A brief summary: From 12 August 2026, the PPWR will introduce a mandatory EU declaration of conformity for packaging for the first time. The manufacturer, as defined by the PPWR, is responsible for assessing the packaging’s compliance based on technical documentation before placing it on the market and for drawing up the declaration. The EU declaration of conformity generally applies throughout the single market and must be presented to the authorities upon request. Missing or incorrect declarations can result in sales bans, product recalls, fines, market surveillance measures and, in individual cases, import delays. While AI assistants can support the drafting process, they cannot replace the required technical evidence or legal responsibility and are therefore of limited use when preparing a Declaration of Conformity independently. To understand all the details, please read on carefully:
From 12 August 2026, the EU Declaration of Conformity (DoC) will be one of the key new obligations under the PPWR. Please note: this does not apply to packaging already placed on the market before this date. The EU Declaration of Conformity for packaging is comparable to the CE Declaration of Conformity required for many products – but specifically for packaging. The obligation to issue a Declaration of Conformity and the requirements for it are set out in Articles 15, 38 and 39 of the PPWR.
Who needs an EU Declaration of Conformity for packaging?
Responsibility always lies with the manufacturer of the packaging within the meaning of the PPWR. This is not necessarily the packaging producer (e.g., a cardboard factory), but rather the party that first places the packaging on the EU market under its own name or brand. In practice, this means:
- Brand owners with own-brand products: yes
- Producers who package their own products: yes
- Importers from third countries under their own brand: yes
- Importers importing from third countries: yes
- Packaging producers acting as suppliers: only insofar as they themselves act as manufacturers within the meaning of the PPWR; they often provide the necessary technical data to their customers.
From when is an EU Declaration of Conformity required for packaging?
For all packaging placed on the EU market for the first time on or after 12 August 2026.
Placing on the market refers to the point at which packaging is made available on the European Union market for the first time, for example:
- by an EU producer,
- by an importer upon import from a third country,
Before placing the packaging on the market, the following must already have been completed:
- the conformity assessment must have been carried out,
- the technical documentation must have been drawn up,
- the EU Declaration of Conformity must have been signed.
There is no separate transition period for this.
What must the EU Declaration of Conformity for packaging contain?
The PPWR prescribes a mandatory template in Annex VIII. Among other things, it must include:
- clear identification of the packaging
- manufacturer’s details
- where applicable, details of the authorised representative
- a declaration that the packaging complies with the requirements of Articles 5–12 of the PPWR
- harmonised standards or technical specifications applied
- references to the technical documentation
- place and date
- name and signature of the responsible person
Furthermore, the declaration must be kept up to date at all times if any changes are made to the packaging.
Does the EU Declaration of Conformity for packaging apply throughout the EU?
Yes. It is explicitly an EU Declaration of Conformity. In principle, a single declaration applies throughout the single market. However, it must be translated into the language(s) required by the respective Member State.
How long must the EU Declaration of Conformity for packaging be retained?
- Single-use packaging: 5 years
- Reusable packaging: 10 years
Market surveillance authorities may request it at any time.
What happens if I do not draw up an EU Declaration of Conformity for packaging, or if the one I draw up is incorrect?
The Declaration of Conformity is a key document for presentation to the supervisory authority. If a declaration is missing or implausible, the authority may request supporting evidence, and products may be held up at customs. The possible consequences if an EU Declaration of Conformity for packaging is found to be incorrect or incomplete include:
- Ban on distribution
- Sales suspension
- Withdrawal from the market
- Recall of packaging already sold
- Official orders
- Fines in accordance with national law
The PPWR expressly obliges Member States to introduce effective sanctions.
How high are the fines if I do not draw up an EU Declaration of Conformity for my packaging?
The PPWR itself does not specify any fixed amounts. Each Member State must set its own penalties. Germany has implemented these in the VerpackDG (Packaging Law Implementation Act). Under Section 66, fines of up to €200,000 are provided for.
Can customs stop my goods at the border if I have not drawn up an EU Declaration of Conformity for my packaging?
Yes – under certain circumstances. Market surveillance and customs authorities cooperate across the EU. If, upon import, there are significant doubts as to whether the packaging complies with the PPWR or the necessary documentation is missing,
- release may be suspended,
- additional documentation may be required,
- or the goods may be handed over to the market surveillance authorities.
Customs does not decide on technical compliance itself but works in collaboration with the relevant market surveillance authorities. These authorities may subsequently prohibit the goods from being placed on the market or order further measures.
