Who owes the technical documentation and the declaration of conformity under the PPWR?

The manufacturer. Under Article 15(1) manufacturers must place on the market only packaging that complies with Articles 5 to 12, and under Article 15(2) they carry out the conformity assessment procedure under Article 38, draw up the EU declaration of conformity under Article 39 and compile the technical documentation in Annex VII. The Commission's PPWR FAQ states that the technical documentation cannot be delegated at all, and that the manufacturer remains the sole economic operator legally responsible for compliance.

When must a PPWR declaration of conformity be drawn up?

In general by 12 August 2026. The Commission's FAQ says that where a provision does not specify its own application date, the general application date applies, and companies therefore have to carry out the conformity assessment procedure by 12 August 2026. For recyclability the same FAQ gives a later date: manufacturers need to comply with the recyclability requirements and perform the Article 38 conformity assessment only two years from the adoption of the design-for-recycling delegated act under Article 6(4), with the binding recyclability performance criteria from 1 January 2030 or two years from the date of entry into force of that act.

Which PPWR requirements already have to be reflected in the technical documentation?

According to the Commission's PPWR FAQ: Article 5(1) on minimising substances of concern and the heavy-metal limits in Article 5(4) apply to all packaging from 12 August 2026, while the PFAS limits in Article 5(5) apply to food-contact materials only. Compliance with the recyclability exemptions in Article 6 and the recycled-content exemptions in Article 7 must be assessed and included in the Annex VII technical documentation. Reusable packaging must be evidenced in the technical documentation as designed to allow the minimum number of rotations to be set under Article 11(2), and environmental claims under Article 14 must relate to properties going beyond the PPWR minimum requirements.

When does PPWR packaging minimisation apply?

Article 10(1) and (2) apply from 1 January 2030. The Commission's FAQ says that until the end of 2029 the essential requirements of Directive 94/62/EC continue to apply, including the existing standard EN 13428:2004, and attributes that to Article 70(1)(b) of the PPWR. From 2030 double walls, false bottoms, frontal flaps and additional layers must be justified and proven in the technical documentation, and minimisation sits within Articles 5 to 12, which is what the declaration of conformity covers.

PPWR: the declaration of conformity and the technical documentation

Who owes what, and in whose name

The duties in this note attach to the manufacturer, which is a different role from the producer who owes the EPR registration and fees on the country desks. Both can land on the same small company, and the difference is worth knowing before you buy a file: who places the order and decides the design gets the conformity duties, and if your name or trademark is on the packaging, that is you. Manufacturer or producer? maps the two roles.

The base obligation: Art. 15(1): manufacturers may place on the market only packaging that is in conformity with the requirements laid down in or pursuant to Articles 5 to 12. The FAQ adds that the same obligation reaches importers and distributors.
Three documents, one file: Under Art. 15(2) the manufacturer carries out the conformity assessment (Art. 38), draws up the EU declaration of conformity (Art. 39) and compiles the technical documentation in Annex VII — the FAQ also points to Annex VIII. The technical documentation must at least include the conceptual design, manufacturing drawings and materials of components.
Who may do the assessment: The assessment can be carried out by the manufacturer or on its behalf — a laboratory or a certification scheme, for example. The declaration may also be drafted by an authorised representative appointed by written mandate.
What cannot be delegated: The technical documentation itself. The FAQ is blunt: under Art. 17 that obligation cannot be delegated, and the manufacturer stays the sole economic operator bearing legal responsibility for compliance, whatever the contract says.
One declaration per packaging type: Not one per company. The FAQ says the declaration should be drawn up at the level where the packaging has the same characteristics in view of the applicable requirements and the packaged product — different products means separate declarations. Grouped packaging such as pallets, pallet collars, wrappings and straps undergo separate assessments and need their own declarations.
One declaration per packaging unit: Bottle, closure and label as one unit: a single assessment and declaration is sufficient for the unit as a whole, though the declaration should carry the relevant information on the separate components.
Language: In the language(s) required by the Member State(s) where the packaged products are supplied, so a market surveillance authority can verify it on request — that is the FAQ reading Art. 39(2).
How long to keep it: Under Art. 15(3) and Art. 18(7): 5 years for single-use packaging, 10 years for reusable packaging. Suppliers passing you design information does not discharge the duty — it is the manufacturer's file.
What your supplier owes you: Art. 16(1): all the information and documentation needed to demonstrate conformity, in paper or electronic form, and the FAQ says they cannot refuse. What suppliers are not is the manufacturer — except where the manufacturer is a microenterprise and the supplier sits in the same Member State.

