PPWR declaration of conformity: what to collect from your packaging suppliers

What the declaration of conformity is

A declaration of conformity is the packaging manufacturer's written statement, under PPWR Article 39, that a given packaging meets the regulation's substantive requirements, the ones in Articles 5 to 12 covering things like recyclability, recycled content, and minimisation. Behind it sits technical documentation (Annex VII) that shows how the packaging was assessed, and the declaration itself follows a set structure (Annex VIII). It is a self-declaration, in the same family as the CE-style conformity statements used elsewhere in EU product law, not a certificate issued by an outside body.

The point of it is traceability. When packaging moves from a maker to a seller to a consumer, the declaration is the paper that says someone assessed it against the rules, and it can be produced if a market-surveillance authority asks. Placing packaging on the EU market without one in the chain is not allowed from 12 August 2026.

Who writes it, and whether you have to keep a copy

The manufacturer of the packaging draws up the declaration and holds the technical documentation. Whether the duty to keep a copy then reaches you is where most write-ups overreach, and it depends on what you actually do with the packaging:

• You buy generic mailers and boxes from an EU supplier and use them to ship. You are a downstream user, not the party placing that packaging on the EU market, so the manufacturer and importer duties sit with your supplier and its maker, not with you. Asking for the declaration is good practice, not a retention duty you carry.
• You import packaging from outside the EU yourself. Now you are the importer, and you have to hold the declaration and keep it available for market-surveillance authorities.
• You have packaging custom-made or branded to your own specification. Depending on the arrangement you can step into a manufacturer's shoes for that packaging, with the fuller set of duties.

How long it has to be kept

Where the retention duty is yours, typically because you import the packaging, keep the declaration and its supporting documentation for five years from when the packaging is placed on the market for single-use packaging, and ten years for reusable packaging. In practice that means filing the declaration somewhere durable and versioned, because a packaging spec that changes mid-year can mean a new declaration, and you want to know which one covered which shipments.

What applies now, and what still phases in

This is where it pays to be precise, because PPWR does not switch on all at once. The declaration-of-conformity obligation applies from 12 August 2026. Some of the substantive packaging requirements it points at already apply, but several phase in later: the recyclability grades, the minimum recycled-content levels for plastic packaging and the harmonised sorting label run through 2028 to 2030. So what a declaration has to demonstrate grows over time, even though the obligation to have one exists now.

What to collect from each supplier

Whether or not the retention duty is legally yours, collecting the declaration is the cheapest way to know the packaging you rely on is compliant, and it is essential if you import your packaging. Turn it into a short, repeatable request to every company that supplies packaging you ship in. For each packaging item you use:

1. The EU declaration of conformity for that packaging, in writing, naming the manufacturer and the packaging it covers.
2. Confirmation of which requirements it covers, so you know whether it already reflects the requirements that phase in later or only those in force now.
3. A point of contact at the supplier for updated declarations, because you will need new ones as specs and rules change.
4. A durable, versioned copy in your own records, kept for five years for single-use packaging or ten for reusable, and linked to the period it applied to.

How this sits next to EPR registration

It is easy to fold this into EPR, but they are different obligations that happen to share the word packaging. The declaration of conformity is about the packaging's design: is it recyclable, does it meet the material rules. EPR registration is about paying for its end of life: registering as a producer and funding collection and recycling, country by country. You can owe both at the same time, and clearing one does nothing for the other. On the EPR side, non-EU sellers also have the separate question of whether they need a packaging authorised representative in the countries they ship to.

How Assuro helps

Assuro connects to your Shopify store and shows where you actually have packaging in scope: which products ship into which of its six supported countries, and where a packaging EPR registration is missing. That tells you which suppliers and which packaging matter enough to chase a declaration for, so the document work starts from your real catalogue rather than a guess. Assuro organizes and flags. It does not assess your packaging, write or check a declaration of conformity, or certify that anything meets PPWR. The declaration stays your supplier's document and the retention stays your responsibility.

• List every company that supplies packaging you ship in: mailers, boxes, void fill, tape, inserts
• Request the EU declaration of conformity for each packaging item, in writing
• Record which requirements each declaration covers, and which are still to phase in
• If you import the packaging yourself, store a durable, versioned copy: five years for single-use packaging, ten for reusable
• Re-request updated declarations as later PPWR requirements start to apply
• Treat a supplier who cannot provide one as a sourcing risk to resolve now