PPWR Declaration of Conformity Pack — EU Packaging Compliance Documents

What changed on 12 August 2026

The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, entered into force on 11 February 2025 and has applied across all EU Member States since 12 August 2026. It replaces the 1994 Packaging Directive. Because it is a regulation rather than a directive, it applies directly — there is no national transposition to wait for and no separate national version to interpret.

From that date, a manufacturer must carry out a conformity assessment, compile technical documentation and draw up an EU Declaration of Conformity before placing packaging on the market. There is no general exemption for small and medium-sized businesses, and no transition period for stock placed on the market after that date.

Most of what circulates online about PPWR describes obligations that start in 2028, 2029 and 2030 — recyclability grades, recycled-content minimums, harmonised sorting labels, the empty-space cap. Those are real, but they are not what binds you today. What binds you today is documentary.

What you actually need right now

Packaging already produced and held in stock before 12 August 2026 does not have to be destroyed, remanufactured or relabelled. The required information can be supplied in an accompanying document instead. New stock gets no such treatment.

Why this is harder than it looks

The document itself is short. Getting to the point where you can honestly sign it is not, and that is where most businesses stall.

• The data sits with your supplier, not with you. Under PPWR, packaging suppliers must give manufacturers the information needed to demonstrate compliance. In practice, asking a supplier for a substance declaration in the wrong format produces silence or a marketing PDF. The request has to name what you need.
• Your role determines your obligations. The same business can be a manufacturer for one product line and an importer for another. Getting the role wrong produces a document that says the wrong thing about who is responsible.
• PFAS is not just the film. For food-contact packaging the restriction is assessed on the packaging unit as a whole, inks, varnishes, glues and adhesives included. A component-by-component check is the only way to answer it honestly.
• Language is not optional. The declaration must be drawn up or translated into the language required by each Member State where the packaging is placed or made available.

How the pack works

1. You complete the intake form. Packaging format, components, suppliers, food contact, your role, the Member States you sell into. Ten minutes if you have the specs, longer if you need to ask a supplier.
2. We identify the gaps and tell you before we start. If a critical piece of supplier evidence is missing, you hear about it on day one, not on delivery day. You can add the supplier data chase at that point or fetch it yourself.
3. We prepare the documents. A Declaration of Conformity per packaging type plus the technical documentation file that stands behind it, structured so an inspector, an importer or a retailer can follow the reasoning.
4. You review, we revise, you sign. The declaration is signed by your legal entity, because the economic operator carries the legal responsibility. We do not sign it and cannot.
5. You keep the file. Technical documentation and traceability records have retention periods of five to ten years depending on the packaging type. We include a retention note so you know what to keep and for how long.

What this service is not

This is document preparation, not legal advice, and it is not a certification. Netalith is not a law firm and does not act as your authorised representative, your EU responsible person or your notified body. Nothing here guarantees an outcome with a market surveillance authority.

What it does give you is a complete, coherent, defensible set of documents built from your own product data — the thing you are supposed to have and probably do not. Penalties are set nationally and vary by Member State; several go into six figures, and authorities can restrict market access. If your packaging is already on the EU market without documentation, the fastest useful move is to build the file, not to wait and see whether anyone asks.

Start with one packaging type

If you are unsure how many packaging types you actually have, start with the one a customer, importer or marketplace has asked you about. Most businesses discover during that first pack that their thirty SKUs share four packaging types, not thirty — which is why the portfolio tier covers ten.