Under the Packaging and Packaging Waste Regulation (PPWR), the EU declaration of conformity follows the Annex VIII model: eight numbered items and a signature block. It states that the requirements of Articles 5 to 12 have been demonstrated. The manufacturer draws one up for each packaging type, keeps it current and holds it for 5 years, or 10 years for reusable packaging.
What goes in each item of the Annex VIII model?
| Item | What it holds |
|---|---|
| Number | The declaration’s own identification number |
| 1 | Unique identification of the packaging |
| 2 | Name and address of the manufacturer and, where applicable, its authorised representative |
| 3 | “This declaration of conformity is issued under the sole responsibility of the manufacturer.” |
| 4 | Object of the declaration: identification of the packaging allowing traceability, and a description |
| 5 | A statement of conformity with the relevant Union harmonisation legislation, with references to other Union acts applied |
| 6 | Harmonised standards, common specifications or other technical specifications used |
| 7 | Where applicable, the notified body, its intervention and any certificate |
| 8 | Additional information |
| Signature | “Signed for and on behalf of”, place and date of issue, name, function and signature |
The Commission’s FAQ reads item 1 as identifying the packaging by type, batch or serial number. Item 7 has nothing to report under the PPWR’s own procedure, which has no notified-body step, as the PPWR certificate answer explains.
What does Article 39 add?
The declaration covers Articles 5 to 12 only. The empty-space ratio, the Annex V format restrictions and the reuse targets are separate duties that it does not state. It must be “continuously updated”, and a design change or new standard that could affect conformity triggers a re-assessment under Article 15(4).
Where the packaging or the packaged product falls under more than one Union act that requires a declaration, Article 39(3) calls for a single declaration “where appropriate”. It names each act and its publication reference, and may be a dossier of the individual declarations. The FAQ adds that it must clearly separate the packaging from the packaged product.
How many declarations, and for how long?
A declaration is needed “for each packaging type”, under Annex VII point 4. It stays with the technical documentation for 5 years after single-use packaging is placed on the market, and 10 years after reusable packaging is. The importer keeps a copy for the same periods. The FAQ lets bottles of different sizes holding the same product share one declaration if size affects none of the Article 5 to 12 requirements. Pallets, pallet collars, wrap and straps each need their own, as the transport packaging answer sets out.
Whether one declaration covers a bottle, its cap and its label together, and which language it uses, is answered in declaration scope per component or packaging unit.
Sources: Regulation (EU) 2025/40 (PPWR), PPWR Frequently Asked Questions, 2nd edition, Commission guidance document, C/2026/3084
Where the declaration sits in the technical file is shown in the EU PPWR guide. GreenSutra’s EU PPWR solutions work from that file to a draft for the manufacturer to check and sign.