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Le PPWR en pratique

The EU declaration of conformity for packaging

One document per packaging type, signed by the manufacturer, saying on its sole responsibility that the packaging meets the PPWR. Article 39 and Annex VIII say what goes in it; the supplier's information is what it rests on.

Who signs it and when

The manufacturer draws up the declaration once the conformity assessment is done, before the packaging is placed on the market, and keeps it for 5 years, 10 for reusable packaging (Art. 39). It is one declaration per packaging type: a carton, a pallet, a strap and a stretch wrap each get their own. It is produced within 10 days when an authority asks.

Since 12 August 2026 the declaration covers the requirements that apply now: the heavy-metal limit, the PFAS limits for food-contact packaging, and the file behind them. Recyclability grades, recycled content and the harmonised label come in later years and are added as they apply.

What Annex VIII puts in it

  • a number that identifies the declaration
  • the name and address of the manufacturer, or of its authorised representative
  • the identification of the packaging the declaration is about, precisely enough to trace it: the type, the reference, and where useful a picture
  • the statement that the declaration is issued under the sole responsibility of the manufacturer
  • the statement that the packaging conforms to Regulation (EU) 2025/40, with the articles it is assessed against
  • the harmonised standards or common specifications applied, where any were
  • the place and date of issue, and the name, function and signature of the person signing for the manufacturer

The language is the one the market requires. Germany accepts German or English; a Polish customer will want Polish. The same packaging sold in both gets both.

What it rests on

A declaration is only as good as the file behind it, and the file is built from what the suppliers gave. The heavy-metal statement comes from the material maker's test report, the PFAS statement from the material maker or the coater, the composition from the data sheets. That is why every supplier owes the PPWR information under Art. 16, and why a manufacturer should refuse a supplier letter that names no reference and no report.

If you are a supplier, the PPWR information in Complizer is the piece your customer builds its declaration on. If you are the manufacturer, the same product keeps every maker's file next to the document made from it, so the file is there when the authority asks.