PPWR:
What It Is and What You Need to Know
to Be in Compliance

Overview

PPWR stands for the Packaging and Packaging Waste Regulation, an EU legislative framework (Regulation (EU) 2025/40) designed to make all packaging on the European market more sustainable and reduce packaging waste.

It entered into force on February 11, 2025, and generally began applying to businesses on August 12, 2026, replacing the older Packaging and Packaging Waste Directive. The Regulation:

  • Covers all packaging and packaging waste, regardless of material or origin
  • Sets requirements for manufacturing, composition, and the reusable or recoverable nature of all packaging placed on the EU market
  • Includes packaging waste management and prevention measures

Objectives

The rules aim to minimise packaging and waste, reduce the use of primary raw materials, and foster the transition to a circular, sustainable, and competitive economy.

The Regulation aims to:

  • Make all packaging on the EU market recyclable in an economically viable way by 2030.
  • Safely increase the use of recycled plastics in packaging.
  • Decrease the use of virgin materials in packaging and put the sector on track to climate neutrality by 2050.

Law

The PPWR establishes a new set of requirements in line with Europe’s waste rules that cover the entire packaging life cycle – from product design to waste handling, including:

  • Restrictions on certain single-use plastics, such as for individual portions or sachets of condiments and sauces.
  • A requirement for take-away businesses to offer customers the option to bring their own containers at no extra cost.
  • Minimising substances of concern, including restrictions on PFAS in food contact packaging if they exceed certain thresholds.

The PPWR followed the Packaging and Packaging Waste Directive 94/62/EC (PPWD), which was generally repealed on 12 August 2026. However, some provisions of the existing regulation will continue to apply even after that date.

Declaration of Conformity

What is a Declaration of Conformity?

An EU declaration of conformity  (DoC) is a mandatory legal document a manufacturer (or their authorised representative) must sign to declare that their products comply with all EU requirements.

The DoC is signed only after the manufacturer has complied with the legal requirements for their product, i.e., undertaken the relevant conformity assessment and compiled all supporting technical documentation.

By signing the DoC, the manufacturer takes full responsibility for the product’s compliance with applicable EU law.

Who is Responsible for the Declaration of Conformity?

Manufacturers are legally responsible for ensuring their product meets all EU requirements and for issuing the declaration of conformity — regardless of whether they are based inside or outside the EU.

You are considered the manufacturer if you make a product yourself, or have it made for you and sell it under your own name or brand. As a manufacturer, you may appoint an authorised representative based in the EU to carry out specific tasks on your behalf, such as:

  • cooperating with national market surveillance authorities
  • providing required documentation (e.g. the DoC and technical files)
  • supporting corrective actions if needed

This is especially important for non-EU manufacturers selling products in the EU.

If your product includes components from multiple suppliers, responsibility for the DoC depends on your role:

  • If you place the final product on the EU market, you must issue a DoC covering the entire product, even if individual components are already CE marked.
  • If you supply only a component, you are responsible only for that component’s compliance. A DoC may still be required for B2B or integration purposes.

What to Include in a Declaration of Conformity

The EU declaration of conformity must contain the following information:

  • your name and full business address or that of your authorised representative
  • the product’s serial number, model or type identification
  • a statement stating you take full responsibility
  • means of identification of product allowing traceability – this can include an image
  • the details of the notified body which carried out the conformity assessment procedure (if applicable)
  • the relevant legislation with which the product complies, as well as any harmonised standards or other means used to prove compliance
  • your name and signature
  • the date the declaration was issued.

Language and Translation Requirements

You must translate the EU declaration of conformity into the language or languages required by the EU country in which your product is sold. You must make it available to national market surveillance authorities upon request, although some EU product rules require the DoC to accompany the product (e.g., radio equipment).

Who Can Sign the Declaration of Conformity?

The declaration must be signed by someone with legal authority to represent the manufacturer or authorised representative:

  • Typically, a director, compliance officer, or senior manager
  • The signatory does not need to be an EU citizen or resident
  • Signing confirms that the product meets all relevant EU requirements

The declaration must include the signatory’s name, position, signature, and the date of issue.

Keeping the Declaration of Conformity Up to Date

The DoC must be reviewed and updated to reflect any changes, including:

  • product modifications (e.g. design, components, materials)
  • updates to applicable EU legislation or harmonised standards
  • changes to contact details of the manufacturer or authorised representative
  • switches in conformity assessment bodies or procedures

Link to summaries and white papers:

https://europa.eu/youreurope/business/product-rules-compliance/general-product-compliance/signing-declaration-conformity/index_en.htm#inline-nav-1

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=LEGISSUM%3A4806724

https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste/facts-about-new-eu-rules-packaging-and-packaging-waste_en

Key Compliance Documents

  • EU Declaration of Conformity (DoC): A legally binding statement signed by the manufacturer or importer confirming that a specific packaging type meets all PPWR rules. It includes a unique declaration number, manufacturer details, and conformity statements. [1]
  • Supporting Technical File: A comprehensive dossier kept alongside the DoC. It holds test reports, material specifications, recyclability assessments, and calculations proving compliance with substance limits (like PFAS) and empty-space reduction targets. [1, 2, 3, 4]
  • Supplier Declarations and Questionnaires: B2B documents collected upstream from packaging suppliers. These confirm raw material compliance, recycled content percentages, and the absence of restricted heavy metals or toxic chemicals. [1, 2]
  • Extended Producer Responsibility (EPR) Registrations: Administrative registry filings completed through national environmental authorities in every EU member state where packaged goods are sold. [1]

PPWR Compliance Product Solutions from AIC Plastics

AIC carries a wide range of products that are sustainable, returnable, and recyclable.

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