The Packaging and Packaging Waste Regulation (EU 2025/40) enters into application on 12 August 2026. For any company placing packaging on the EU market, the practical question between now and that date is whether the technical documentation and Declarations of Conformity required by the Regulation can be produced, evidenced, and stood behind for every relevant packaging type.
This is substantial work, and many businesses are already well along the path. In this article, we look at what the Regulation requires, why the question of value chain role has become more pressing following the European Commission’s recent Guidance Notice, and how to approach the data collection that underpins both the Technical Documentation and the Declaration of Conformity.
Establish your role in the value chain
The Commission’s Guidance Notice and accompanying FAQs, issued earlier this year, have helpfully sharpened a question that many companies had been working through informally. For any given packaging item, who is the manufacturer, who is the importer, who is the distributor, and who is the fulfilment service provider?
The answer is rarely obvious. A company that designs its own retail packaging but contracts production to a converter, a brand that imports finished packaged goods from outside the EU, an online retailer that holds stock on behalf of third-party sellers, all carry different PPWR obligations, and those obligations attach to different parties in different ways.
The Commission’s guidance makes clear that companies are expected to take a position on their role for each packaging item they handle, and it helps to agree that position with their customers and suppliers. Where two parties disagree about who carries which obligation, neither can rely on a clean compliance position. Role determination is therefore a conversation that needs to be had, documented, and reflected in commercial arrangements. For most companies, this work needs to be done before, or in parallel with, the documentation work that follows from it.
What PPWR Technical Documentation requires
Article 38 of PPWR sets out the conformity assessment procedure, and Annex VII describes the content of the Technical Documentation that supports it. The documentation must demonstrate that the packaging meets the substantive requirements of the Regulation, including those relating to recyclability (Article 6), recycled content for plastic packaging (Article 7), compostability where claimed (Article 9), minimisation (Article 10), and the restrictions on substances of concern (Article 5).
The Technical Documentation is prepared per packaging type, not per batch. A packaging type is identified by stable references such as product codes or SKUs, and the documentation remains valid until the design or material composition of that type changes. Where a change occurs, a new technical file and a new PPWR Declaration of Conformity are required.
The content of the file is substantial. It covers the design specification, the materials used (with quantities, percentages of recycled content where relevant, and supplier evidence), the results of any testing carried out, and the reasoning that supports each compliance claim. Much of this information already exists within manufacturing, procurement, and product teams. The work is in locating it, verifying it, and structuring it in a form that can be presented to a market surveillance authority on request.
What the PPWR Declaration of Conformity requires
The Declaration of Conformity is required by Article 39 and detailed in Annex VIII. It is the formal, signed statement that a particular packaging type meets all applicable PPWR requirements, drawn from the underlying Technical Documentation.
Like the technical file, the Declaration is issued per packaging type and remains valid until a triggering change occurs. It identifies the packaging by its stable reference, names the responsible party, lists the applicable provisions of the Regulation, and is signed on behalf of the manufacturer or the manufacturer’s authorised representative.
The Declaration itself is shorter than the Technical Documentation that sits behind it, but it is only as reliable as the file it draws from. Most of the practical work in preparing for 12 August lies in the Technical Documentation and the Declaration is the visible output of that work.
How to prepare for 12 August 2026
For companies that have not yet completed this work, the remaining time is enough to make meaningful progress, particularly if effort is concentrated in the right places.
A workable sequence is to begin with an inventory of every packaging type placed on the EU market, including primary, secondary, and transport packaging where relevant. For each type, the role question is settled with customers and suppliers, and the responsible party is recorded. The data requirements of Annex VII are then mapped against what is already known, and the gaps are identified. From that point, most of the remaining work is a matter of engaging suppliers for the missing information, verifying what is returned, and assembling the file in a consistent format that will support both the PPWR Declaration of Conformity and any subsequent market surveillance enquiry.
The companies we work with vary widely in the maturity of their packaging data and in the complexity of their portfolios. The work is more discrete for a focused product range than for a multi-category retailer, but the structure of the task is the same in both cases.
PPWR Frequently Asked Questions
When does PPWR apply?
PPWR (Regulation EU 2025/40) enters into application on 12 August 2026 for the majority of its obligations.
Is the PPWR Declaration of Conformity issued per packaging type or per batch?
Per packaging type. A type is identified by stable references such as product codes or SKUs, and the Declaration remains valid until the design or material composition of that type changes.
Who signs the PPWR Declaration of Conformity?
The manufacturer or the manufacturer’s authorised representative, under Article 39 of PPWR.
What goes into PPWR Technical Documentation?
The content is set out in Annex VII and covers the design specification, the materials used, recycled content evidence, any testing results, and the reasoning supporting each compliance claim.
When must a new Declaration of Conformity be issued?
When the design or material composition of the packaging type changes. The change triggers a new technical file and a new Declaration of Conformity.
What to do between now and August
For companies that have not yet completed this work, the remaining time is enough to make meaningful progress, particularly if effort is concentrated in the right places.
A workable sequence is to begin with an inventory of every packaging type placed on the EU market, including primary, secondary, and transport packaging where relevant. For each type, the role question is settled with customers and suppliers, and the responsible party is recorded. The data requirements of Annex VII are then mapped against what is already known, and the gaps are identified. From that point, most of the remaining work is a matter of engaging suppliers for the missing information, verifying what is returned, and assembling the file in a consistent format that will support both the Declaration of Conformity and any subsequent market surveillance enquiry.
The companies we work with vary widely in the maturity of their packaging data and in the complexity of their portfolios. The work is more tractable for a focused product range than for a multi-category retailer, but the structure of the task is the same in both cases.
How Jordisk can Help
Whether you are still working through the role question with your trading partners, or building out a documentation programme across a complex packaging portfolio, we would be glad to help.
Jordisk offers a free impact assessment that gives you a clear view of where you stand against the PPWR obligations relevant to your business. From there, we can support the work of determining your role in the value chain for each packaging type, communicating that position to customers and suppliers, and collecting, verifying, and structuring the information needed to satisfy your Technical Documentation and Declaration of Conformity obligations under Articles 38 and 39.
If 12 August feels close, that is because it is. The work is achievable from where most companies sit today, provided focused effort is applied in the right order. Contact us to discuss how we can help.
