What is the EU declaration of conformity under the PPWR?

The EU declaration of conformity under Article 39 is the manufacturer's formal statement that a packaging meets the requirements of the PPWR applicable to it. The template is set out in Annex VIII. The underlying evidence is documented in the technical documentation under Annex VII. The declaration is drawn up by the manufacturer and may rely on information and evidence from suppliers. The legal responsibility remains with the manufacturer.

What matters is which requirements are already applicable at the relevant point in time. The basic requirement under Article 6(1) that packaging must be recyclable has applied since 12 August 2026. Until the harmonised design-for-recycling criteria under Article 6(4) are available, however, the Commission does not yet require a conformity assessment under Article 38 and Annex VII for recyclability. The minimum recycled content targets under Article 7 likewise apply only at a later date.

An EU declaration of conformity should therefore not certify blanket compliance with all requirements of Articles 5 to 12, but reflect correctly the requirements actually applicable at that time.