PPWR declaration of conformity: who signs it and what goes in it

The EU declaration of conformity is drawn up and signed by the manufacturer of the packaging, under its own responsibility. Under PPWR, the manufacturer is the company that makes the packaging, or has it designed or made and sells it under its own name or brand, even if another brand is also visible on it.

For an online shop, that usually comes down to one question: whose name is on the box?

An authorised representative in the EU may draw up the declaration for a manufacturer, but the technical file and the legal responsibility stay with the manufacturer. Where you sell and how, decides the rest; for UK businesses, see PPWR for UK online sellers.

Yes. The regulation asks for a declaration for each packaging type, not for each product. For an online shop, the shipping box, the mailer and the product box are usually separate types, each with its own declaration and technical file. Which of your packaging can share a declaration is something we work out together in the assessment.

The declaration follows the model structure in Annex VIII of the regulation and is kept up to date: when the packaging changes, a new version is issued. Our example declaration contains:

• The declaration number and version
• The manufacturer’s name and address
• A statement that the declaration is issued under the sole responsibility of the manufacturer
• The object of the declaration: the packaging type and its identification code
• The statement that the packaging conforms to Regulation (EU) 2025/40
• Supporting documents: supplier declarations and test reports
• Place and date, the signatory’s name and job title, and the signature

UMUTCAN ONAYI: indirilebilir İngilizce beyan şablonu verecek miyiz (İngiltere’de ayda ~280 “template” araması; rakipler ücretsiz veriyor)

The technical file is what the declaration rests on. The manufacturer carries out the conformity assessment and prepares the file before the packaging goes on the EU market. In practice the file holds:

• A description of the packaging and its material composition
• Supplier declarations for each component
• A declaration or test report showing that lead, cadmium, mercury and hexavalent chromium together stay below 100 mg/kg
• For packaging in contact with food, PFAS evidence: 25 ppb for any single PFAS, 250 ppb for the sum of PFAS and 50 ppm for total fluorine
• The identification on the packaging (type, batch or serial number) and the manufacturer’s name and contact details, on the pack or in an accompanying document
• The record of the conformity assessment (internal production control)

The regulation requires your packaging suppliers to give you the information and documents you need to show conformity, and the European Commission’s guidance says they cannot refuse. A general “we comply” letter, or a blank template sent back unsigned, does not say which material, which values or which tests are behind it.

Your declaration needs signed and dated information for each component: the board, the film, the ink, the adhesive. This is usually the slowest part of the work, because the request has to travel down your supply chain.

If you make or sell boxes, mailers, film, ink or labels, your customers will ask you for the evidence behind their declarations. Most requests cover the same points:

• Material composition of what you supply
• A declaration or test report on the heavy-metal sum (below 100 mg/kg)
• PFAS evidence, if the packaging is in contact with food
• A safety data sheet where relevant, and a signed and dated statement

If your customer is a micro-enterprise in the same country as you and the packaging carries their brand, you may be its manufacturer, and the declaration is then yours to prepare.

In Evreka’s supplier view you enter this information once and answer every customer from it, in the format each one asks for. UMUTCAN ONAYI: tedarikçi erişimi ücretsiz mi; tedarikçi görünümü canlı mı

Usually not. Under the regulation, marketplaces and fulfilment partners have to collect your packaging EPR registration number for each country where your customers are, together with a self-certification that you meet your obligations there. A fulfilment partner that cannot get this confirmed has to suspend its service for those offers.

The registration number comes from an EPR service or compliance scheme in each country; Evreka does not register you or act as your authorised representative. The declaration and technical file are for your business customers and for the authorities. Which of these apply to you: 2-minute PPWR check.

With Evreka’s PPWR software you run every step in one place, from settling your role to sending the file to a customer.

PPWR is not the first EU regulation we build software for. Evreka has been building software for the waste and materials industry for twelve years, and our Wasteform product prepares the documents for cross-border waste shipments in the EU and works with DIWASS, the EU’s digital system under Regulation (EU) 2024/1157.