Is there a PPWR certificate, and who issues it?

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Team GreenSutra Staff answered on
PPWR conformity without a certificate: an engineer measures a carton beside a bottle, a pouch and a binder of technical files

No: the Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, has no certificate, and no authority, laboratory or notified body issues one. The manufacturer runs the Annex VII internal production control procedure itself or has it run on its behalf. It keeps the technical documentation and signs an EU declaration of conformity on its sole responsibility.

Diagram, No PPWR certificate: what proves conformity. Does not exist; A PPWR certificate; A notified body step; CE marking for packaging; What proves conformity; Annex VII internal production control; Technical documentation with test reports; EU declaration of conformity signed by the manufacturer; On request, the manufacturer has 10 days to hand the file to the authority; Articles 15, 38 and 39, Regulation (EU) 2025/40
What proves PPWR conformity in place of a certificate

What proves PPWR conformity instead?

Every packaging conformity assessment uses one procedure, Module A internal production control, set out in Annex VII and required by Article 38. Under it, the manufacturer “ensures and declares on his sole responsibility” that the packaging meets Articles 5 to 12. A laboratory or someone else may carry out the procedure on the manufacturer’s behalf under Article 15(2), but the manufacturer stays responsible. An authorised representative may hold the file for the authorities, but Article 17(2) keeps drawing it up out of the representative’s mandate.

The evidence is two documents. The first is the Annex VII technical documentation, which lists test reports among its elements. The second is the EU declaration of conformity, drawn up for each packaging type. A national authority can ask for both, and the manufacturer has 10 days to provide them under Article 15(10).

Where do test reports and other certificates fit?

Test reports go into the technical documentation. Test methods that follow harmonised standards cited in the Official Journal get a presumption under Article 36(2) when accredited bodies perform them. The PPWR does not require accreditation. The Commission’s FAQ says older harmonised standards now serve only as guidance and give no presumption of conformity, apart from the minimisation standard until the end of 2029. Its guidance says the same of compostability certificates.

For food-contact packaging, Article 5(5) obliges upstream suppliers to provide fluorine test proof on request where total fluorine exceeds 50 mg/kg. That proof also belongs in the file, as the PFAS answer explains.

Is there CE marking or a notified body?

No. Recital 109 says CE marking on packaging should not indicate PPWR compliance, only compliance of the packaged product with its own law. The PPWR procedure has no notified-body step. Line 7 of the Annex VIII model declaration opens with “Where applicable” before it mentions a notified body.

What can a buyer be given instead?

No article obliges a manufacturer to hand its file to a commercial customer. The duty runs the other way for suppliers. A supplier of packaging or packaging material must give the manufacturer what it needs to show conformity, including the Annex VII technical documentation, under Article 16(1). The importer must make sure the assessment was carried out and keep a copy of the declaration, under Article 18. A buyer that asks for a “PPWR certificate” can be offered the signed declaration, with test reports for specific claims. A missing or incorrect declaration is formal non-compliance under Article 62, and if it persists the packaging can be withdrawn or recalled.

Sources: Regulation (EU) 2025/40 (PPWR), Commission guidance document, C/2026/3084, PPWR Frequently Asked Questions, 2nd edition

GreenSutra’s PPWR consulting helps a manufacturer assemble the technical file and draft the declaration it signs, while testing stays with the laboratory it appoints. The EU PPWR guide sets out the file step by step.