The PPWR requires the manufacturer to draw up an EU declaration of conformity under Article 39 and the model in Annex VIII once conformity has been demonstrated through the relevant procedure. The declaration must remain current and link to the correct technical documentation.
The basis: Articles 38 and 39 and Annex VIII
Before placing packaging on the market, the manufacturer carries out or arranges the relevant conformity assessment procedure and prepares the technical documentation. Once compliance with the applicable requirements has been demonstrated, the manufacturer draws up the EU declaration of conformity.
The declaration does not replace evidence
A signed form does not create compliance. It should be based on technical documentation, calculations, specifications, test reports and other evidence required for the specific packaging.
What should the declaration establish?
- clear identification of the packaging;
- details of the manufacturer and, where applicable, the authorised representative;
- reference to the relevant Union legislation;
- reference to standards or specifications used to demonstrate conformity, where applicable;
- consistency with the technical documentation for the specific product and version;
- the signature and responsibility of the relevant operator.
One declaration may cover more than one EU act
Article 39 provides for a single EU declaration of conformity where packaging or a product is subject to several Union acts requiring such a declaration. Its scope must match the legislation that actually applies.
Language and keeping the declaration current
The declaration should be drawn up or translated into the language or languages required by the Member State where the packaging is placed or made available on the market. It must also be updated when a change to the design, material, standard or another criterion affects conformity.
How long must the declaration be retained?
The PPWR requires technical documentation and the EU declaration of conformity to be retained after placing the packaging on the market for:
- 5 years – for single-use packaging;
- 10 years – for reusable packaging.
The role of third-party certificates
A certificate, laboratory report or RecyClass assessment may provide evidence for a specific area, but it does not take over the manufacturer's responsibility for the EU declaration of conformity.
Key point
The EU declaration of conformity should be the final element in a logical chain: requirement → evidence → conformity assessment → technical documentation → declaration. The compliance process should not start with the declaration form itself.