The PPWR Declaration of Conformity: What It Is and How to Create One

The Document That Keeps Your Products on Shelves

Among all the PPWR requirements hitting on August 12, 2026, the Declaration of Conformity (DoC) is the one that will actually stop your products from being sold. Customs will ask for it. Marketplaces will demand it. Regulators will audit it. Without a properly completed DoC for your packaging, your products can be blocked at the border, suppressed from listings, or pulled from shelves.

The DoC isn't complicated in principle — it's a structured document confirming your packaging meets PPWR requirements. But most sellers have never created one, don't know what goes in it, and are relying on suppliers who may not provide complete or accurate data.

This article covers exactly what a PPWR Declaration of Conformity is, what it must contain, when you need one, and how to create one that holds up to scrutiny.

What Is a Declaration of Conformity Under PPWR?

The Declaration of Conformity is defined in Article 39 of the PPWR, with the required contents specified in Annex VIII. It's a legally binding document in which the manufacturer (or importer, or authorised representative) declares that the packaging meets all applicable requirements of the Regulation.

Key points:

• It's mandatory. Every packaging type placed on the EU market from August 12, 2026 onward must have a DoC. There is no exemption for small volumes, no simplified procedure for low-value products, no de minimis threshold.
• It's your responsibility. If you're the manufacturer placing packaged products on the EU market, you issue the DoC. If you're an importer bringing packaged goods into the EU, you assume the manufacturer's obligations for compliance — meaning you issue the DoC, not your overseas supplier. If your supplier provides a DoC, that's helpful as supporting documentation, but you're still responsible for its accuracy.
• It covers the packaging, not the product. This is separate from CE marking declarations, product safety declarations, or any other conformity documentation. The PPWR DoC is about packaging only — its recyclability, its recycled content, its substance restrictions, and its compliance with the Regulation's design requirements.
• It must be available on demand. You don't file the DoC with a central authority (unlike EPR registrations, which are country-by-country). But you must be able to produce it immediately when requested by market surveillance authorities, customs, or marketplace platforms. "I'll get back to you" isn't a compliance strategy.

When You Need a DoC — And When You Don't

You need a DoC if:

• You manufacture packaged products in the EU and place them on the EU market
• You import packaged products from outside the EU and place them on the EU market
• You distribute packaged products under your own brand or trade name (you're considered the manufacturer under PPWR)
• You modify packaging in a way that affects compliance (re-boxing, re-labelling, adding packaging components)
• You're an authorised representative assuming the manufacturer's PPWR obligations for a non-EU producer
• You're a fulfilment service provider (Amazon FBA, third-party logistics) if you add packaging to products — the added packaging needs a DoC

You probably don't need a DoC if:

• You sell entirely outside the EU with no EU market placement
• You're a retailer selling products in their original, unmodified packaging — the manufacturer's DoC covers you, but you should still have a copy accessible in case of audit

The grey area: marketplace sellers

If you're a marketplace seller using FBA, the responsibility split depends on who introduces the packaging to the EU market. Your branded product in your packaging: you need the DoC. Amazon's shipping packaging (the outer Amazon box): Amazon is responsible for that DoC, not you. Your product repackaged by Amazon: if Amazon adds packaging to your product for fulfilment, Amazon is responsible for the added packaging, but your product's own packaging still needs a DoC from you.

The safe approach: assume you're responsible for your product's packaging DoC regardless of fulfilment method.

What Must Be in the Declaration of Conformity

Annex VIII of the PPWR specifies the required contents. Here's exactly what you need, with the level of detail that passes scrutiny.

1. Packaging Identification

A unique identification of the packaging that allows traceability. Include: product or SKU reference number, clear description of the packaging format (e.g., "Folding carton box, 200×150×80mm, 350gsm SBS board with aqueous coating"), and photograph or technical drawing (not strictly required by the regulation text but strongly recommended).

2. Responsible Party Information

Name, registered trade name or trademark, and postal address of the manufacturer. If the manufacturer is outside the EU, this must be the importer's information (or the authorised representative's). Include: full legal entity name, registered office address (not a PO box), contact email and phone, and VAT or company registration number.

3. Statement of Responsibility

A single sentence, but it carries legal weight: "This declaration of conformity is issued under the sole responsibility of the manufacturer." The PPWR requires this exact formulation or its equivalent. Don't paraphrase creatively.

4. Object of the Declaration

Describe the packaging covered by the DoC. This can be: a single packaging format (one SKU's box), a group of identical packaging formats (if 47 SKUs use the exact same box, one DoC can cover all 47), or a packaging family (if variations differ only in dimensions but use identical materials and construction). Be specific. "Cardboard box" is not sufficient. "Folding carton box, clay-coated newsback board, 350gsm, 200×150×80mm, with transparent PET window 60×40mm" is sufficient.

5. Recyclability Grade

The assigned recyclability grade (A through E) per Article 6, with the supporting calculation:

• Total packaging weight per unit: ___ g
• Recyclable-at-scale component weight: ___ g
• Recyclability percentage: ___%
• Assigned grade: ___

List each component material and its recyclability status. The component breakdown shows your work. If a regulator questions your grade, the breakdown gives them a specific point to challenge — which is better than them challenging the entire DoC because it lacks transparency.

6. Recycled Content (Where Applicable)

For plastic packaging components, declare the percentage of post-consumer recycled content. If your packaging contains no plastic components, state that explicitly.