Importing from outside the EU? Art. 18 puts the burden on the importer: from 12 August 2026 it must satisfy itself that the third-country manufacturer has carried out the Art. 38 procedure and drawn up the declaration, that the marking duties in Art. 15(5) and (6) are met, and that the required documents accompany the packaging.

What bites now — Articles 5 to 14

"The PPWR applies from 12 August 2026" is true but coarse. The FAQ separates the provisions that came in on the general application date from those tied to an act that is still to be adopted, and that separation is what should shape your file.

Substances of concern — Art. 5(1): All packaging, from 12 August 2026. The FAQ: "The general obligation to minimise SoC in Article 5(1) and the limits on four heavy metals in Article 5(4) apply to all packaging from 12 August 2026." The Regulation sets no general concentration limit for SoC — the Commission's own answer — but specific limits exist for certain substances.
Heavy metals — Art. 5(4): All packaging, from 12 August 2026, and not a new duty: it restates what Art. 11 of the repealed Directive 94/62/EC already required. The limit concerns the sum of lead, cadmium, mercury and hexavalent chromium. The FAQ recommends the CEN report CR 13695-1/2000 to measure it, and records that the glass derogation in Commission Decision 2001/171/EC survives — recycled glass may exceed the limit, but none of the four metals may be intentionally introduced.
PFAS — Art. 5(5): Food-contact materials only. The FAQ is explicit, and corrects the common shorthand: the PPWR does not ban PFAS, it sets maximum concentration levels, and those limits do not distinguish between intentionally added and unintentionally present PFAS. They apply to the packaging unit as a whole, including the associated inks, varnishes, glues and adhesives.
Recyclability — Art. 6(1): All packaging must be recyclable. This is the one to read with the section below: the FAQ's application-date rule points to the general date, while its answer on manufacturers' obligations defers the Art. 38 assessment for recyclability to two years from the Art. 6(4) delegated act.
Reuse — Art. 11: The FAQ dates reusable packaging to the entry into force of the Regulation, 11 February 2025 — but the minimum number of rotations is to be set in the act under Art. 11(2). That act is to be adopted by 12 February 2027; the FAQ calls it a delegated act in its reuse chapter and an implementing act in its list of application dates. Either way, manufacturers have to show in the technical documentation that the design and the reuse system allow the minimum rotations to be met — for open-loop and closed-loop systems alike.
Green claims — Art. 14: Claims must go beyond the minimum requirements the PPWR sets, and must say what they refer to. More in the claims section below.
Recycled content — Art. 7: Not live now: 1 January 2030 or three years from the entry into force of the implementing act under Art. 7(8). Compliance is demonstrated in the technical documentation either way, and the FAQ says the exemptions in Art. 6 and Art. 7 also have to be assessed and recorded in the Annex VII file.

The recyclability deferral

This is the part of the PPWR the Commission's FAQ answers twice, in two directions, and it is worth reading both answers before you commission any recyclability testing.

The general rule, chapter XV

Asked from which date companies must carry out the conformity assessment procedure, the FAQ answers: where a relevant provision does not specify its own date for entry into application, the general application date applies, and "companies will thus have to carry out the conformity assessment procedure by 12 August 2026".

The recyclability exception, chapter X

"As regards recyclability, manufacturers must comply with the recyclability requirements and perform the conformity assessment procedure in accordance with Article 38 and Annex VII of the PPWR only two years from the adoption of the delegated act on design for recycling requirements. On the assumption that this delegated act will be adopted by the Commission in January 2028 and will fully harmonise design for recycling requirements and the related assessment methodology, the binding recyclability performance criteria will only apply from 1 January 2030 or two years from the date of entry into force of the delegated act."

The date the FAQ works from: The delegated acts under Art. 6(4) are to be adopted by 1 January 2028. That is the assumption behind the 1 January 2030 figure, and it is an assumption, not a fixed date in the Regulation.
Design for recycling — Art. 6(2): Recyclability according to the design-for-recycling principles in those delegated acts applies 24 months from the date of entry into force of the acts, which the FAQ frames as 1 January 2030 or two years after entry into force. It covers every type of packaging, reusable or single-use, sales, grouped or transport.
What that means for stock: Because the clock runs from the acts, packaging placed on the market before then can stay on the market even if it does not meet the recyclability requirements. The FAQ adds that placing on the market means every single packaging unit, not the design.
The part that is already active: The recyclability performance grade assessment is the manufacturer's, and the FAQ says the result must be in the technical documentation before the packaging is placed on the market. Market surveillance authorities check it and national penalties apply under Art. 68.

