Manufacturer of packaging
Before placing packaging on the market: evaluate conformity, compile the technical file and issue an EU declaration of conformity for the packaging type where required.
BuVNK · EU packaging rules · Updated 13 October 2026
PPWR compliance: technical documentation and EU declaration of conformity
How businesses organise evidence for packaging: understand the technical file, conformity assessment, declaration of conformity and the different responsibilities of manufacturers, importers and distributors.
Articles 15–19Annexes VII & VIIIConformity assessment5 or 10 years
Already relevant in 2026: Regulation (EU) 2025/40 generally applies from 12 August 2026. Under Articles 15 and 38–39, the manufacturer must assess the packaging against the requirements applicable to it and prepare the appropriate documentation before placing it on the market. Some substantive design and labelling rules have later start dates; do not treat those future duties as already fully applicable.
01 / RolesArticle 15 Article 16 Article 18 Article 19 / EPR
Which business has which PPWR responsibility?
PPWR uses different concepts for the packaging manufacturer (conformity) and the producer responsible for extended producer responsibility (EPR). One business may hold more than one role.
Supplier of packaging or materials
Provide the manufacturer with the relevant material, test and technical information necessary to demonstrate conformity.
Importer
Check that the manufacturer completed conformity assessment and technical documentation, retain the declaration and make supporting documentation available to authorities.
Distributor / producer obligations
Distributors have due-diligence checks; EPR registration, financing and reporting concern the separate producer role and applicable national implementation.
02 / Technical file01 02 03 04 05 06
What goes into the technical documentation?
Annex VII (Module A: internal production control) describes the technical file. Its concrete contents depend on the packaging type and the PPWR requirements already applicable.
Packaging ID and intended use
Clear description of the packaging and intended use; a traceable identifier for the packaging type.
Design and material information
Drawings and specifications of relevant components, materials, coatings and structures, as applicable.
Applicable legal requirements
Record which requirements under Articles 5–12 apply and from what date; distinguish future criteria and exemptions.
Tests, calculations and risk assessment
Test reports and other evidence, relevant methods or standards, and analysis of potential non-conformity.
Supplier evidence
Material declarations, supplier specifications and other documents needed to substantiate conformity.
Production and change control
Internal procedures to ensure repeat production corresponds to the assessed packaging; re-evaluate after relevant changes.
03 / ConformityAnnex VIII 5 years 10 years 10 days
EU declaration, time limits and authority requests
The EU declaration of conformity is based on Article 39 and the model in Annex VIII. The technical file and declaration are separate but linked elements.
EU declaration of conformity
Identify the packaging and responsible manufacturer; state conformity with applicable EU legislation, including appropriate references and signature information.
Single-use packaging
Manufacturers retain the technical file and declaration for five years after placing the packaging on the market.
Reusable packaging
The corresponding retention period is ten years after placing the packaging on the market.
Requests from authorities
On a reasoned request, manufacturers and importers must provide relevant conformity documents within ten days; observe language and format requirements.
04 / Implementation01 02 03 04 05 06 07
Seven practical steps for compliance teams
A useful internal workflow — not a substitute for a packaging-specific legal assessment or conformity evidence.
Assign roles
Map manufacturer, supplier, importer, distributor and EPR-producer roles for each distribution chain.
Identify packaging types
Create traceable package IDs, intended uses and a materials/components inventory.
Create an applicability matrix
Link Articles 5–12 to packaging formats, effective dates, exemptions and delegated/implementing acts.
Request supplier evidence
Collect current specifications, material declarations, test reports and responsible contacts.
Compile technical files
Document assessments, evidence and applicable specifications for every relevant packaging type.
Issue and control declarations
Complete the Annex VIII template when conditions are met and track versions, approvals and changes.
Prepare for enquiries
Set up protected access, retention and rapid document retrieval for competent authorities.
06 / Legal sources
Primary legal sources
Consult the legal text for binding requirements. The national packaging register provides practical role information but is not responsible for reviewing declarations of conformity.
Regulation (EU) 2025/40 ↗Articles 15–19, 38–39 and Annexes VII/VIIIEuropean Commission guidance (2026) ↗Interpretative guidance for PPWR implementationCentral Agency Packaging Register ↗Roles and obligations under PPWR and German implementationCommission PPWR FAQ ↗Official implementation questions and answers
07 / FAQ
Frequently asked questions
Is a certificate from an external testing body mandatory for every packaging type?
No, not generally. Annex VII prescribes internal production control (Module A). Manufacturers remain responsible for conformity and adequate evidence; specialist test reports may still be needed in individual cases.
Are technical files and the EU declaration the same document?
No. The technical file under Annex VII supports the conformity assessment. The EU declaration under Article 39 and Annex VIII is the manufacturer’s formal declaration.
Must every PPWR rule already be demonstrated in full in 2026?
No. Apply the requirements that are legally applicable to the packaging at the relevant time; later requirements and follow-on EU acts must be monitored.
Does LUCID registration replace conformity documentation?
No. EPR registration and conformity assessment are different legal duties. One company may need to address both.
BuVNK · Independent information
Questions about PPWR documentation and evidence?
BuVNK explains regulatory requirements and supports professional exchange. Packaging-specific legal advice and independent assessments should be sought from qualified professionals.