New EU Declaration of Conformity for Packaging: Key Changes and Responsibilities

The EU’s Packaging and Packaging Waste Regulation (PPWR), effective since August 12, 2026, introduces a new Declaration of Conformity (DoC) specifically for packaging. This regulation shifts compliance responsibilities to the pre-market phase, requiring manufacturers to ensure their packaging meets stringent criteria regarding chemical restrictions, recyclability, and labelling before products reach consumers.

Under the PPWR, the term ‘manufacturer’ refers to the entity whose name appears on the packaging, not necessarily the producer. This means brands must take responsibility for compliance, supported by a technical file that validates their DoC. The technical file must include supplier declarations, test reports, and documentation confirming adherence to chemical limits, particularly for substances like PFAS and heavy metals.

The DoC must detail the packaging type, manufacturer identity, specific compliance requirements, and reference the supporting technical file. It is crucial for manufacturers to maintain accurate documentation as market surveillance authorities may request it.

For non-EU manufacturers, appointing an Authorised Representative within the EU is essential for compliance. This representative acts as a contact point for authorities but does not assume legal responsibility for compliance, which remains with the manufacturer.

The PPWR also outlines distinct obligations for different roles within the supply chain, including importers and distributors, emphasizing the need for clear communication and data sharing among all parties involved.

As the regulation continues to evolve, brands are encouraged to proactively engage with their suppliers to ensure compliance and avoid potential penalties, including product recalls or fines. The PPWR’s requirements extend across all packaging materials, reinforcing the EU’s commitment to sustainability and food safety.