Read it as a sequencing rule, not a holiday. The paper trail around Articles 5 to 12 is live for what applies now, and the composition side — substances of concern and the heavy metals — is exactly what you can document today with information from your suppliers.

The interim benchmark, and its limits

Until the design-for-recycling act and its assessment method exist, there is no PPWR methodology against which a manufacturer can demonstrate recyclability. The interim position is still built on the old framework, and the FAQ is careful about how much weight that framework now carries.

The old standards, as guidance: The FAQ lists the harmonised standards cited under the old Directive 94/62/EC — among them EN 13430:2004, packaging requirements for packaging recoverable by material recycling, and EN 13428:2004 on prevention by source reduction. Under the PPWR, it says, these can be used only as guidance (Recital 58): there is no longer a presumption of conformity based on them.
The one exception: Art. 70(1)(b), for the packaging-minimisation essential requirements of the old Directive — those continue to apply until the end of 2029, and so does the related harmonised standard with its presumption of conformity. That is a minimisation rule, not a recyclability rule.
What it means on a file: An EN 13430:2004-style test report is therefore not, by itself, proof of PPWR conformity. Treat it as evidence you were reasonable under the framework that was then in force, and label it that way in the file rather than presenting it as the Art. 38 assessment.
The Commission's own housekeeping: The FAQ records that the Commission will consider formally repealing the list of old harmonised standards before the Regulation becomes applicable, and that a presumption of conformity with PPWR standards only returns once a Commission decision listing the new standards is published in the Official Journal.

Where we are cautious. The summary that prompted this note said the Commission directs manufacturers, in the interim, to meet the recyclability requirement under the old Directive's rules and EN 13430:2004. We could not verify that in the Commission's FAQ, which instead says the old standards are guidance only. See what we could not establish.

Green claims need an analysis, too

Art. 14 is easy to miss because it is not a requirement about the packaging; it is a requirement about what you say about it. The FAQ's answer is specific.

Beyond the minimum: A claim may only be made for properties that go beyond the applicable minimum requirements set out in the PPWR. Recyclability, compostability, recycled content, reusability, minimisation of weight and volume all fall inside Art. 14.
What the claim must say: It must be clear whether it refers to the whole packaging unit, a part of it, or all packaging placed on the market over a calendar year by the operator. The FAQ illustrates this on recycled content: for a PET bottle at the 30% target with a PP closure at 10%, a claim on the whole unit needs to beat 30%, while a claim on the closure alone needs to beat 10%.
What is outside it: Claims about properties the PPWR does not regulate — recycled content in aluminium packaging, for example — are governed by Directive (EU) 2024/825 and the unfair commercial practices rules. The FAQ notes that where the two conflict, the PPWR as the specific rule prevails.
Where the analysis lands: Underneath the claim there has to be a legal filing. The FAQ says that regardless of whether an environmental claim is made, compliance with the legal requirements must be demonstrated in the technical documentation.

One thing we could not confirm. The summary we worked from said a claim under Art. 14 does not have to be confirmed by a declaration of conformity, but that the analysis should be reflected in the technical file. The second half is supported by the FAQ; for the first half we found no statement either way. Do not treat Art. 14 as a formal annex of the declaration on that basis.

The 1 January 2030 dates

Two requirements that carry their own dates sit in the same technical file, so they belong here rather than only on the minimisation note.

Minimisation — Art. 10(1) and (2): From 1 January 2030, both paragraphs. Until the end of 2029 the essential requirements of Directive 94/62/EC continue to apply, including EN 13428:2004 — Art. 70(1)(b) PPWR. See void fill and the minimisation duty for the empty-space side.
Design for recycling — Art. 6(2)(a): 1 January 2030 or 24 months after entry into force of the Art. 6(4) delegated acts, whichever the FAQ's reading gives you. Separate collection, sorting and large-scale recycling requirements come later still.
Features that inflate perceived volume: From 2030, double walls, false bottoms, frontal flaps and additional layers may only be used where the packaging's functionality cannot be ensured otherwise and/or where they add legitimate functionality. The operator must prove it with tests in the technical documentation — the FAQ's own wording.
How it is confirmed: By the declaration of conformity. The FAQ says the documentation must make it possible to assess the packaging's conformity with the sustainability requirements laid down in Articles 5 to 12 — and Art. 10 is one of them. That is the link between the minimisation rules and the file.
The paperwork clock behind it: 12 February 2027 for the request to update the minimisation standard, 12 February 2028 for the empty-space calculation method, 1 January 2028 for the design-for-recycling delegated acts the FAQ assumes, and 12 February 2027 for the act fixing the minimum rotations under Art. 11(2).

