From 12 August 2026 no packaging at all may go on the EU market without a declaration of conformity. It is the pivot of the whole PPWR legislation: the document in which you record that your packaging meets the essential requirements, and in which you also substantiate that.
Without a declaration the packaging is non-conforming. Non-conforming packaging may not be placed on the market. That is how simple the sanction is.
Who draws it up?
The manufacturer — the party that designs or has the packaging made under its own name or brand. So that is you too even if you do not produce the packaging yourself. Put your logo on a box that someone else prints, and you are the manufacturer of that box.
The importer checks that the declaration is present, keeps a copy for five years, and may place nothing on the market without a declaration. The distributor checks that the packaging meets the requirements in Articles 5 to 12, and reports non-conformity.
Micro-enterprises — fewer than ten employees and at most two million euros in turnover or balance sheet total — can under conditions be exempt from the manufacturer obligations, but only when their packaging supplier is established in the Netherlands. This is an exemption with sharp edges; check your situation. See roles.
What must it contain?
The requirements are in Annexes VII and VIII of the regulation. In broad terms:
- identification of the packaging: type, batch or serial number
- name and address of the manufacturer
- reference to the harmonised standards or technical specifications used
- substantiation that harmful substances stay below the limit values (PFAS, heavy metals)
- substantiation of the packaging minimisation
- substantiation of the recyclability
- design drawings and material composition
- date and signature on behalf of the manufacturer
The declaration rests on technical documentation. You keep that documentation for five years for single-use packaging and ten years for reusable.
The hardest part: substantiating recyclability
The recyclability obligation already applies from 12 August 2026 — not only from 2030. What is added in 2030 is the classification into performance grades A, B or C. Until then you substantiate recyclability in the declaration of conformity, for example via the European harmonised standard EN 13430. For minimisation you do the same via EN 13428.
This distinction is left out of many Dutch summaries, which makes companies think recyclability is a 2030 problem. See recyclability.
Not sure whether this applies to your packaging? The PPWR Check walks through your role, market and material in eight questions and shows per pillar what applies to you. Take the PPWR Check →
Where it breaks down in practice
The declaration is a data question, not a legal question. The information you need — material specifications, PFAS declarations, recyclate content, laminate build-up — sits with your suppliers. Suppliers are required under the PPWR to provide that data, but that does not mean they will do it tomorrow.
A realistic order:
- Inventory all packaging types you place on the market. Not all SKUs — all types.
- Determine per type who the manufacturer is. Often it is you and you did not know it.
- Send your suppliers a request with a concrete deadline. Ask for material composition per component, total fluorine content for food contact, and the standard on which their recyclability claim rests.
- Build a single template for the technical documentation and fill it in per packaging type.
- Sign the declarations and store them where an inspector can obtain them within a reasonable period.
Verpact is working on a template for the declaration of conformity, without legal guarantee.
Enforcement
The Human Environment and Transport Inspectorate (ILT) supervises in the Netherlands. During an inspection the declaration may be requested. Its absence can lead to enforcement and fines, and to removal of the packaging from the market.