Most Declarations of Conformity that fail a check fail on the same few things, a missing technical file, the wrong language, a QR that has gone dead. This checklist is the nine items a valid DoC needs, plus the five places people slip. Work down it and you have one that holds up.
The Declaration of Conformity is the signed statement, required under PPWR from 12 August 2026, that a packaging type meets the EU rules.
This EU Declaration of Conformity checklist runs through all nine items, then the mistakes that catch people out. For the full walkthrough of each step, see how to create an EU Declaration of Conformity.
The nine items
Every item, with the article or annex it comes from.
| # | What you need | Where it comes from |
|---|---|---|
| 1 | Confirm you are the manufacturer | Articles 15 and 21 |
| 2 | Define the packaging type | Article 39 |
| 3 | Assess it against Articles 5 to 12 | Articles 5 to 12 |
| 4 | Build the Annex VII technical file | Annex VII |
| 5 | Fill the 8 Annex VIII fields | Annex VIII |
| 6 | Sign and date it | Annex VIII |
| 7 | Provide it in each market's language | Article 39 |
| 8 | Put your identification on the packaging | Article 15 |
| 9 | Keep it for 5 or 10 years | Article 15 |
Work through each item
Each item in the order you tackle it, grouped into before you draw the declaration up, while you write it, and after you issue it.
1. Confirm you are the manufacturer
The manufacturer draws up the DoC. That is you if you make the packaging, or have it made and sell it under your own name or trademark. If you import, rebrand or modify it, Article 21 makes you the manufacturer too.
2. Define the packaging type
One DoC covers one packaging type, not your whole company, so pin down exactly which item you are declaring before anything else. A different design or material is a different type.
3. Assess the packaging against Articles 5 to 12
A Module A self-assessment with no notified body, covering substances of concern, recyclability, recycled content from 2030, minimisation and labelling as they apply to your packaging.
4. Build the Annex VII technical documentation
The evidence behind the declaration. It holds a general description, the materials, the standards used, and the recyclability, minimisation and reuse assessments, so a market surveillance authority could follow your reasoning.
5. Fill the 8 Annex VIII fields
The Annex VIII model has eight fields plus a signature block, a unique identification number, your name and address, the sole-responsibility statement, a traceable identification of the packaging, the conformity statement, the standards used, notified body details (usually left blank), and any additional information.
6. Sign and date it
An authorised signatory of the manufacturer signs and dates the declaration. A digital signature is fine where it meets eIDAS requirements.
7. Provide it in each market's language
The DoC has to be in the language required by every member state where you place the packaging, so pan-EU packaging usually means a multilingual declaration or a set of translations.
8. Put your manufacturer identification on the packaging
Your identification goes on the packaging itself, by print or a QR code that resolves to the declaration, so the document can be traced back to the item.
9. Keep it for 5 or 10 years
Retain the signed declaration for 5 years for single-use packaging and 10 years for reusable, counted from the date the packaging was placed on the market.
Where declarations slip
A declaration can tick every box above and still fail on one of these five. They are the difference between a DoC that holds up and one that does not, so check them last.
- A generic letter. "All our packaging is compliant" is not a DoC. Annex VIII requires the packaging to be identified so it can be traced to the document.
- No technical file behind it. A signed declaration with no Annex VII evidence is empty, and market surveillance can ask for that evidence.
- The wrong language. A DoC in English only, placed on a market that requires its own language, does not count there.
- A QR that rots. If the code points at a page that later returns an error, it is the same as having no identification.
- One DoC for the whole range. The declaration is per packaging type, so a genuinely different type needs its own.
How Repax Declare handles the manual parts
Repax is an EPR compliance platform for producers, and Declare is the product built for the EU Declaration of Conformity.
Most of the load in this checklist is items 5 to 9, and it is exactly where the five slips happen.
Declare takes a packaging type you have defined once, fills the 8 Annex VIII fields, signs and versions the declaration, generates the QR code, hosts the public page it resolves to so it cannot rot, and tracks the 5 or 10 year retention for you.
It does not do the Article 5 to 12 assessment for you, and no tool makes you compliant, that stays the manufacturer's responsibility under Article 15. What Declare removes is the paperwork and the decade of hosting.
You can also start from the blank Annex VIII template and fill it by hand.
EU Declaration of Conformity checklist questions answered
The questions that come up most often when people work through this list.
Do I need a Declaration of Conformity for every packaging type?
Yes. The DoC is per packaging type, not per company. A specific design and material specification is one declaration, and a genuinely different packaging type is another.
Do I need a notified body to sign off my DoC?
No. PPWR uses Module A, internal production control, which is a self-assessment. There is no notified body and no CE-style mark for packaging.
How long do I have to keep the Declaration of Conformity?
5 years for single-use packaging and 10 years for reusable packaging, counted from the date the packaging was placed on the market.
When does the DoC become mandatory?
From 12 August 2026, when PPWR applies. There is no official fill-in template and no grace period.
Can I use one Declaration of Conformity for my whole range?
No. A generic letter covering all your packaging is not valid, because Annex VIII requires the packaging to be identified so it can be traced to the document.
The regulation itself is on EUR-Lex, and the European Commission keeps an overview on its packaging waste pages.