What we could not establish

This note rests on one official document and a handful of others, and we would rather print the edges than paper over them.

We have not read the Regulation's own text: EUR-Lex refused automated access when we tried, so every article and paragraph number here — Art. 5(1), (4) and (5), Art. 6(1), (2) and (4), Art. 10, Art. 11(2), Art. 14, Art. 15, Art. 16, Art. 17, Art. 18, Art. 38, Art. 39, Art. 68 and Art. 70(1)(b), plus Annexes VII and VIII — comes from the Commission's FAQ quoting them. Check the numbers against EUR-Lex before you rely on one, and note the FAQ's own disclaimer: it reflects the views of its authors and is not binding law.
The Commission's guidance document itself: The FAQ repeatedly refers to a separate "Notice – Guidance document for Regulation 2025/40 (EU) on packaging and packaging waste", published in March 2026. We could not open that document when writing this page, and nothing here is sourced to it. Where the FAQ points into it, we say so instead of paraphrasing it.
The interim recyclability benchmark: The claim that manufacturers should meet the recyclability requirement through the old Directive's rules and EN 13430:2004 is not what the FAQ says as we read it — the FAQ puts the old standards at guidance level and expressly removes the presumption of conformity. If a Commission guidance document directs otherwise, we have not seen it; treat the point as open.
Whether Art. 14 needs its own paperwork: We found no statement on whether an environmental claim under Art. 14 requires a declaration of conformity, or only an analysis in the technical documentation. The FAQ supports the analysis; the rest is open.
The date tension on Art. 6(1): The FAQ's own two answers do not line up: the application-date rule makes the general date (12 August 2026) govern Art. 6(1), while the answer on manufacturers' obligations defers the Art. 38 recyclability assessment to two years from the delegated act. We have printed both rather than picking the convenient one. Which one a market surveillance authority will apply to a file handed over today, we cannot say.
The feature behind this note: A Polish environmental-law publication, Sozosfera, published an analysis on 5 October 2026 setting out which PPWR requirements should already be reflected in the technical documentation since 12 August 2026. We could not read the article body — the site serves scripts rather than text to our tools — so nothing on this page is sourced to it, and the two claims we could check against the FAQ are marked above as unverified.

Known traps

"My supplier's test report is my technical documentation"

It is an input. Art. 17 means the technical documentation cannot be delegated, and the manufacturer stays legally responsible whatever any contract says. Suppliers only have to hand you the information in Art. 16(1).

"One declaration covers my whole shop"

No. It is drawn up per packaging type, at the level where the packaging shares the same characteristics — and where the packaged product differs, the FAQ says you should not draft a single declaration for everything.

"Recyclability is live, so I need the test now"

The Art. 38 assessment for recyclability is the one the FAQ defers to two years from the design-for-recycling delegated act under Art. 6(4), tentatively 1 January 2030. Commissioning a test now is a choice, not a deadline.

"PFAS is banned in all packaging since August"

Two corrections. The limits in Art. 5(5) apply to food-contact materials, and the PPWR sets maximum concentration levels rather than a ban. They do cover inks, varnishes, glues and adhesives in that packaging unit.

"Minimisation has been live since 12 August 2026"

It has not. Art. 10(1) and (2) apply from 1 January 2030, and until 31 December 2029 the Directive 94/62/EC minimisation rules continue to apply under Art. 70(1)(b).

"I'm tiny, so none of this reaches me"

The manufacturer obligations apply from 12 August 2026 and there is no general small-business exemption. The microenterprise references in the FAQ are narrow exceptions in specific places — most notably where a supplier is treated as the manufacturer because the manufacturer is a microenterprise in the same Member State.

"A licence number proves the exemption"

Whether it is Art. 10 minimisation exemptions or an Art. 6 or Art. 7 exemption, the FAQ's line is the same: the existence and the conditions have to be assessed and evidenced in the technical documentation. A number is not the evidence.

