If you’re reading this article, you may, like us, have received requests from customers concerning the EU Packaging and Packaging Waste Regulation [PPWR]. You may have been asked for technical information about your products, evidence of compliance, or a PPWR Declaration of Conformity. Those requests may have arrived shortly before—or even after—PPWR went into effect or, in EU terminology, became ‘applicable’ on August 12, 2026.
If your company sells only to US customers, it is understandable to question why an EU packaging regulation would concern your business. The connection comes through what happens to your products after you sell them.
Your company may manufacture packaging, supply components used to assemble it, or provide the raw materials those components are made from. If that packaging eventually reaches the EU, technical information about your products may be needed to support the packaging manufacturer’s PPWR assessment. Or you may be the packaging manufacturer responsible for ensuring that your packaging product complies with PPWR. A request can therefore reach your company through a US customer, even when you have no direct relationship with the company receiving the packaging in Europe.
What your company needs to provide depends on its role in that chain. Supporting technical information and the manufacturer’s Declaration of Conformity serve different purposes.
A PPWR Declaration of Conformity [DoC] is the manufacturer’s signed statement that the identified packaging meets the applicable PPWR requirements. Before signing it, the manufacturer must assess the packaging and document the evidence supporting that conclusion. PPWR specifies the assessment procedure in Annex VII and the declaration’s required structure in Annex VIII. 1, Articles 15(2), 38–39; Annexes VII–VIII
This article is for US manufacturers responsible for the conformity of transport packaging: pallets, pallet collars, industrial strapping, stretch wrap, and boxes or crates used to protect goods during handling and transport. PPWR defines this category by the packaging’s function. Road, rail, ship, and air freight containers are excluded from that definition. Other packaging categories are outside this article’s scope. 1, Article 3(1)(7) 2, Section 2
This is our understanding based solely on directly reading the Regulation, the European Commission’s Guidance and FAQ, and its official implementation updates. It is intended to help. It is not legal advice, an authoritative EU interpretation, or a claim of EU approval. Manufacturers should review the sources, perform their own assessments, and seek qualified legal advice as needed to meet their compliance needs. The Regulation establishes the requirements; the Guidance and FAQ explain the Commission’s interpretation. Our examples show how we propose to apply them.
In This Article
- What the Declaration Covers
- Why the Manufacturer Is Responsible
- Understanding the Annex VII Assessment
- How the Technical File Supports the Assessment
- What Annex VIII Requires in the Declaration
- How Our Template Organizes the Declaration
- How to Provide and Maintain the Declaration
- References
What the Declaration Covers
The Declaration of Conformity communicates the manufacturer’s conclusion about an identified packaging product. The assessment establishes whether that product meets the requirements that apply to it. The Technical File contains the assessment and its supporting technical information. PPWR calls this collection “technical documentation.” Together, these records explain what the manufacturer is declaring and why it can make that declaration. 1, Annex VII; Article 39
A Product Declaration That Can Cover Continuing Production
Annex VII requires a written declaration for each packaging type. The Commission’s FAQ allows packaging to be grouped when it has the same characteristics relevant to the applicable requirements and its differences do not affect conformity. A product family therefore needs a defined scope that the assessment actually covers. 1, Annex VII, point 4 3, Section XV, Questions 2 and 10
This supports using the same assessment and declaration for continuing production of the covered product or family. PPWR does not require a new assessment and DoC for every lot, batch, sale, or shipment. Individual production records and test reports can provide supporting technical information, while the manufacturing process and its monitoring must ensure that the packaging being produced continues to conform. The assessment concerns both the product and the relevant aspects of how it is manufactured. 1, Article 15(4); Annex VII, points 2–4
A Safety Data Sheet (SDS) is a useful comparison for this document relationship. A company provides the current document for the covered product repeatedly, rather than generating a new document each time it sells that product. The analogy concerns reuse and availability; an SDS and a PPWR DoC establish different things.
