PPWR · Article 39 · 12 Aug 2026
Audit-Ready EU Declarations of Conformity
From August 2026, anyone placing packaging on the EU market for the first time must issue a signed EU Declaration of Conformity.
Repax Declare
Declaration of Conformity
RPX-DOC-2026-04287
Manufacturer signature
Article
39
EU 2025/40
Article 39 · Personal liability
A real human signs every Declaration.
Every Declaration in Repax is signed by a named manufacturer representative under Article 39. Declare timestamps the signature, links it to evidence, and freezes the PDF.
Hand it to an auditor unchanged.
Even if you don't run a factory
manufacturer
noun/ˌmæn.jʊˈfæk.tʃər.ər/
The first company responsible for placing packaging on the EU market under its name or trademark. Not just the factory. Whoever crosses the EU border first.
PPWR · Article 3
at national scope: producer
Webshop
Mosaik Furniture
Imports furniture from China. Ships from a Polish warehouse to EU buyers.
Dropshipper
Vela Skincare
Skincare made in Vietnam. Drop-shipped direct to EU customers.
EU packaging maker
BioGlass
Glass shampoo bottle factory in Czech Republic. Sells empty bottles to cosmetics brands across the EU.
Private-label brand
Aurora Naturals
Berlin wellness brand. Contract lab in Italy makes the vitamins. Every bottle carries Aurora's logo.
All four owe a signed EU Declaration of Conformity.
Articles 5 to 12
Attest the articles that apply to your packaging
For every packaging type, read all eight articles and attest the ones that apply. Evidence sits in the Annex VII technical file under Article 38.
Substances
test reports, restricted list
Recyclable
DfR spec, recyclability class
Recycled content
supplier cert, % verified
Biobased feedstock
feedstock certificate
Annex VII · Module A
Technical File
Sealed by Article 38 · Declared by Article 39
Compostable
EN 13432 certificate
Minimisation
design rationale doc
Reusable
design spec, return system
Labelling
label artwork, instructions
PPWR · Annex VIII
The checklist behind every valid declaration
Five duties from Annex VIII and Article 39. Three ways to work through them. Only one leaves you audit-ready by design.
Generate unique IDs
DoC number + packaging ID · Art 15(5)
Without Declare
numbered by hand
Repax Declare
Auto-assigned. QR links to a public verification page.
Name who's liable
Manufacturer + sole-responsibility clause
Without Declare
a name in a Word file
Repax Declare
Named signer with function and date, timestamped.
Attest Articles 5 to 12
One verdict per article, per packaging type
Without Declare
8 articles × every SKU
Repax Declare
Guided checks. Not-applicable recorded with reasoning.
Link the evidence
Annex VII technical file behind every claim
Without Declare
scattered in inboxes
Repax Declare
Evidence vault. Every claim links to its document.
Freeze, version, retain
5 years single-use · 10 years reusable · Art 15(3)
Without Declare
nothing frozen for 10 years
Repax Declare
Frozen PDFs, versioned, retained the full term.
Passes the audit?
Without Declare
gaps surface in audit
Repax Declare
For auditors
Hand it over as-is.
Annex VIII requires every field. Declare enforces every field. Auditors stop calling.
Pricing
Free to evaluate. Plans scale with your catalogue.
A declaration is one active, signed DoC per packaging type. QR-verifiable, with the technical file behind it.
Free
One real declaration. End to end. Sign the DoC, generate the PDF, scan the QR.
See planGrowth
100 declarations. For small producers onboarding their first catalogue.
See planPro
500 declarations. Addons stack on top. Built for established portfolios.
See planAll prices monthly in EUR, ex-VAT
12 August 2026 is closer than it looks
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No card required for Free · Prices in EUR, ex-VAT