What is a Declaration of Conformity and do I need one for the PPWR?

The Declaration of Conformity (DoC) is a document by which you, as the manufacturer or person placing goods on the market, confirm in writing that your packaging meets all requirements of Regulation (EU) 2025/40 – in particular regarding recyclability, recycled content, and minimum volume. It is not an official approval, but your own self-declaration with legally binding effect.

When is it mandatory? From 12.08.2026, the PPWR requires a documented conformity assessment for virtually all packaging placed on the EU market. The Declaration of Conformity is the formal conclusion of this process.

What must it contain? - Name and address of the manufacturer or authorised representative - Description of the packaging (material, intended use, packaging category) - Reference to the standards or technical specifications applied - Statement of conformity with the relevant PPWR requirements - Date, place, signature, and position of the signatory

Template: No binding EU template exists yet – the implementing acts for the PPWR are expected by mid-2026. For the transitional period, an internal document modelled on the CE Declaration of Conformity is recommended as a structural reference, supplemented by PPWR-specific information on recyclability and recycled content.

Important: The DoC must be made available upon request to authorities and market surveillance bodies – it does not need to be publicly disclosed, but must be retained for at least 5 years.

For a binding assessment of your specific product portfolio, please contact your relevant Chamber of Commerce (IHK) or competent authority.