By the end of this guide you will have a signed EU Declaration of Conformity for one packaging type, with the evidence behind it ready for inspection. It is written for the person who has to produce the document, not decide policy.
This is the practical how-to. For what the declaration is and who it falls on, see the EU Declaration of Conformity overview. The declaration is the written statement, required under PPWR from 12 August 2026, that a packaging type meets the EU rules.
Before you start
You need three things in place:
- One defined packaging type. The declaration is per packaging type, not per company, so decide exactly which item you are declaring.
- Its specification. Materials, components, weight, and any supplier declarations for the inputs.
- The applicable requirements identified. Which of Articles 5 to 12 actually bite for this packaging (they vary by material).
The five steps
Each step maps to a duty in the regulation, and they run in order.
1. Confirm you are the manufacturer
The manufacturer draws up the declaration. That is you if you make the packaging, or have it made and sell it under your own name or trademark. If you import or distribute and you modify the packaging or rebrand it, Article 21 makes you the manufacturer too. Done when you know the duty is yours.
2. Assess the packaging
Check the packaging against the requirements in Articles 5 to 12 that apply to it, such as substances of concern, recyclability, recycled content from 2030, minimisation and labelling. This is a self-assessment, Module A, with no notified body or third-party certifier. Done when you can show how each applicable requirement is met.
3. Build the technical file
Assemble the Annex VII technical documentation, the evidence behind the declaration. It holds a general description, design and materials, the standards or specifications used, a qualitative description of the recyclability, minimisation and reuse assessments, and any test reports. Done when a market surveillance authority could follow it.
4. Fill the declaration fields
Draw up the declaration on the Annex VIII model, its 8 fields plus a signature block. That includes a unique identification number, your name and address, the fixed 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. Done when all 8 fields are complete.
5. Sign and keep the declaration
Sign it (an authorised signatory of the manufacturer, a digital signature is fine), date it, and provide it in the language of each market where you place the packaging. Keep it for 5 years for single-use packaging or 10 years for reusable, and put your manufacturer identification on the packaging by print or QR code. Done when it is signed, filed, and the packaging carries your identification.
The free template and why doing it by hand gets hard
You can do this by hand. The Annex VIII model, with all 8 fields ready to fill in, is a free download.
The catch is that filling it in by hand does not scale. The declaration is per packaging type, so a producer with dozens of packaging types fills the same fields over and over.
Every time the packaging changes, the declaration has to be re-issued, and every market it is sold into needs its own language.
Then there is the part the template does not show, and it is the one that hurts. Each declaration has to stay retrievable for 5 or 10 years, and the manufacturer identification on the packaging usually points to it through a QR code.
That QR has to resolve to a live declaration for the whole retention period. Host it yourself and let the page move or lapse, and the QR on every unit you already shipped is now dead.
So you end up running and paying for hosting, versioning and a retention archive for up to a decade, per declaration. That is what turns a one-page document into an ongoing operations problem.
How Repax Declare handles all of it
You enter a packaging type once. Declare confirms which Annex VIII articles apply, fills the 8 fields, and signs and versions the declaration.
It then hosts the public declaration page that the QR code points to, keeps it live for the full retention period, and tracks the views and downloads on it.
The hosting, the QR staying alive, and the 5 or 10 year archive are all handled for you, the part that is otherwise the most bother.
What takes an afternoon per type by hand, plus a decade of hosting to worry about, becomes a few minutes and nothing to maintain. For the full walkthrough, the guide covers it end to end.
No tool makes you compliant. Compliance is the manufacturer's responsibility under Article 15, and the packaging still has to meet Articles 5 to 12. What Declare does is make the declaration correct, hosted, traceable and audit-ready, at any scale.
Common mistakes to avoid
- A generic declaration. "All our packaging is compliant" is not a declaration. 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. The declaration has to be in the language of each member state where the packaging is placed on the market.
- A QR that rots. If the QR points at a page that later returns an error, it is the same as having no QR.
How to create an EU Declaration of Conformity questions answered
Do I need a notified body or certifier?
No. PPWR uses Module A, internal production control, which is self-assessment. There is no notified body and no CE-style mark for packaging.
Can I use one declaration for all my packaging?
No. The declaration is per packaging type. A specific design and material specification is one declaration; a genuinely different packaging type is another.
Who signs the declaration?
An authorised signatory of the manufacturer, with their name and function on the document. A digital signature is fine where it meets eIDAS requirements.
What language does it have to be in?
The language required by each member state where the packaging is placed on the market. For pan-EU packaging that usually means a multilingual declaration or a set of translations.
How long do I keep it?
5 years for single-use packaging and 10 years for reusable packaging, counted from the date the packaging was placed on the market.
The full regulation is on EUR-Lex, and the European Commission keeps an overview on its packaging waste pages.
