A PPWR declaration of conformity is drawn up for the entire packaging unit, not for each component. The European Commission states that for a unit made of bottle, closure and label, a single assessment and declaration suffices, with relevant information on all the separate components used. Under Article 6(9), a truly separate component, such as a fully removable lid, still gets its own recyclability assessment in that file.
Article 38 sets the conformity assessment procedure and Article 39 governs the EU declaration of conformity, with its content specified in Annex VIII and the supporting technical documentation in Annex VII.
Scope and language at a glance
| Question | Position |
|---|---|
| One declaration per component, or per unit | Per unit; a single assessment and declaration covers bottle, closure and label together |
| Must components appear in it | Yes; the declaration should carry relevant information on all separate components used to make up the unit |
| Language | Drawn up in, or translated into, one or more languages required by the Member State where the packaging is placed on or made available on the market |
| Do the Article 6 and Article 7 exemptions need assessing | Yes; compliance with them is assessed and included in the Annex VII technical documentation |
The unit-level answer appears in the Commission FAQ as updated material in the August 2026 edition. The language rule is not guidance but the article: Article 39(2) provides that the EU declaration of conformity shall be drawn up in, or translated into, one or more languages required by the Member State in which the packaging is placed on the market or made available on the market.
What that means for a multi-market shipment
Because the language obligation attaches to each Member State of placing or making available, a consignment distributed across several markets can require the same declaration in several languages. The Commission FAQ frames the purpose as enabling the respective market surveillance authority to verify the declaration on request.
Article 15(3) and Annex VII point 4 set the retention period: five years from the date single-use packaging was placed on the market, ten years for reusable packaging. Under Article 15(10), documents must reach a national authority within ten days of a request. Article 17(2) lets an authorised representative hold the file under a mandate.
Sources: Regulation (EU) 2025/40, PPWR Frequently Asked Questions, second edition
The definition of the instrument itself is covered in What is EU Declaration of Conformity?. Drafting one at unit level across a multi-supplier bill of materials, for the manufacturer to check and sign, is handled in EU PPWR solutions, with the surrounding duties in the PPWR compliance guide.