What is the EU Declaration of Conformity for packaging? And do you need it? (2026)

From 12 August 2026, every packaging item sold in the EU needs an EU Declaration of Conformity signed by the manufacturer.

This is the EU's new packaging law (PPWR) at work. The Declaration is a written statement that the packaging meets the new sustainability rules, backed by an evidence file kept for five or ten years.

There is no small-producer exemption. A local bakery and a global FMCG brand are on the same hook.

This is the practical guide. What the Declaration is, who has to produce it, what goes on it, and how to actually do it without turning compliance into a project that runs your calendar.

What the EU Declaration of Conformity actually is

The EU Declaration of Conformity for packaging (the Declaration, or the DoC) is a written document, signed by the manufacturer, that says your packaging meets the EU packaging rules. It is the piece of paper that says your packaging is legally allowed on the EU market.

It is new. The old EU packaging directive worked differently. Each country wrote its own version of the rules, and producers complied through national EPR registers, packaging waste reporting, and material restrictions.

The new regulation skips the national-translation step. The same rules apply in Berlin, Madrid, and Copenhagen on day one.

What the Declaration confirms is that the packaging meets the substantive parts of the new law. Those rules cover restrictions on substances of concern like PFAS and heavy metals, recyclability grades, minimum recycled content in plastic packaging from 2030, packaging minimisation, compostability where it applies, reusable packaging criteria, and harmonised labelling.

The Declaration does not have to be printed on the packaging. It stays with the manufacturer as a document.

What goes on the packaging is your contact information as the manufacturer? Name, registered trade name, postal address.

You can either print this directly, or expose it through a QR code or other data carrier.

A growing share of producers will use the QR for both purposes. The legally required contact info, plus a link to the live Declaration for anyone scanning it.

Why this is new

The old packaging directive did not require a Declaration. Compliance happened at the country level. Producers tracked the packaging they put on the market and the country handled recycling targets.

There was no EU-wide certification that each piece of packaging met the rules.

The new regulation pulls packaging into the same regime that already governs toys, medical devices, and most other regulated products. A written self-declaration, backed by evidence, available to regulators on request.

Packaging is now treated like a product, not a waste category. As a producer, you are in the same legal position as a toymaker or a medical device manufacturer, with the same paperwork.

Who has to draw up the Declaration

The Declaration is the manufacturer's duty. So who counts as the manufacturer? It depends on which side of the supply chain you sit on.

If you make the packaging yourself

You are the manufacturer. You produce a Declaration for every packaging type you sell on the EU market.

If you have packaging made under your own brand

You are still the manufacturer, even if a different company physically produces it. Brand ownership trumps physical production. If your name or trademark goes on the packaging, the Declaration duty sits with you.

If you import packaging from outside the EU

You are an importer. You do not produce the Declaration yourself. Your non-EU supplier does.

What you do is verify that the Declaration exists, that it is complete, and that it ties to the actual packaging you are importing. You keep a copy on file. If the supplier is outside the EU, they have to appoint an EU-based authorised representative who holds the Declaration and the evidence file for regulators to access.

If you modify the imported packaging in any way that affects how it complies, or you rebrand it under your own name, you become the manufacturer and inherit the full duties.

If you are a distributor

Lighter duty. Before you sell the packaging on, you check that it's correctly labelled, that the manufacturer or importer's contact information is on it, and that the producer is registered with the relevant EPR register in your country. You do not have to hold the Declaration yourself, and you do not have to verify it personally. That sits with the importer.

The carve-out for the smallest producers

The Declaration and the evidence file shift up the chain to your supplier. This shaves real work off the smallest producers, but it does not remove your responsibility entirely.

You still need to know who carries the duty in your supply chain, confirm that they actually have a Declaration in place for the packaging you put on the market under your brand, and be able to point to it if a regulator asks. The legal authorship sits with the supplier; the responsibility for knowing the paperwork exists stays with you.

The carve-out also requires the supplier to be aware of the duty and willing to carry it. A short conversation with your packaging supplier is worth having now, not in August.

What goes in the Declaration

The law sets a fixed template. The Declaration has to contain eight pieces of information, plus a signature block:

1. A unique identification number. Ties the Declaration to your internal records, like batch, SKU, or packaging spec ID. Each Declaration gets its own.

2. The manufacturer's name and address. Plus the authorised representative's details if you are non-EU.

3. A "sole responsibility" statement. The verbatim wording is "This declaration of conformity is issued under the sole responsibility of the manufacturer." This is what gives the Declaration its legal weight.

4. The object of the declaration. Identification and description of the specific packaging, traceable enough that someone holding the packaging in their hand can match it to this Declaration. Photo, drawing, model number, batch range, whatever it takes.

5. A statement of conformity referencing the relevant EU rules. The packaging regulation, plus any other EU law the packaging is subject to.

6. References to the standards or specifications used. Which industry standards or technical specs you followed to demonstrate each requirement.

7. Notified body details, if any were involved. Packaging uses self-assessment by default, so this field is usually blank. It exists for edge cases.

8. Any additional information. Free-text field for supplementary context.

Plus the signature block. Place and date of issue, name and function of the signatory, signature. Digital signatures are fine if they meet EU eIDAS standards.

Avoid generic declarations

The most common mistake is treating field 4 as a category statement. "All our cardboard boxes conform with the EU packaging regulation" is not a Declaration. The law requires identification that is traceable. Someone holding the packaging in their hand has to be able to match it to the document. One Declaration per packaging type, not one per producer.

This is where the QR code becomes useful. A QR on the physical packaging that resolves to the matching Declaration solves the traceability problem permanently. The scanner sees the link. The link resolves to the right document. No ambiguity.

