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.
How many packaging items does one declaration cover?
The conformity assessment and the declaration apply to the packaging unit as a whole. A bottle with closure and label therefore calls for one assessment and one declaration — but that declaration must include information on all the separate components.
Per packaging type, not per size. If your bottles differ in size but contain the same product, and the size difference affects none of the requirements in Articles 5 to 12, one declaration covers the whole range. If the products do differ, you may not group them under a single declaration — the assessment of minimisation, for instance, depends on the packaged product.
There is no exemption for transport packaging. Pallets, pallet collars, wrappings and straps are different packaging types and each require a separate assessment and a separate declaration.
In which language?
The EU declaration of conformity must be drawn up in — or translated into — the language(s) of the Member State where the packaging is placed or made available on the market, so that the market surveillance authority there can verify it. Supplying both the Netherlands and Germany? Account for both.
Note: the old standards no longer give certainty
Under the old directive, complying with the harmonised standards (EN 13427 to EN 13432) created a presumption of conformity. Under the PPWR that presumption has lapsed — those standards may now only be used as guidance. One exception: for the minimisation requirement the presumption of conformity still applies until the end of 2029.
Concretely for substances of concern: Annex C of EN 13428:2004 no longer creates a presumption of conformity, because the PPWR goes further than that standard (also covering effects on reuse and recycling, and a broader hazard scope). Until an updated standard is available you can still use the existing one as a method. For the four heavy metals the Commission recommends CEN report CR 13695-1 as the measurement method. Once new harmonised standards are listed in the EU Official Journal, the presumption of conformity returns.
What can you outsource — and what not?
You may have the conformity assessment carried out on your behalf, for example by a laboratory or a certification scheme. The declaration itself may also be drafted by an authorised representative. But you must draw up the technical documentation yourself: that obligation cannot be delegated. And however you arrange it — legal responsibility for compliant packaging remains with you as the manufacturer and cannot be transferred by contract.
Your suppliers are obliged to cooperate: under Article 16 they must provide you with all the information and documentation you need to demonstrate conformity. They may not refuse.
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.