Will online marketplaces require an EU Declaration of Conformity for packaging?
The PPWR does not explicitly oblige marketplaces to request every Declaration of Conformity. In practice, however, it is not unlikely that large platforms will require such evidence. There are several reasons for this:
- Amazon already requires CE documentation, DoCs or test reports for numerous product groups.
- Since the Product Safety Regulation (GPSR) came into force, marketplaces have increasingly been proactively requesting compliance documents.
- The PPWR establishes, for the first time, a standardised EU Declaration of Conformity for packaging that can be easily accessed digitally.
It is therefore entirely possible that online platforms could request this declaration in future in a similar way to CE documents – if not at the time of listing, then perhaps on an ad hoc basis during inspections. However, there is currently no explicit legal obligation for marketplaces to request every PPWR Declaration of Conformity.
How much time do I have to respond if market surveillance authorities have enquiries regarding my EU Declaration of Conformity for packaging?
If an enquiry is received from the authority, you generally have four weeks to submit the Declaration of Conformity. Experience shows that in larger companies, such enquiries are often forwarded to the wrong department, meaning that the actual processing only takes place in the final week. This is where trade-e-bility is happy to provide prompt assistance, particularly when time is of the essence.
Can I use AI assistants to draw up my EU Declaration of Conformity for packaging?
Given the limited time remaining until 12 August 2026, using AI assistants to draw up the EU Declaration of Conformity for packaging is certainly an option that can make the process of creating the DoC easier. However, it is important to make a clear distinction here:
AI is very well suited to creating a draft, structuring the document in accordance with Annex VIII, formulating individual phrases, translations, consolidating supplier data or carrying out plausibility checks.
AI is not particularly suitable for assessing recyclability, verifying recycled content, assessing material compliance or chemical requirements, checking harmonised standards and, above all, assuming legal responsibility. The latter is the key point that strongly argues against drawing up the DoC using AI assistants. AI only recognises the data it is given. If material data or test results are incorrect or incomplete, it will still generate a formally plausible declaration. For most distributors or producers, however, it is almost impossible to detect this themselves, whereas market surveillance authorities can quickly identify implausible Declarations of Conformity. During an inspection by the authorities, evidence relating to the standards and tests mentioned in the declaration is required. AI cannot provide this evidence, which can lead to problems, particularly regarding the consistency and traceability of multiple declarations. AI solutions can also produce inconsistent declarations for different components, which may be quickly identified by the authorities. It is therefore advisable to consult an expert.
Why should I commission an expert to draw up the EU Declaration of Conformity for my packaging?
As mentioned at the outset, the DoC for packaging generally applies across the entire single market. Therefore, if it is flagged in just one country, this can lead to problems in several countries simultaneously due to the interconnected nature of market surveillance authorities. trade-e-bility therefore recommends that, during the introductory phase of the PPWR and for standard packaging with complete supplier data, AI should only be used in the most extreme emergencies, and even then only as an assistant in drafting the declaration. Subsequently, a technical review should be carried out by an expert. trade-e-bility is happy to assist you with this.
For new packaging, in-house developments or complex material composites, the preparation or approval should only be carried out by a product compliance or packaging expert. The real challenge lies not in writing the declaration – which amounts to just a few pages – but in structuring the technical documentation in accordance with Annex VII in a robust manner and being able to demonstrate that all the requirements of Articles 5–12 of the PPWR are actually met. It is precisely this technical documentation that is crucial in the event of a dispute or an inspection by the authorities. Here, too, trade-e-bility is happy to assist you.
How can trade-e-bility help me with my EU Declaration of Conformity for packaging?
trade-e-bility helps you create consistent and traceable documents and also offers support at short notice in emergencies, particularly for Declarations of Conformity covering various packaging components and combinations. This extends to packaging with technological components such as RFID chips and radio modules, where additional regulations such as RED or RoHS must be taken into account – making the Declaration of Conformity significantly more complex. trade-e-bility also offers the option of using a system to generate a suitable Declaration of Conformity specifically for each combination, which is particularly efficient for customers with a wide variety of packaging. trade-e-bility is especially helpful in emergencies, for example, when a regulatory authority requests a Declaration of Conformity and you need to respond quickly.
Do you urgently need help drawing up your EU Declaration of Conformity (DoC) for packaging in accordance with the requirements of the PPWR? trade-e-bility will be happy to help!