The product boundary also matters. A pallet, the strapping holding goods on it, and the stretch wrap protecting the load are separate transport packaging types, each requiring its own assessment and declaration. The pallet assessment includes its relevant components, such as the lumber and nails used to build it. That does not make a request for technical information about those nails a request about the box in which the nails were delivered. 3, Section XV, Questions 5 and 11
Other Compliance Statements Can Support the Work
Manufacturers may already have specifications, supplier declarations, chemical compliance statements, and laboratory reports. Those documents may provide useful supporting technical information for a PPWR assessment.
A statement concerning the EU chemicals regulation REACH or another regulation does not, by itself, establish conformity with PPWR. The manufacturer still has to assess the applicable PPWR requirements through Annex VII, document the basis for its conclusions, and issue a declaration meeting Annex VIII. Several statements about other regulations do not automatically complete that work. 1, Articles 38–39; Annexes VII–VIII
Where several EU laws require declarations, Article 39 provides for a single declaration covering the relevant laws where appropriate. This can take the form of a collection of individual declarations, called a “dossier.” Combining documents is allowed; the PPWR assessment and declaration requirements still have to be fulfilled. 1, Article 39(3) 3, Section XV, Question 4
Why the Manufacturer Is Responsible
The company responsible as the manufacturer under PPWR is responsible for the assessment, technical documentation, and declaration. A distributor forwarding a customer’s request does not take over that responsibility merely by supplying the packaging. Suppliers of packaging materials and components provide the technical information needed to support the manufacturer’s work. 1, Articles 15–16
The responsible manufacturer is determined by PPWR’s definitions and the actual supply arrangement. Our previous articles explain US pallet manufacturer responsibility and responsibility for unbranded packaging. The broader packaging declarations explanation discusses how these requests reach US companies.
A manufacturer can obtain third-party help with the assessment and drafting the declaration. It remains responsible for the resulting conformity statement and technical documentation. A formal authorized representative is a separate PPWR role: a person or company established in the EU and acting under a written mandate. That appointment does not transfer the manufacturer’s obligation to draw up the technical documentation. 1, Articles 3(1)(19), 15(2), 17 and 39(4) 2, Section 2
Understanding the Annex VII Assessment
Annex VII calls the procedure Module A: Internal Production Control. In practical terms, the manufacturer assesses its packaging against the applicable requirements, documents the assessment, ensures that production continues to meet those requirements, and declares conformity under its own responsibility. 1, Annex VII, points 1–4
Annex VII requires the technical documentation to identify the applicable requirements and address the packaging’s design, manufacture, and operation where relevant. It also requires an adequate analysis and assessment of the risks of nonconformity. For a manufacturer, this means considering whether the product and the way it is made support the conformity conclusion, including circumstances that could cause it to fall short. 1, Annex VII, points 2–3
The following table identifies the areas covered by Articles 5–12, which Annex VII and Article 39 reference. It is a guide to the assessment’s scope. Each linked article opens the actual regulatory text in a new tab, where the manufacturer can review its full requirements, qualifications, and timing.
| PPWR Article and Assessment Area | What It Concerns for a Transport Packaging Manufacturer |
|---|---|
| Article 5 — Substances in Packaging | Substances present in the packaging and its components, including restrictions on certain heavy metals. Some provisions concern particular uses, such as food-contact packaging. Supporting technical information about the materials and components helps establish which requirements apply and whether they are met. |
| Article 6 — Recyclable Packaging | Whether the packaging meets the applicable recyclability requirements. The article addresses design for recycling and recycling in practice, with requirements introduced in stages. The exemption for certain lightweight-wood sales packaging is not a general exemption for wooden transport packaging. |
| Article 7 — Recycled Content in Plastic Packaging | Recycled-content requirements for plastic parts of packaging, subject to the article’s scope, exemptions, and application dates. Relevant technical information concerns the plastic material and the basis for any applicable recycled-content conclusion. |
| Article 8 — Biobased Feedstock | A Commission review and possible future measures concerning biobased plastics. The article does not itself establish a current minimum biobased-content requirement for manufacturers. |
| Article 9 — Compostable Packaging | Which packaging must be compostable and the treatment of other packaging. Calling transport packaging “non-compostable” does not settle the whole article: paragraph 3 also addresses material recycling for packaging outside the specified compostable categories. |
| Article 10 — Packaging Minimization | Whether packaging weight and volume are limited to what is necessary for its function, taking account of its design and materials. Annex IV provides the assessment criteria and documentation framework. The transition to these requirements matters. |
| Article 11 — Reusable Packaging | The conditions packaging must meet to be considered reusable, including its design, repeated use, and reconditioning. A customer’s ability to use an item again does not alone establish that it meets this article. |
| Article 12 — Packaging Labels | Applicable labeling and information requirements. The consumer waste-sorting label excludes transport packaging other than e-commerce packaging; that exclusion does not remove every other provision of Article 12. |
The table summarizes the Regulation; the Commission’s Guidance further explains recyclability, exemptions, and minimization. Each company’s assessment needs to address the requirements that apply to its own packaging product and intended use. 1, Articles 5–12; Annex VII 2, Sections 6, 7 and 10
Applicability and Timing Are Part of the Assessment
A requirement that applies now, one that applies later, and one that does not apply to a particular product are different conclusions. An exemption also has conditions. Our approach is to account for those distinctions explicitly, with the reason and relevant provision, so a reader can understand why an item was included or excluded.
