Short answer: When the applicable conformity assessment demonstrates compliance, the manufacturer draws up an EU Declaration of Conformity under Article 39. The declaration follows the model structure in Annex VIII and links a defined packaging type to the applicable PPWR requirements.
What the declaration does
It records the manufacturer’s responsibility for the conformity of identified packaging. It should be supported by the technical documentation required by Article 15 and Annex VII. A material certificate, food-contact declaration or supplier statement can support the assessment, but none of them automatically replaces the PPWR declaration.
Core declaration fields
- Declaration and packaging identification.
- Name and address of the manufacturer and, where applicable, its authorised representative.
- A statement that the declaration is issued under the manufacturer’s sole responsibility.
- Description sufficient to identify the packaging.
- The relevant Union legislation and applicable harmonised standards or common specifications.
- Notified-body information where applicable.
- Place, date, name, function and signature.
Who should sign?
The signatory must be authorised to sign for the manufacturer. The signature is an organisational control, not a substitute for technical review. Before signing, verify that the final packaging identifier and the applicable-requirements conclusions agree with the released technical file.
Frequent weaknesses
- The declaration covers a product family but does not identify the packaging variants.
- The supplier is named although the brand owner is the PPWR manufacturer.
- Standards and legal references are copied without an applicability assessment.
- The declaration is current but its evidence relates to a previous material or supplier.
- No change-control process links design changes to declaration review.
Retention
Article 15 requires the manufacturer to retain the technical documentation and declaration for five years for single-use packaging and ten years for reusable packaging, calculated from the date the packaging was placed on the market.