GuidelinesRegulatory updates2026.11.05
PPWR EU Declaration of Conformity (DoC) — How It Differs from a Supplier Confirmation, the Annex VIII Item Table and a Pre-Drafting Checklist
When an EU customer asks for a PPWR DoC, some companies send a supplier's material confirmation instead. The two documents differ in who drafts them and who is responsible. This guide separates in a comparison table what supplier documents, the Annex VII technical documentation and the EU declaration of conformity under Article 39 each do, and sets out the Annex VIII item table for the declaration, a pre-drafting checklist, the retention and updating provisions and the importer's duty to keep a copy.
Key takeaway — The three documents in one line: supplier documents are the evidence, the technical documentation is the assessment record, and the EU declaration of conformity is the conclusion for which the manufacturer takes responsibility. Before filling in the declaration form, confirm first that the packaging and the applicable requirements have been identified, that the assessment evidence is in the technical documentation, and that the supplier documents match the current specification.
This article is based on Regulation (EU) 2025/40 (PPWR) and Commission Notice C/2026/3084 (implementation guidance), as checked on 6 October 2026. Who is responsible for the declaration is covered in PPWR responsible operators and internal role allocation, and how to collect the supporting evidence in packaging specification sheet and supplier document requests.
Comparison of the roles of the three documents
| Aspect | Supplier documents | Technical documentation | EU declaration of conformity |
|---|---|---|---|
| Legal basis | Article 16(1), (2) | Article 15(2), Annex VII point 2 | Article 39, Annex VIII |
| Drawn up by | Supplier | Manufacturer (the assessment may be entrusted to others) | Manufacturer or authorised representative; responsibility rests with the manufacturer |
| Content | Information and documents needed to demonstrate compliance, such as material, composition and tests | Applicable requirements, design, manufacturing and assessment evidence, analysis and assessment of the risk of non-conformity | Statement that fulfilment of the requirements in Articles 5 to 12 has been demonstrated |
| Subject | Packaging materials and components supplied | Packaging type | Packaging type (Annex VII point 4: drawn up for each packaging type) |
| Retention | Incorporated by the manufacturer into the technical documentation | 5 years single-use, 10 years reusable (Article 15(3)) | Same period, together with the technical documentation (Article 15(3), Annex VII point 4) |
| Importer's role | Verify before placing on the market that the manufacturer has drawn up the technical documentation (Article 18(2)) | Duty to ensure it can be made available on request (Article 18(7)) | Keep a copy at the disposal of the market surveillance authorities (Article 18(7)) |
The key is not to confuse the stage of having collected documents with the stage of having completed the assessment. Look at the part number covered, the test conditions, the scope demonstrated and the revision date, not the document title.
Annex VIII declaration item table
Article 39(2) requires the declaration to follow the model structure in Annex VIII and to contain the elements specified in the Annex VII module. The items of Annex VIII and the points to confirm when filling them in are as follows.
| Item | Annex VIII | What to confirm when filling in |
|---|---|---|
| No. | Identification number of the declaration | A numbering system linked to the packaging type and version |
| 1 | Unique identification of the packaging | Matches the packaging number on the specification sheet |
| 2 | Name and address of the manufacturer and, where applicable, the authorised representative | Is it the manufacturer determined under the Article 3 definitions? |
| 3 | Statement that the declaration is issued under the sole responsibility of the manufacturer | Leave as is |
| 4 | Object of the declaration (identification of the packaging allowing traceability): description of the packaging | Sales, grouped or transport packaging, components |
| 5 | Statement that the object conforms to the relevant EU harmonisation legislation, and reference to any other EU legislation applied | Article 39(3): a single declaration is possible where several EU acts require one |
| 6 | References to the harmonised standards, common specifications or other technical specifications applied | Matches the list in Annex VII point 2(d) |
| 7 | Where applicable, name, address and number of the notified body, its intervention and the certificate issued | Leave blank if not applicable |
| 8 | Additional information | |
| Signature | Place and date of issue, name and function, signature | Internal signing authority |
Distinguish the items of the statutory model from your own internal checklist, and do not invent content that does not apply.
Pre-drafting checklist
| Step | Check | Basis | Pass criterion |
|---|---|---|---|
| 1 | Has the packaging been identified? | Annex VIII points 1 and 4 | Packaging number, version and components match the specification sheet |
| 2 | Have currently applicable requirements been separated from future ones? | Article 71; application dates of Articles 6, 7 and 12 | A table of application dates per requirement exists |
| 3 | Is the assessment evidence for each applicable requirement in the technical documentation? | Annex VII point 2 | Each requirement is linked to a supporting document and a conclusion |
| 4 | Do the supplier documents match the current specification? | Article 16 | Part number and revision date match |
| 5 | Has the timing of the recyclability assessment been confirmed? | Guidance Section 6 | No Article 38 assessment needed before the Article 6(4) delegated act enters into force |
| 6 | Drafting language and translation | Article 39(2) | Language required by the Member State of placing or making available on the market |
| 7 | Signing authority and version control | Article 39(4) | Signatory, date of issue, retention of previous versions |
Section 6 of the Commission guidance explains that the recyclability principle in Article 6(1) applies from 12 August 2026, and that the design-for-recycling criteria in Article 6(2)(a) apply from 1 January 2030 or 24 months after the delegated act enters into force, whichever is later. Because the declaration is a conclusion on requirements whose assessment has been completed, merging the dates into one without separating them by requirement distorts the scope of the declaration.