What counts as a packaging type?

Anything with a materially different spec. Two packaging items that share design, material composition, and labelling are one type. Change one of those and it becomes a second type. Some practical examples:

• A bakery selling cakes and pastries might use a cardboard cake box, a paper bag for pastries, and a label sticker. Three types, three Declarations.

• A wine producer might use a glass bottle, a cork, a capsule, a shipping carton, and a label. Five types, five Declarations.

• A 250 ml and a 500 ml of the same bottle, same material, same design, just different size, is typically one type. The spec is functionally identical.

• A 500 ml clear PET bottle and a 500 ml green PET bottle is two types. Colour changes the recyclability spec, so the underlying compliance claim is different.

• The same cardboard box from two different suppliers is two types, unless the suppliers deliver to identical specifications and you can prove it.

Most producers underestimate the count by a wide margin. Walking the warehouse counting distinct packaging specs is usually a sobering exercise.

Drop this in right after the "Avoid generic declarations" paragraph, before the "This is where the QR code becomes useful" closer.

The evidence file behind the Declaration

The Declaration is a public statement. The evidence behind it is an internal file the manufacturer has to keep on hand. The Declaration does not exist on its own. A Declaration without underlying evidence is, in practice, false.

The evidence file has to contain:

• A general description of the packaging and its intended use.

• Design and production drawings, plus the materials of components.

• Descriptions and explanations needed to understand the drawings.

• A list of the industry standards and technical specifications used.

• A qualitative description of how you assessed recyclability, minimisation, and reusability.

• Test reports, where you used testing to demonstrate compliance.

The file has to exist before the packaging goes on the market. It has to be kept for 5 years from the date the packaging was first sold for single-use packaging, and 10 years for reusable packaging. The clock starts when the packaging first goes on the market, not when production ends. Friendlier than some early commentary implied.

Regulators can ask for the evidence file at any point during the retention period. The producer has to produce it, in the language of the requesting authority, within a reasonable period.

What this actually means for you, in practice

If you sell packaging in the EU, here is the punch list for 12 August 2026:

1. A list of every packaging type you sell. This is the unit of work. One Declaration per type, not per item.

2. For each type, an evidence file. The internal binder that backs the Declaration.

3. For each type, a signed EU Declaration of Conformity. Each backed by the underlying evidence.

4. Contact information accessible on the packaging. Either printed directly, or via a QR code or data carrier.

5. A process for keeping these up to date when packaging changes, like material, design, supplier, or manufacturing process. If compliance is affected, the evidence file and Declaration need a new version.

6. A retention plan. 5 or 10 years, depending on whether the packaging is single-use or reusable. Audit-ready, language-flexible, retrievable.

Existing EPR registration in national producer registers does not satisfy any of this. The new regulation adds a product-conformity layer on top of EPR. Two parallel obligations, one calendar.

The painful part

For a producer with three packaging types, the work is manageable. A weekend, maybe. For a producer with several hundred SKUs sold across multiple EU markets, with packaging that changes every time a supplier swaps materials or a new format rolls out, the work is real. Spreadsheets stop working at a certain scale. Email archives don't qualify as audit-ready documentation. And a generic compliance letter doesn't qualify as a Declaration.

The producers who get this right will not be the ones who hire a consultant to do it once. They will be the ones who put the data into a system that holds the spec, generates the Declaration, exposes the QR, and keeps the retention archive, so that the next packaging change is one update, not another project.

How Repax Declare handles this

Repax Declare is the part of the Repax platform built specifically for the EU Declaration of Conformity. It is designed for the producer who treats compliance as a property of knowing their products, not as a recurring engagement.

Four steps, end to end:

1. Pulls product specs from your data. Specs flow in from Repax Core or your own data source. Materials, recycled content, and the standards you applied are already mapped to the right fields. No re-entry.

2. Generates the Declaration. All eight required fields filled in for each packaging type. The "sole responsibility" wording is locked. PPWR Annex VIII coverage out of the box.

3. Signs and archives. Manufacturer signature applied. Each Declaration gets a unique reference number. Held in an audit-ready archive for at least ten years.

4. Shares downstream. Send as a PDF, a portal link, or pull via API. Each Declaration ships with a QR code ready to print on the packaging. The QR resolves to the live Declaration and doubles as the legally required contact info. Versioned automatically when packaging changes.

Declare is for the producer who would rather spend the next eighteen months building a business than building a compliance project. It is operator-grade software, not consultant-grade paperwork.

See how Declare works

Frequently asked questions

Does this apply to me if I only sell in one country?

Yes. The new regulation applies the same way in every EU country.

My packaging is transport packaging for my own products. Does it count?

Yes. Transport packaging is in scope. Your shipping boxes count.

Do I need to test the packaging myself?

Where you rely on industry standards and supplier declarations, often not. Where you make claims that aren't backed by standards or supplier evidence, you may need test reports as part of the evidence file.

What happens if the Declaration is missing?

Regulators can prohibit the packaging from being sold, require recall, or require corrective measures. False Declarations can carry administrative or, in some cases, criminal penalties under national law.

When does enforcement actually start?

The obligation starts 12 August 2026. Enforcement curves typically start with high-volume producers and visible categories, then expand. Acting before the deadline is cheaper than acting after.

What to do next

If you sell packaging in the EU, three steps make sense between now and August 2026:

1. List your packaging types. Each unique design, material spec, and use case is one Declaration. Most producers underestimate this count.

2. Talk to your packaging supplier. If you are a microenterprise and your supplier is in the same country, the duty may sit with them. Worth confirming.

3. Decide how you will produce and hold the Declarations. Spreadsheets work for two or three packaging types. Above that, you want a system.