New rules on product conformity for packaging — effective 12 August 2026
On 12 August 2026, several new provisions of the Packaging and Packaging Waste Regulation (PPWR) will become applicable. One major change for businesses is the introduction of a conformity assessment procedure and the requirement to draw up an EU Declaration of Conformity. From 12 August 2026, businesses must ensure that their packaging has been subjected to a conformity assessment procedure following which the EU declaration of conformity has been drawn up. This requirement is entirely new and applies to all packaging.
The conformity assessment procedure must be carried out by the company considered the manufacturer under the PPWR. The procedure requires the compilation of technical documentation. The technical documentation must, inter alia, contain a general description of the packaging and its intended use, conceptual design and materials of components, a qualitative description of the assessment of certain PPWR requirements, as well as test reports.
Key facts at a glance
Upon confirmed conformity, an EU Declaration of Conformity may be drawn up using the format set out in Annex VII of the Regulation.
The declaration shall be drawn up for each kind packaging used and kept, together with the technical documentation for five or ten years, depending on whether it is single-use or reusable packaging.
By drawing the declaration, the company confirms compliance with the relevant requirements of the Regulation.
While functionally similar to a CE declaration, there is no requirement to affix a conformity label on the packaging; this distinction serves to avoid confusion with CE labelling that may apply to the packed product.
Manufacturer under the PPWR is the company that manufactures the packaging or the packaged product. Importers of packaging and packaged products may also be considered producers if they place the packaging or the packaged product on the market in the EU for the first time.
Recommendations for you:
Ascertain your legal role under the PPWR and the consequential obligations.