Fictional example: a bottle confirmation exists but the label has changed
This is a fictional example for illustration. Suppose the bottle supplier's confirmation has been obtained, but the current product's label changed last quarter. A review remains as to whether the bottle documents alone can explain the changed label and the relevant requirements for the complete packaging. The current packaging configuration must be matched to the documents, the change impact confirmed and the missing evidence supplemented; the review is not closed merely because the document title and signature block are complete. This example is not a compliance judgement on specific packaging.
After the declaration: versions and retention
Article 39(2) requires the declaration to be continuously updated, and Article 15(4) requires reassessment under the Article 38 procedure where a change in the packaging design or characteristics is judged capable of affecting compliance. Link the packaging number, the declaration version, the applicable specification and the date of issue to reduce reuse of old documents. The retention period under Article 15(3) is 5 years from placing on the market for single-use packaging and 10 years for reusable packaging. The importer must keep a copy of the declaration for the same period under Article 18(7) and ensure the technical documentation can be made available on request, and Article 18(8) requires information to be provided within 10 days of a reasoned request from an authority.
Common misunderstandings
| Common explanation | What the legal text provides | What to check |
|---|---|---|
| The supplier confirmation is the DoC | The declaration is a document under the sole responsibility of the manufacturer. | Signatory |
| A certification body issues the DoC | Module A in Annex VII is the manufacturer's own procedure. | Whether Annex VIII point 7 applies |
| Filling in the form is enough | Article 39(1) presupposes that fulfilment of the requirements has been demonstrated. | Assessment evidence per requirement |
| All requirements are declared as of one date | Each requirement has its own application date. | Table of application dates |
| Once written, it never changes | Article 39(2) requires continuous updating. | Change history and versions |
| The consultant wrote it, so the consultant is responsible | Article 39(4) and guidance Section 2 place responsibility on the manufacturer. | Signing authority |
Documents that speed up the review if prepared before enquiring
- List of packaging in scope with packaging numbers and versions
- Applicable requirements review or a list of evidence per requirement
- List of supplier documents and test reports (including part numbers and revision dates)
- If an existing declaration exists, its version and signatory
Please mention PPWR packaging in your message when you use the PPWR declaration review enquiry. We will review the evidence to link to the declaration and the scope of supplementation. The scope and cost of the review are advised individually after we have confirmed the packaging configuration and the state of the documents.
Prepared and sources checked: 2026-10-06. Sources: Regulation (EU) 2025/40 Article 15(2) to (4), Article 16, Article 18(2), (7) and (8), Article 38, Article 39, Article 71, Annex VII, Annex VIII · Commission Notice C/2026/3084 Section 2 (drawing up the declaration and manufacturer responsibility), Section 6 (timing of recyclability application). The comparison table, item table, checklist and fictional example are our own practical tools and do not replace a compliance judgement on individual packaging.
Frequently asked questions
- Q. Can we send the supplier's confirmation of compliance to the EU importer as the DoC?
- No. Article 39(4) provides that by drawing up the EU declaration of conformity the manufacturer assumes responsibility for the compliance of the packaging, and point 3 of Annex VIII states that the declaration is issued under the sole responsibility of the manufacturer. A supplier confirmation is information and documentation that the manufacturer uses under Article 16 to demonstrate compliance; it is not the declaration itself.
- Q. Is the PPWR declaration issued by an external certification body?
- Article 38 provides that the conformity assessment follows the procedure in Annex VII, and Annex VII is Module A, internal production control, under which the manufacturer ensures and declares conformity on its sole responsibility. The notified body field in point 7 of Annex VIII is filled in only where applicable. Section 2 of the Commission guidance explains that the assessment can be entrusted to a test laboratory or similar, but the declaration is drawn up by the manufacturer or the authorised representative and responsibility rests with the manufacturer.
- Q. Do we have to include design-for-recycling criteria that do not yet apply in the declaration?
- Under Article 39(1), the declaration states that fulfilment of the requirements in Articles 5 to 12 has been demonstrated, so its subject is the requirements applicable at that time. Section 6 of the Commission guidance explains that until the delegated act under Article 6(4) enters into force, there is no need to carry out the conformity assessment under Article 38 and Annex VII for recyclability. Do not write as if future requirements had already been assessed.
- Q. How long is the declaration kept and when is it revised?
- Article 15(3) requires the technical documentation and the declaration to be kept for 5 years from placing on the market for single-use packaging and 10 years for reusable packaging. Article 39(2) requires the declaration to be continuously updated and to be drawn up or translated into the language required by the Member State where the packaging is placed or made available on the market. The importer also keeps a copy of the declaration for the same period under Article 18(7), at the disposal of the market surveillance authorities.