From 12 August 2026, the PPWR will require manufacturers to support the EU declaration of conformity with robust technical documentation built across the packaging supply chain. The declaration will initially cover requirements already in force, including substance limits, and will expand as recyclability and labelling obligations become applicable
While public debate continues to focus on the future of six-bottle water multipacks or single-serve ketchup sachets — neither of which will disappear entirely, nor in the immediate future — companies affected by the overhaul brought about by the EU Packaging and Packaging Waste Regulation will face far more significant and complex changes from 12 August 2026. One of the most demanding from an operational standpoint will be the EU declaration of conformity: the document through which the manufacturer must formally assume responsibility for ensuring that packaging placed on the market complies with the applicable requirements of Regulation (EU) 2025/40, commonly known as the PPWR.
This is neither a voluntary environmental certification nor a new mark to be placed on packaging. The declaration is the formal outcome of the conformity assessment procedure established by the PPWR and must certify compliance with the requirements applicable at the time the packaging is placed on the market. From 12 August 2026, for example, this will include limits on substances present in packaging — including PFAS — while other specifications will follow at a later stage.
This is where the issue becomes more complex. The declaration itself may run to only a few pages, but signing it will require an extensive documentary basis, including information on materials, design specifications, checks, analyses, test results and data supplied by upstream operators. As Donata Gammino of CONAI’s Centre for Circular Economy Studies explains, “the declaration of conformity is only the tip of the iceberg”. The most demanding part lies below the surface, in the body of technical evidence needed to substantiate what the manufacturer states in the final document.
The central figure in the new system is therefore the manufacturer, a role that under the PPWR does not necessarily coincide with the company that physically produces the packaging. The regulation defines the manufacturer as the natural or legal person that manufactures packaging or a packaged product, or has it designed or manufactured, and markets it under its own name or trademark. This means that, in many cases, responsibility may fall on the brand owner or on the company commissioning the packaging and determining its specifications, even where physical production is outsourced to a third party.
On this point, the European Commission’s FAQs — released a few days ago in an updated version — place particular emphasis on the decision-making chain governing the packaging’s characteristics. They clarify, for example, that the information provided along the supply chain must enable the manufacturer, among other things, to identify the possible presence of PFAS or other substances of concern and to demonstrate compliance with the requirements of Article 5.
In other words, it will be the manufacturer’s responsibility to ensure that the packaging has been designed and produced in accordance with the applicable provisions, to carry out or commission the conformity assessment procedure, to prepare the technical documentation and to sign the EU declaration of conformity. By signing it, the manufacturer will assume legal responsibility for the packaging’s compliance.
Although formal responsibility rests with one operator, compliance will inevitably have to be built collectively. “Compliance is not exclusively the manufacturer’s responsibility”, but “the result of a process involving the entire packaging supply chain,” Gammino notes. The manufacturer will only be able to fulfil its obligations if suppliers and other upstream operators provide adequate data, information and documentation.
For companies, this creates an organisational challenge before it becomes a legal one. They will need to determine what information should be requested from suppliers, how its reliability should be assessed, where it should be stored and how it should be linked to a specific packaging type. The information may also include formulas, compositions, manufacturing-process characteristics and other elements protected by confidentiality or industrial know-how. According to the approach outlined by CONAI, data exchange will therefore need to be supported by appropriate confidentiality mechanisms, capable of reconciling the need to demonstrate compliance with the protection of sensitive information.
The technical basis of the system is set out in Annex VII to the PPWR, which governs internal production control. The regulation does not provide a pre-completed form to be adapted, but rather a binding framework in terms of content. The document must be numbered and include a reference enabling the packaging covered by the assessment to be identified unequivocally. It must also contain the manufacturer’s details, a statement of sole responsibility, a description of the packaging sufficient to ensure traceability, references to the regulation and any other applicable legislation, the technical specifications used and, where relevant, information on the involvement of third parties.
The content of the declaration will evolve over time. While from 12 August 2026 particular attention will have to be paid to the requirements of Article 5 concerning substances present in packaging, the PPWR includes numerous obligations with staggered application dates and, in some cases, implementation dependent on delegated acts, implementing acts and new technical specifications. This is the case, for example, with the new harmonised labels on material composition, which will not apply before 2028, and with design-for-recycling requirements, which will become binding from 2030.
As regards substances, the regulation confirms the combined limit for lead, cadmium, mercury and hexavalent chromium and introduces specific thresholds for PFAS in food-contact packaging. This latter requirement raises significant procedural questions, since there is not yet an established and codified methodology for measuring the presence of so-called “forever chemicals”. From the same date, the general obligation to minimise the presence and concentration of substances of concern in packaging will also apply, although the technical framework will still require further development. The use of laboratories, certification bodies or other independent organisations, Gammino points out, “is an option, not a requirement”.
The declaration must conclude with the place and date of issue, the name and position of the authorised person and their signature. The regulation also establishes specific retention obligations. The declaration and the technical documentation must remain available to the authorities for five years after single-use packaging has been placed on the market and for ten years in the case of reusable packaging.
Following a reasoned request, the manufacturer must provide the national authorities with all the information and documents needed to demonstrate conformity. Market-surveillance authorities will be able to verify the accuracy of the declarations and request access to the evidence supporting them. In the event of formal non-compliance affecting the declaration, the authority must first require the economic operator to put an end to the irregularity. If the non-compliance persists, the Member State must take appropriate measures to prohibit the packaging from being made available on the market or to ensure that it is withdrawn or recalled.
The regulation does not establish a predetermined EU-wide financial penalty for an omitted or irregular declaration. Article 68 requires Member States to lay down effective, proportionate and dissuasive penalties by 12 February 2027. In Italy, therefore, the amounts and any additional administrative consequences will have to be assessed in light of the national implementing provisions.
Where the packaging itself is substantively non-compliant, operators may also be required to take corrective measures and, where provided for, withdraw or recall it from the market. Following a reasoned request from the national authority, the manufacturer must make available the information and documentation necessary to demonstrate conformity.
“Our advice to companies is not to start from the declaration of conformity, but from collecting the information needed to complete it,” Gammino says. At least in its first phase of application, the real impact of the PPWR may therefore be felt less on supermarket shelves than in technical departments, laboratories, supply contracts and corporate information systems. Water multipacks and ketchup sachets may continue to dominate public debate. For businesses, however, the more urgent challenge will be played out below the surface: building the evidence needed to demonstrate that every packaging type placed on the market is genuinely compliant.
