On 12 August 2026, one requirement quietly changes how packaging moves into the European Union. From that date, no packaging type can be placed on the EU market without a signed EU Declaration of Conformity. There is no grace period, no sell-through window, and no inventory exemption. If the document is missing, the packaging is not considered lawfully placed on the market.
For most manufacturers, this is not a manufacturing problem. Your bottles, cartons, films, and closures may already meet the physical requirements. The PPWR Declaration of Conformity is a documentation and evidence problem: proving conformity, per packaging type, with data you have to collect from suppliers across your chain.
This guide explains what the declaration must contain, the substance limits behind it, who carries the obligation, and a practical checklist to close the gap before the deadline.
Key Takeaways
📌 From 12 August 2026, every packaging type on the EU market needs a signed EU Declaration of Conformity under Article 39 of Regulation (EU) 2025/40.
⏳ There is no grace period. Packaging without a valid DoC is treated as not compliantly placed on the market from day one.
📊 The declaration is only as strong as the technical file behind it, built from Annex VII evidence, substance test results, and supplier data.
⚠️ Food-contact packaging faces binding PFAS limits under Article 5(5): 25 ppb individual, 250 ppb sum, and 50 ppm total fluorine.
🔗 Importers do not create the DoC. They must hold a copy per packaging type and make technical documentation available to authorities on request.
🏭 Article 21 can reclassify an importer or distributor as the manufacturer, transferring the full DoC obligation onto them.
🤖 The real bottleneck is collecting and verifying supplier evidence at scale, which is where AI document parsing and automated supplier portals change the economics.
What the PPWR Declaration of Conformity Actually Is
The Declaration of Conformity is a written, legally binding self-declaration in which the manufacturer confirms that a specific packaging type meets the sustainability requirements of Articles 5 to 12 of Regulation (EU) 2025/40. It is defined in Article 39, and it follows the model structure set out in Annex VIII.
It is a self-declaration, not a third-party certificate. No notified body is involved, because conformity assessment under Article 38 uses Module A, internal production control. That does not make it low-stakes. By signing, the manufacturer assumes full legal responsibility for the packaging's compliance under Article 39(4).
The declaration applies per packaging type. A company with fifty distinct formats needs fifty declarations, each backed by its own evidence file. This is where the workload is hiding, and it maps directly to the challenge Certivo addresses through BOM-level compliance intelligence and centralized supplier documentation.
Book a Compliance Risk Assessment to map your PPWR exposure across every packaging type and supplier before the deadline: https://www.certivo.com/contact
What Must Be in the Declaration (Annex VIII)
The Annex VIII model has eight numbered points, plus a signature block and a unique identification number. Read together, the mandatory content includes:
✓ A unique identification number that ties the declaration to your internal systems, such as a material or supplier reference
✓ The name and address of the manufacturer, or authorised representative where applicable
✓ A statement that the declaration is issued under the manufacturer's sole responsibility
✓ Unique identification of the packaging type
✓ The Union act covered, namely Regulation (EU) 2025/40
✓ Reference to conformity with the applicable requirements under Articles 5 to 12
✓ The conformity assessment reference (Module A under Annex VII), which normally reads "not applicable" for the notified-body point
✓ Signature, place, date, and name of the signatory
A point that does not apply is marked as such rather than deleted, because market surveillance authorities read the declaration against the model numbering. A declaration without a supporting technical file will not survive scrutiny. That evidence file, compiled under Annex VII, is the substance behind the signature.
The Substance Limits Behind the Signature
The declaration is a promise about physical reality. Two substance areas dominate the day-one obligations.
PFAS in Food-Contact Packaging (Article 5(5))
From 12 August 2026, food-contact packaging cannot be placed on the EU market if PFAS are present at or above these thresholds:
Measure | Limit | Basis |
|---|---|---|
Any individual PFAS (targeted analysis, excluding polymeric) | 25 ppb | Article 5(5)(a) |
Sum of PFAS (targeted analysis, excluding polymeric) | 250 ppb | Article 5(5)(b) |
Total PFAS including polymeric, measured as total fluorine | 50 ppm | Article 5(5)(c) |
The Commission's March 2026 guidance sets out a stepwise testing logic: screen total fluorine first, and if it stays below 50 ppm the material is treated as compliant without further testing. If total fluorine exceeds 50 ppm, the burden shifts to you to show the fluorine is not from restricted PFAS. Supplier word alone is not evidence. You need Certificates of Analysis from accredited laboratories, which is a supplier data collection problem more than a chemistry problem. Certivo's approach to PFAS compliance across multi-tier supply chains is built for exactly this evidence chain.