PPWR’s August 12, 2026 application date did not activate every detailed requirement at once. Some provisions depend on additional rules the Commission is authorized to adopt, called delegated or implementing acts:
- Recyclability: Article 6’s general requirement applies, but the Guidance distinguishes that duty from the Annex VII recyclability assessment, which becomes applicable when the relevant delegated acts enter into force. The detailed design-for-recycling requirements apply from January 1, 2030, or 24 months after those acts enter into force, whichever is later.
- Recycled content: Article 7’s initial targets apply from January 1, 2030, or three years after the relevant implementing act enters into force, whichever is later. Its calculation and verification provisions have a separate timetable.
- Compostability and minimization: The compostability and material-recycling requirements in Article 9(1) and (3) apply from February 12, 2028. Article 10’s new minimization requirements apply from January 1, 2030; specified requirements from the previous Packaging Directive continue through December 31, 2029.
- Labeling: Article 12 has its own dates and conditions, including provisions dependent on later Commission measures.
These distinctions are explained in the Regulation and Guidance. The Commission’s implementation page provides updates on the additional measures. A future requirement should remain visible as future work, rather than being presented as a current conformity finding or a permanent exemption. 1, Articles 6–7, 9–10, 12 and 70 2, Sections 6 and 10 4
How the Technical File Supports the Assessment
The Technical File is the collection of supporting documentation on which the conformity assessment is based, together with the recorded assessment. It connects the packaging product, the applicable PPWR requirements, the supporting technical information, and the manufacturer’s conclusions.
A supplier declaration or test report may establish something about a material or component. The Technical File explains how that information supports the assessment of the packaging product. An organized collection of documents becomes useful when that connection is clear. Annex VII requires documentation that makes the packaging’s conformity assessable, including the applicable requirements and risks of nonconformity. 1, Annex VII, point 2
Annex VII lists the following documentation categories wherever applicable. The examples in the second column illustrate the kinds of existing records that may contribute; they are not additional mandatory document formats.
| Annex VII Documentation Category | What That Can Mean in Familiar Manufacturing Terms |
|---|---|
| General description and intended use | A product specification or description identifying the packaging product, covered variants, and the work it is intended to do. |
| Design, manufacturing drawings, and component materials | Drawings, construction details, bills of materials, and supporting technical information about the materials and components. |
| Explanations needed to understand the design and operation | Descriptions that explain the drawings, assembly, and how the packaging functions in its intended use. |
| Standards, common specifications, and other relevant technical specifications | References to the standards or specifications used, including those used for measurement or calculation, which parts were applied, and the solutions adopted where harmonized standards or common specifications were not applied. |
| Qualitative descriptions of assessments under Articles 6, 10, and 11 | Written explanations of how the applicable recyclability, minimization, and reusability assessments were carried out. “Qualitative” here concerns explaining the assessment, rather than supplying only a numerical result. |
| Test reports | Relevant reports supporting the assessed requirements for the packaging and its materials or components. |
Source: 1, Annex VII, point 2(a)–(f).
