Everything you need to know to meet PPWR requirements on 12 Aug 2026
- Renata Daudt
- 1 day ago
- 7 min read
Just four months to go!
If your products are sold in the EU or you're planning to enter the European market, there's a compliance deadline you cannot afford to ignore. The Packaging and Packaging Waste Regulation (PPWR) comes into effect on 12 August 2026, and one of its first mandatory requirements is the Declaration of Conformity (DoC).
At AWEN Packaging Consulting, we work with brand owners navigating packaging regulations across global markets, and right now, the DoC is the question we're hearing most. Many brands are either unaware of it entirely or assume their packaging supplier will handle it.
Spoiler: most of the time, that's not how it works.
This post breaks down exactly what the DoC is, who is responsible for it, what it must contain, and most importantly, what you should be doing right now to prepare.
What Is the PPWR Declaration of Conformity?
The Declaration of Conformity is a legally binding self-declaration that confirms a specific packaging type meets the sustainability requirements set out in the PPWR (Regulation (EU) 2025/40).
It sits under Article 39, follows the structure set out in Annex VIII, and covers compliance with Articles 5 - 12: minimisation, recyclability, recycled content, reuse, and restricted substances.
In plain terms: you are putting your name on a legal document that states that your packaging meets the EU requirements. That is not a light commitment, which is exactly why you need to start preparing now.
The DoC is mandatory for all packaging placed on the EU market from 12 August 2026 onwards, both B2C and B2B.
So Who Actually Has to Issue the Declaration of Conformity (DoC)?
This is where a lot of brands get tripped up, as it's honestly one of the most common misconceptions we come across.
There is a widespread assumption that the Declaration of Conformity (DoC) can simply be passed on to your packaging supplier, but it cannot. Suppliers need to be engaged, they hold essential technical information, but the legal obligation to issue the DoC belongs to the manufacturer as defined under PPWR.
Under Article 3(1)(13) and Article 21, the manufacturer is the entity that places packaging on the EU market under its own name or trademark. This is not necessarily the company that physically produced the packaging.
Here's a real-world example to make this concrete:
Company A produces the packaging but puts no brand on it → they are a supplier, not the manufacturer under PPWR
Company B adds its brand and places the product on the EU market → Company B is the manufacturer and signs the DoC
Your brand on the packaging = you are most likely the manufacturer under PPWR.
If the packaging or product carries your brand, you are responsible for conducting the packaging conformity assessment, establishing the DoC, and gathering the required technical documentation.
Diagram sourced from the PPWR Guidance Communication release on 30th March 2026. You can find the full document below.
Isn't the Manufacturer the Same as the Producer?
No, and this distinction matters a lot.
Under PPWR, the Manufacturer is responsible for compliance. They sign the DoC, maintain technical documentation, can be audited by market surveillance authorities, and must hold data that supports every claim in the declaration.
The Producer holds Extended Producer Responsibility (EPR) obligations. They register with national authorities, pay EPR fees, and report packaging volumes annually.
Mix them up, and you could find yourself with serious compliance gaps and a legal headache you really don't want.
What Does the Declaration of Conformity (DoC) Actually Contain?
One detail that catches a lot of brands off guard: the DoC is required per packaging type, meaning each format, material, and configuration needs its own declaration with its own supporting documentation. If you have 30 packaging formats, you need 30 DoCs.
To put that in perspective, a skincare brand selling a moisturiser in a glass jar with a plastic lid, a pump bottle, and a travel sachet needs three separate declarations. A food brand with a cardboard outer, a plastic inner tray, and a resealable pouch? Three more. The more complex your packaging portfolio, the more declarations you are managing and the more technical documentation sits behind each one.
The structure is defined in Annex VIII and requires six things:
# | Element | What it means |
1 | Unique identification number | Links to your internal systems and batch tracking |
2 | Manufacturer name and address | Or authorised representative if applicable |
3 | Sole responsibility statement | You are confirming your exclusive legal liability for every claim |
4 | Packaging identification | Type, material, batch or serial number |
5 | Conformity statement | Your declaration of compliance with Articles 5–12: minimisation, recyclability, recycled content, reuse, and substances |
6 | Signature, place, and date | By the manufacturer or authorised representative |
Beyond the DoC, brands have to build and maintain the technical documentation (Annex VII) that supports every statement, and that's where most brands are currently underprepared. Technical packaging knowledge is needed to interpret the documentation.