Heavy Metals and Substances of Concern
Article 5 also caps the combined concentration of lead, cadmium, mercury, and hexavalent chromium at 100 mg/kg across all packaging, and imposes a general duty to minimise substances of concern. Managing these thresholds against thousands of components is a classic BOM substance and threshold management task, closely related to the discipline your teams already apply for REACH and RoHS.
For a deeper treatment of the food-contact rules specifically, see Certivo's companion analysis, EU packaging PFAS ban 2026.
PPWR PFAS food contact limits under Article 5(5) for packaging compliance
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Who Carries the Obligation
Under PPWR, "manufacturer" is a legal role, not a factory. It is the entity that markets the packaging under its own name or trademark. For private-label goods, that is usually the brand owner, not the converter that physically produced the packaging.
Two provisions catch companies off guard:
Article 21 reclassification. An importer or distributor becomes the manufacturer, and inherits the full DoC obligation, when it places packaging on the market under its own name or trademark, or modifies packaging in a way that can affect compliance.
Importer duties (Article 18). Importers do not draw up the DoC. Their supplier does. But importers must hold a copy of the declaration per packaging type, verify the manufacturer completed conformity assessment, and ensure the technical documentation can be produced to market surveillance authorities on request.
Retention runs 5 years for single-use packaging and 10 years for reusable packaging. This is where multi-tier supply chain transparency and audit-ready documentation stop being nice-to-haves.
PPWR importer requirements and manufacturer roles for Declaration of Conformity
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Struggling to see who owns the DoC across your portfolio? Request a Compliance Review at https://www.certivo.com/contact
Why This Is a Data Problem, Not a Physical Problem
Here is the uncomfortable truth for large manufacturers. Most of your packaging probably already meets the physical limits. What you cannot do quickly is prove it.
Proving conformity per packaging type means collecting, for every format, verified substance test results, recycler and recycled-content certificates, and full material breakdowns from every supplier in the chain. A brand chasing hundreds of packaging suppliers by email, then reconciling PDFs in spreadsheets, will not assemble a defensible technical file for every SKU by August. The deadline is not a testing bottleneck. It is a supplier data collection and verification bottleneck.
This connects PPWR to the wider circular-economy stack. The same evidence base feeds Digital Product Passport and Extended Producer Responsibility obligations. Building it once, in a centralized compliance data backbone, avoids rebuilding it for every framework.
How Certivo Closes the Gap
Certivo functions as the system of record for packaging compliance. The supplier portal issues structured requests per packaging type, so suppliers submit test reports and declarations into a defined workflow instead of an inbox. CORA-powered regulatory intelligence then parses and validates those documents, extracting substance data, flagging missing Certificates of Analysis, checking values against the Article 5(5) PFAS thresholds and the 100 mg/kg heavy-metals limit, and mapping each result to the right packaging type and its bill of materials.
The output is continuous, audit-ready documentation. When a market surveillance inspection, a retailer audit, or a certification audit arrives, the technical file and DoC for a given packaging type are retrievable in hours, not weeks. CORA-driven compliance intelligence also monitors PPWR's later waves, including recyclability and recycled-content rules phasing in from 2030, so your regulatory intelligence and horizon scanning stays ahead of the next trigger date rather than reacting to it.
No platform makes you audit-proof. The realistic objective is audit-ready: fewer surprises and a far shorter response time when authorities ask for evidence with a clock running.
PPWR Compliance Checklist Before August 12, 2026
📌 Determine your PPWR role for each product line. Are you the manufacturer, importer under Article 18, or reclassified manufacturer under Article 21?
🔗 Map your packaging portfolio. List every format, material, and configuration. Each type needs its own declaration.
📊 Prioritise substance testing. Start with food-contact PFAS and heavy metals, the day-one limits with defined thresholds.
📄 Build the Annex VII technical file for each type, then draw up the Annex VIII declaration on top of it.
⚠️ Collect and verify supplier evidence, including accredited-lab Certificates of Analysis and recycled-content certificates.
⏳ Set retention and version control, 5 years single-use and 10 years reusable, with updates triggered by design or material changes.
🤖 Automate the collection and validation so the process scales across hundreds of suppliers without manual reconciliation.
Speak with a Compliance Specialist to pressure-test your PPWR readiness across products and jurisdictions: https://www.certivo.com/contact
Hariprasanth
Hariprasanth is a Chemical Compliance Specialist with nearly four years of experience, underpinned by a degree in Chemical Engineering. He brings in-depth expertise in global product compliance, working across key regulations such as REACH, RoHS, TSCA, Proposition 65, POPs, FMD, and PFCMRT.
Hariprasanth specializes in reviewing technical documentation, validating supplier inputs, and ensuring that products consistently meet regulatory standards. He works closely with cross-functional teams and suppliers to collect accurate material data and deliver clear, audit-ready compliance reports that stand up to scrutiny.