The industry association Pro-K has published a template for an EU Declaration of Conformity in accordance with the new EU Regulation on Packaging and Packaging Waste (PPWR). The template is aimed at manufacturers, producers and distributors of reusable and transport packaging made of plastic and is intended to support companies with the new documentation and proof obligations.
With the PPWR, the European Union is introducing a comprehensive conformity regime for packaging for the first time. From 12 August 2026, companies will have to provide technical documentation and a formal EU declaration of conformity for numerous packaging types. The template developed by Pro-K together with member companies of the Storage and Transport Systems working group takes into account, among other things, requirements for recyclability, the use of recycled content, reusability, substance restrictions, and technical documentation. According to the association, it will be continuously adapted to regulatory developments.
Orientation on open PPWR requirements
In Pro-K's assessment, there are currently still considerable uncertainties regarding the implementation of the PPWR. Many specific requirements will only be established within the framework of European secondary legislation. These include, among others, provisions on the definition of post-consumer recyclates, the calculation of recyclate quotas, proof of recyclability, and the assessment of the reusability of packaging.
The association sees the danger that established reusable plastic systems will be unnecessarily burdened by unclear or impractical requirements. These include, for example, pallets, crates, containers, and crates for bottles, which, according to Pro-K, already have high circulation numbers, long service lives, and closed material cycles.
Association calls for planning certainty
Jürgen Schultz, spokesperson for the professional group for storage and transport systems at Pro-K, emphasises: „The manufacturers of reusable plastic containers are not latecomers to the transformation – they are its pioneers.“
With an eye on the remaining detailed regulations, Schultz also demands: „What is now needed quickly are clear and practicable provisions through European secondary legislation. Companies need planning security, not regulatory chaos.“ The association is calling for proportionate requirements from the federal government and EU institutions regarding conformity assessment, proof of compliance, and labelling, in order not to burden existing reusable and circular systems with additional bureaucracy.
Source: Pro-K