One more practical detail worth flagging early: the DoC must be available in a language that end users in the country where the packaging is placed on the market can easily understand. If you are selling across multiple EU countries, that has real implications for how you manage and store your declarations.
The Signature Is a Legal Commitment Here's What It Covers
When your authorised representative signs the DoC, they are taking full legal responsibility for every claim in that declaration.
Under Article 39(4), that signature is confirmation that:
Substance compliance: heavy metals, PFAS, and other restricted substances are within defined limits
Recycled content: the percentages you've stated are accurate and verifiable
Recyclability: your packaging meets the requirements of Article 6
Supporting documentation: the technical documentation per Annex VII exists and backs every claim
There are also document retention requirements attached to the DoC. Single-use packaging documentation must be kept for 5 years from the date of market placement and reusable packaging documentation must be kept for 10 years.
This is not a form you fill in and file away, it is an ongoing legal commitment with audit exposure.
Your 5-Step Action Plan to Get Declaration of Conformity (DoC)-Ready
The first PPWR requirements land in August 2026, and the DoC is one of them. If your team has not started on this yet, now is the time.
Here is how we recommend approaching it:
Step 1: Decide which department will own the DoC
Someone in your organisation needs to lead this. That department will likely coordinate the cross-functional team, establish the DoC framework, and manage technical documentation collection. Assigning a clear project leader early is often half the battle.
Step 2: Define what "packaging type" means in your context
The DoC is issued by packaging type, so before anything else, your team needs to align on how packaging types will be defined and categorised across your portfolio. This decision has significant downstream consequences; it determines how complex your compliance processes will be and how you link technical documentation over time.
Step 3: Map your full packaging portfolio
The DoC requirement applies to all packaging types, both B2C and B2B. List every format, every material, and every supplier. You cannot assess what you cannot see. Make sure you have full visibility across your entire packaging scope before moving forward.
Step 4: Conduct a documentation gap assessment
Perform an inventory of the information and technical documentation required for each DoC, referencing Annex VII and Annex VIII and map the gaps. Then assign each gap to the relevant internal function or supplier for collection. This gap assessment will tell you how much work is ahead and where the pressure points are.
Step 5: Assign a signatory and set up document retention
The person who signs the DoC assumes legal liability for its accuracy. Once the signatory is confirmed, set up your document retention processes: 5 years for single-use packaging, 10 years for reusable, from the market placement date.
A Note on What Is and Isn't Enforceable Right Now
One thing worth noting: substance compliance under Article 5 is enforceable from August 2026, with defined thresholds now in place for PFAS, heavy metals, and other restricted substances. This is where you should start building your technical documentation.
Recyclability and recycled content methodologies are still pending delegated acts, expected in 2028 and 2029. That means the DoC you issue in August 2026 will need to be updated as those methodologies are confirmed. Build that update process into your planning now rather than treating the first DoC as a one-and-done exercise.
The Hardest Part Is Not the Document
The hardest part of the DoC is not writing the declaration. It is getting the data that backs it up.
Substance test certificates for heavy metals and PFAS across every packaging component, from every supplier, across your entire portfolio, that is the real work. Suppliers vary enormously in how prepared they are to provide this information, how quickly they respond, and how usable the data they provide actually is.
This is where having a clear process and the right conversations with suppliers early makes an enormous difference. The brands that will struggle most in August 2026 are the ones that started those conversations in July.
If you are not sure where to start, or you want an honest assessment of where your business currently stands, we would love to hear from you. That is exactly the kind of work we do at AWEN Packaging Consulting, and we offer a free initial consultation to help you get your bearings.
One exception worth knowing about
If your business is a micro-enterprise, meaning fewer than 10 employees and an annual turnover or balance sheet under €2 million and your packaging supplier is located in the same EU country, the supplier becomes the manufacturer under PPWR instead of you. In that case, the DoC obligation shifts to them.
That said, if you are a micro-enterprise but your supplier is based in a different EU country, or outside the EU entirely, the obligation still sits with you. If you are unsure which side of this line your business falls on, it is worth getting clarity early rather than assuming the exemption applies.
More FAQs on the PPWR
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