Under PPWR, harmonized standards whose references are published in the EU Official Journal can support conformity with the requirements they cover. “Common specifications” are specifications the Commission can establish under Article 37. Annex VII also accommodates other relevant technical specifications and requires an explanation of the solutions used when harmonized standards or common specifications are not applied. These references identify the basis for the assessment; a manufacturer still needs to determine what is appropriate for its product. 1, Articles 36–37; Annex VII, point 2(d)
Supplier material declarations, chemical compliance statements, and laboratory reports can all be supporting technical information within this collection. Their relevance depends on what they establish about the identified packaging product and the particular PPWR requirement.
The Regulation establishes what the documentation must support and contain. The company determines the appropriate technical work and evidence for its circumstances. Our suggestion is to keep the relationship visible: the requirement being assessed, the relevant supporting technical information, and the resulting conclusion. This also makes later changes easier to review without recreating unaffected work.
What Annex VIII Requires in the Declaration
Once conformity has been demonstrated, the manufacturer issues the written declaration. Article 39 requires it to state that the applicable requirements in Articles 5–12 have been fulfilled and to follow Annex VIII’s model structure. 1, Articles 15(2) and 39; Annex VII, point 4
Annex VIII supplies a prescribed structure and required content. We have not identified a separate official EU fill-in template in the sources reviewed. A company can design its document around that structure, provided the required information and statements are present.
The heading identifies the document as an EU Declaration of Conformity and provides a declaration identification number.
The declaration identification number is assigned by the manufacturer through its own document-control system. It is not an EU-issued approval or registration number. Together with the revision and issue date, it identifies the particular declaration being provided. In our template, that information connects the issued declaration to the packaging products it covers and the Technical File supporting it at the time of issuance.
Annex VIII then contains eight entries:
- Unique Identification of the Packaging. The product identification that establishes which packaging the declaration covers.
- Manufacturer and Authorized Representative. The manufacturer’s name and address, plus those of its authorized representative where applicable.
- Sole Responsibility. The statement that the declaration is issued under the manufacturer’s sole responsibility.
- Object of the Declaration. A description identifying the packaging and allowing traceability. “Object” means the packaging product being declared.
- Applicable EU Legislation. The statement of conformity and identification of the relevant EU legislation. For this article’s purpose, that includes Regulation (EU) 2025/40, with any other EU acts applied.
- Technical References. The relevant harmonized standards, common specifications, or other technical specifications in relation to which conformity is declared.
- Notified Body, Where Applicable. Its name, address, identification number, work performed, and certificates issued, including dates and applicable validity information. A notified body is an officially designated conformity-assessment organization. Annex VII’s Module A does not itself require one.
- Additional Information. Space for other information relevant to the declaration.
The signature block identifies who the declaration is signed for and on behalf of, the place and date of issue, and the signer’s name, function, and signature. These elements are part of the model, even though they follow the numbered entries. 1, Annex VIII
Article 39 also requires the declaration to remain updated and to be translated into the language or languages required by the EU country where the packaging is placed or made available on the market. An English original may therefore need translated copies. 1, Article 39(2) 3, Section XV, Question 14
How Our Template Organizes the Declaration
Our template for polyester (PET) strapping is one possible way to organize this information. It includes the Annex VIII entries and adds space to connect the declaration to the applicable PPWR requirements and the Technical File.
This is our own method, based solely on our reading of the Regulation, Commission Guidance, and FAQ. It is not an official EU template, legal advice, or a claim of EU approval. Manufacturers should conduct their own assessments and seek qualified legal advice as needed. Completing the fields does not itself demonstrate conformity.
Connecting the Required Entries to the Template
The template’s section numbers are our organizational choices. They do not replace Annex VIII’s numbering or create additional regulatory requirements.