7. Substance Restrictions

Confirmation that the packaging complies with PFAS restrictions in food-contact packaging (from August 12, 2026) and heavy metals restrictions per the Packaging Directive 94/62/EC (lead, cadmium, mercury, hexavalent chromium: sum ≤ 100 mg/kg). If the packaging is not food-contact and contains no restricted substances, state it — don't leave this field blank.

8. Empty-Space Ratio

For grouped packaging, transport packaging, and e-commerce packaging: confirmation that the empty-space ratio does not exceed 40%. If your DoC covers primary/sales packaging only, this requirement may not apply — but if your product box is oversized relative to its contents, verify this.

9. References to Harmonised Standards

List any harmonised standards applied (e.g., EN 13430 for material recycling requirements). If no harmonised standards were applied — which is the reality in 2026 since the standards are still being updated for PPWR — you can state that assessment was conducted per the methodology referenced in Article 6.

10. Date and Signature

Date of issue (DD/MM/YYYY), name and position of the signatory (must be a person with authority to bind the company), and signature (electronic signature is fine — DocuSign, Adobe Sign, or embedded digital certificate).

Example DoC: Walkthrough

Here's what a completed DoC looks like for a typical e-commerce product.

PPWR DECLARATION OF CONFORMITY — Per Regulation (EU) 2025/40, Article 39 and Annex VIII

*1. Packaging Identification*

Product: Organic Coffee Beans — 250g retail pack SKU: COF-250G-RETAIL Packaging description: Stand-up pouch, 180×260mm, matte finish, with one-way degassing valve and tear notch. Re-sealable zipper closure.

*2. Manufacturer*

GreenBean Roasters GmbH, Roasterystraße 42, 10997 Berlin, Germany VAT: DE123456789 | Email: compliance@greenbeanroasters.de

*3. Statement of Responsibility*

This declaration of conformity is issued under the sole responsibility of the manufacturer.

*4. Object of the Declaration*

The packaging described in item 1 for products SKU COF-250G-RETAIL and COF-250G-RETAIL-3PACK.

*5. Recyclability Grade*

|-----------|----------|--------|----------------------|

Total packaging weight: 15g | Recyclable-at-scale weight: 1g (PE zipper) Recyclability percentage: 1/15 = 6.7%

*Assigned Grade: E*

Note: This packaging is E-grade and must be redesigned or replaced before January 1, 2030. A transition project to mono-material PE packaging is in progress (target: Q3 2027).

*6. Recycled Content*

The pouch body contains no post-consumer recycled content (multi-layer laminate with aluminium barrier — PCR integration not currently available at commercial scale). The PE zipper contains 30% post-consumer recycled PE.

*7. Substance Restrictions*

The packaging complies with: heavy metals restrictions per Directive 94/62/EC (<100 mg/kg sum of Pb, Cd, Hg, Cr VI). PFAS restrictions: Not applicable (not a food-contact packaging format).

*8. Empty-Space Ratio*

Not applicable — this is primary/sales packaging. Empty-space ratio <5% (product fills the pouch volume).

*9. Harmonised Standards*

EN 13430:2004 referenced for recyclability assessment methodology, supplemented by RecyClass Protocol v3.0 for multi-material assessment.

*10. Signature*

Issued: 09 July 2026 Signed: Anna Schmidt, Head of Quality & Compliance, GreenBean Roasters GmbH

A few things to note about this example:

• The grade is E, and they acknowledge it. This is important. A DoC that claims an E-grade package is A-grade is a false declaration. An E-grade DoC with a documented transition plan is compliant. The DoC's job is to state the truth, not to look good.
• The component breakdown is specific. Every material, every weight, and a clear yes/no for recyclability at scale. No hand-waving.
• PFAS non-applicability is explained. "Not applicable" alone isn't sufficient — explain why.

Don't Make These 5 Mistakes

1. Confusing the packaging DoC with the product CE declaration

The CE marking declaration covers your product's compliance with applicable EU product directives. The PPWR DoC covers your packaging. They are separate documents, separate requirements, separate legal bases.

2. Copying your supplier's DoC without verification

Your packaging supplier may provide a DoC — but if the data is wrong, it's your problem, not theirs. Verify the material composition and weights. A DoC with your company's name on it is your declaration, regardless of who prepared the data.

3. Issuing one blanket DoC for everything

A single DoC covering "all our packaging" without specifying individual packaging types is unlikely to pass scrutiny. Each packaging type has its own material composition, weight, and recyclability profile.

4. Leaving fields blank or writing "N/A" without explanation

Empty fields in a regulatory document invite questions. If a requirement doesn't apply, state that explicitly and briefly explain why.

5. Not dating and signing

A DoC is a living document — it should be dated so it's clear when the assessment was performed. Signatures (electronic or ink) are legally required. An unsigned DoC is a draft, not a declaration.

How DutyScope Automatically Generates Your DoC

Manually creating DoCs for every packaging format is tedious and error-prone — especially if you have dozens or hundreds of SKUs.

DutyScope's PPWR module generates complete Declaration of Conformity documents from the packaging data you enter once: enter your packaging details, the system assigns recyclability grades, your DoC is generated to Annex VIII requirements, export as PDF, and update and re-issue when packaging changes.

For sellers managing 50+ SKUs across multiple countries, the time saved is measured in days, not hours.

Generate your PPWR compliance documentation →

This article provides general guidance and does not constitute legal advice. Always consult your legal counsel for questions specific to your situation.