"It's only a claim, not a compliance issue"

Art. 14 is a legal requirement for properties the PPWR regulates, and the wording has to be exact about what the claim covers. A claim that merely restates the legal minimum is not allowed.

Sources

One official document does nearly all the work, and we name the chapter each claim comes from rather than citing it as a lump.

European Commission — PPWR Frequently Asked Questions, 2nd edition (KH-01-26-068-EN-N), August 2026 Official: DG ENV Unit B01. Read in full for this page, from the copy we mirror and describe here. Chapter III question 5 on suppliers having to give the manufacturer what it needs to draft the declaration of conformity under Article 5; questions 10 to 12 and 15 on the heavy-metal measurement, the general SoC duty and heavy-metal limits applying to all packaging from 12 August 2026, the PFAS limits applying to food-contact materials only, and PFAS being concentration limits rather than a ban; chapter IV question 8 on packaging placed on the market before the design-for-recycling acts; chapter V question 4 on Article 14 claims covering the unit, a part of it or all packaging placed on the market over a calendar year, and on compliance being documented regardless; chapter VII questions 1 and 2 on Article 10(1)–(2) applying from 1 January 2030, the old Directive's essential requirements until the end of 2029 via Article 70(1)(b), EN 13428:2004, and the tests and technical documentation a minimisation exemption needs; chapter IX question 1 on claims having to go beyond the minimum requirements and on the specific rule prevailing over the unfair commercial practices rules; chapter X questions 1, 2, 9, 10 and 11 on the manufacturer also being importers' and distributors' obligation, the manufacturer being the sole legally responsible operator, the technical documentation not being delegable, the 5- and 10-year retention periods, the application-date list (recyclability, recycled content, minimisation, reuse and the Article 11(2) act due by 12 February 2027) and the importer's duties from 12 August 2026; chapter XIII question 1 on reusable packaging design and rotations being evidenced in the technical documentation; chapter XV questions 1, 3, 5, 6, 7, 9, 10, 12 and 14 on the general application date for the conformity assessment, the meaning of "type", one declaration per packaging unit, mandatory documentation for Article 6 and Article 7 exemptions, the choice of type, batch or serial number, the old harmonised standards being guidance only with Article 70(1)(b) as the sole presumption-of-conformity exception, the declaration being drawn up per packaging type and covering Articles 5 to 12, the recyclability grade going into the file before placing on the market with penalties under Article 68, and the language of the declaration. Note its own disclaimer: it reflects the views only of its authors and is not binding law
European Commission, DG Environment — Packaging waste Official. Read for this page. Regulation (EU) 2025/40 in force since 11 February 2025 with 12 August 2026 as the application date; the old Directive 94/62/EC generally repealed on 12 August 2026 with some provisions continuing; and the page's own listing of the implementation resources — guidelines for economic actors and Member States of March 2026 and the FAQ of August 2026
Regulation (EU) 2025/40 (PPWR) — EUR-Lex The governing text, and what the FAQ interprets. We could not open it when writing this page — EUR-Lex declined our requests — so article, paragraph and annex numbers here trace back to the FAQ quoting them. Where the two disagree, this is what governs
Commission Notice — Guidance document for Regulation 2025/40 (EU) on packaging and packaging waste, March 2026 Official, and the document the FAQ keeps pointing into. We could not open it, so we list it as the place the FAQ's cross-references sit and source nothing on this page to it
Sozosfera — Polish environmental-law publisher, article of 5 October 2026 Secondary, and the report that prompted this note. We could not read its body — the site serves scripts rather than text to our tools — so nothing here is sourced to it. The summary that reached us put Art. 6(1) as applying from 12 August 2026 with the Art. 6(4) deferral, the minimisation duty at 1 January 2030 with the old Directive running to 31 December 2029, and an interim benchmark of the old Directive's rules plus EN 13430:2004. The first two are consistent with the FAQ; the third is not, as far as we can read it

Help us keep this page honest

What would improve this page most is one real declaration of conformity from a small seller — not the commercial template, the actual document you ended up with, and what it took to produce. If you have been through an Art. 38 assessment and a market surveillance authority has looked at it, we would rather report your file than the FAQ's intentions.

Tell us on Discord The Commission's PPWR FAQ Void fill and the 2030 cap Manufacturer or producer?

The PPWR technical file: the declaration of conformity and the technical documentation