| Annex VIII Element | How Our Template Provides for It |
|---|---|
| Declaration heading and number | Section 0 identifies the EU Declaration of Conformity and provides document-control fields, including its number and revision. |
| 1. Unique packaging identification | Section 1 identifies the strapping product or defined family covered by the declaration. |
| 2. Manufacturer and representative | Section 2 records the manufacturer’s identity and address, with space for an authorized representative where applicable. |
| 3. Sole responsibility | Section 3 provides the manufacturer’s sole-responsibility statement. |
| 4. Object and traceable description | Section 4 describes the strapping and its covered scope so the declaration can be connected to the actual packaging product. |
| 5. Applicable legislation and conformity | Section 5 identifies PPWR and provides the conformity statement, with room to address other applicable EU legislation. |
| 6. Technical references | Section 6 provides space for the relevant standards, common specifications, and other technical specifications. |
| 7. Notified body, where applicable | Section 7 accounts for the entry, including an explanation when it is not applicable. Any applicable notified-body involvement would need the details required by Annex VIII. |
| 8. Additional information | Section 8 provides supporting context, including Technical File identification and language information. Section 9 adds our summary of applicability and assessment references. |
| Signature block | Section 10 provides the on-behalf-of statement, place and date, and signer’s name, function, and signature. |
This arrangement lets the declaration carry both the required statement and a concise explanation of its basis. The complete supporting technical information remains in the Technical File.
Showing the Connection to the PPWR Requirements
The additional assessment summary is where we account for the relevant Articles 5–12. It provides space for the assessment conclusion or applicability explanation and a reference to the supporting Technical File.
For example, an Article 5 entry can identify the substances assessment and point to the relevant material and component technical information. An entry concerning a future requirement can explain the applicable timing. An entry considered not applicable can identify the product characteristic and regulatory provision supporting that conclusion.
Those are examples of the information the space is intended to communicate. They are not findings about any particular strapping product. The manufacturer supplies the conclusions supported by its own assessment.
Annex VIII does not require the declaration to reproduce every part of the assessment. We include this summary because it makes the connection easier to follow: the reader can see the PPWR requirement, the manufacturer’s position, and where its supporting assessment is documented. A Technical File reference supplements the declaration’s required statements and technical references; it does not replace them.
The manufacturer’s declaration remains subject to review. An EU importer may need further information before relying on it, and national authorities can examine whether it is supported. Customer acceptance does not establish regulatory approval. 1, Articles 18(2) and 39(5) 3, Section XV, Question 8
How to Provide and Maintain the Declaration
The manufacturer generates and maintains the declaration and makes it available when requested. Annex VII requires a copy to be available to the relevant authorities on request. It does not establish a general requirement to issue a fresh declaration or attach a copy to every sale or shipment. 1, Annex VII, point 4
Our suggestion is to make the Declaration of Conformity generally available as a downloadable PDF through a dedicated company website link. The manufacturer would retain the supporting Technical File and provide it upon specific request to appropriate customers and national authorities as required by PPWR.
Providing current copies to suppliers and distributors is another option. A strapping manufacturer can provide its DoC to a distributor, which supplies it to a US sawmill using the strap for export shipments. The sawmill can then pass it to its customer. The same manufacturer’s declaration can serve that chain.
The current copy needs to be identifiable by the products it covers and its revision.
Keeping the Assessment and Declaration Current
Article 15 requires changes that could affect conformity to be considered, and Article 39 requires the declaration to remain updated. Changes to materials, design, manufacturing, intended use, or relevant requirements may affect the existing assessment. The purpose of review is to establish whether the documented conclusion still holds for the packaging being produced. 1, Articles 15(4) and 39(2)
Our approach is to retain valid work and update the parts affected by a change. A material change may affect one assessment area without requiring unrelated drawings or conclusions to be recreated. Maintaining that connection between the product, assessment, Technical File, and declaration makes reuse of the documentation more practical.
PPWR requires the declaration and technical documentation to be retained for five years for single-use packaging and ten years for reusable packaging, measured from when the packaging is placed on the EU market. The date of the first signature does not start a single retention period for all later production. Article 15(10) requires relevant documentation within ten days of receiving a reasoned request from a national authority. The records therefore need to remain retrievable as well as current. 1, Article 15(3), (10); Annex VII, point 4
Template Disclaimer
The templates provided below reflect our understanding of PPWR based on our reading of the Regulation, Commission Guidance, and FAQ. We do not present them as official EU templates or as formats pre-approved or accepted by EU authorities. They are practical starting points, not legal advice or completed declarations. Manufacturers should review the applicable requirements, make an informed decision about each template’s suitability, perform their own conformity assessments, and seek qualified legal advice as needed.
