PPWR, DoC, TeDo – the questions that packaging professionals are grappling with right now are concrete and urgent. This article answers the most important questions on the Declaration of Conformity and Technical Documentation – based on the PPWR (EU 2025/40), EU Commission Guidance C(2026) 2151 of March 2026, and the Commission's official PPWR FAQ, 2nd edition (August 2026).
From 12 August 2026, the core obligations of the PPWR (Regulation (EU) 2025/40) apply to all packaging placed on the EU market. For many companies, the same questions keep coming up: Who exactly is the manufacturer under PPWR? What must go into the Declaration of Conformity (DoC)? How detailed does the Technical Documentation (TeDo) need to be — and what level of evidence is actually sufficient?
This article answers the most important questions on roles and responsibility, documentation obligations, substance restrictions, timelines, and enforcement – based on the PPWR, Commission Guidance C(2026) 2151 (March 2026) and the Commission's PPWR FAQ, 2nd edition (August 2026).
Disclaimer: This article provides general information and does not constitute legal or compliance advice. Parts of the regulatory framework are still being developed — in particular, implementing acts and harmonised standards remain outstanding. For binding determinations, we recommend consulting qualified legal or compliance advisors.
The manufacturer is the legal entity that places packaging on the EU market under its own name or trademark (Art. 3(1)(13)). The decisive criterion is not who produces — but whose name or trademark appears on the packaging, or, where no name or trademark appears, who places the order and decides the specifications. This means: if your brand is on the packaging, you are the manufacturer.
The role is determined at the stage where the empty packaging has reached its final form, meaning it is usable without adding further components. A flat cardboard box that still needs folding has reached its final form. Stretch wrap sold on a roll is packaging even if it is cut later. For unbranded transport packaging, the manufacturer is the physical producer; for branded packaging, it is the trademark holder. Adding a shipping sticker does not count as branding.
No. The role attaches by law to the facts – it cannot be transferred, refused, or reassigned through a commercial agreement. Suppliers cannot be made liable for a customer's PPWR obligations, but under Art. 16 they must supply the manufacturer with all information and documentation needed to demonstrate conformity, and they cannot refuse.
Name and trademark carry equal weight. Where they point to different entities, manufacturer status goes to whoever determines the design and specifications — assessed case by case on the basis of the contract. The same logic applies to custom-made transport packaging with no marking at all: the manufacturer is whoever places the order and decides the specifications.
Where the entity that would otherwise be the manufacturer is a micro-enterprise and the supplier is established in the same Member State, the supplier becomes the manufacturer. Note this does not extend to EPR: there is no general micro-enterprise exemption from registration and reporting, though lighter reporting applies below 10 tonnes per year.
It depends on whose name or trademark appears on the packaging at the point of sale. In a typical private label scenario where the retailer's brand is on the finished packaging, the retailer is the manufacturer. Physical production, material selection, or design authority do not override this.
The EU-established entity that places the packaging on the market – the importer – is the responsible party. If the importer places the packaging under its own name or trademark, or modifies it in a way affecting conformity, it becomes the manufacturer under Article 21 – with full DoC and TeDo obligations. This catches most own-brand and private-label importers. Even where the importer does not become the manufacturer, it must verify that the third-country manufacturer carried out the conformity assessment and drew up the DoC, that the Art. 15(5)-(6) identification requirements are met, and that the documents accompany the packaging. Importers must also indicate their own contact details — on the packaging or on an accompanying document — including for imported generic or unbranded packaging.
No. Goods in transit towards a third country that are not released for free circulation and not placed on the EU market fall outside the PPWR.
Distributors who do not place packaging under their own name and do not modify it are not required to establish a DoC. Their duty is one of due diligence (Art. 19): verify that required labelling and markings are present, check EPR registration, keep non-conforming packaging off the market, and cooperate with market surveillance authorities. If a distributor rebrands packaging or places it on the market under their own name, they become the manufacturer under Article 21 — with full obligations.
Yes. A single DoC is valid across all EU Member States – no separate document is required per country or per customer. But Art. 39(2) requires the DoC to be drawn up in, or translated into, the language(s) required by the Member State where the packaging is placed or made available on the market.
Yes. Internal group structures do not exempt from PPWR obligations. When packaging is imported into the EU — even from an affiliated entity — and placed on the market under the EU entity's own name or trademark, that entity becomes the manufacturer under Article 21, with full DoC and TeDo obligations for all packaging types involved, including transport packaging.
Packaging you produce in-house and use to ship between your own sites has not been placed on the market — there is no commercial transaction — and is not subject to the PPWR. The picture changes if you use transport packaging you did not manufacture yourself for those internal shipments: that packaging is deemed placed on the market and the PPWR applies.
A DoC is required per distinct packaging specification, not per SKU or product. Packaging units that share the same material composition, structural design, functional characteristics, and compliance profile can be grouped under a single DoC. Multiple SKUs can reference the same DoC where the underlying packaging specification is truly identical. Note that "type" in Annex VII is not the same as the packaging "types" listed in Annex II - it refers to each format, batch or series, not to the material category.
No - a generic material label is too broad to group on. Factors such as the precise polymer grade, structure, additives, inks, and any food-contact function all affect the Article 5, 6, and 10 assessments. Two items sharing the same generic label can reach different compliance outcomes and therefore require separate documentation.
A single DoC is possible where the difference in size affects none of the Articles 5–12 requirements. Where it does — for example because it changes the minimisation assessment or the recycled-content calculation — separate DoCs are needed.
Always. It is simply more conservative than needed in most cases. For organisations with a manageable number of packaging references, per-SKU documentation may even be simpler to manage. For those with hundreds of references, grouping by packaging type is both legally sound and practically necessary.
Art. 15(5) is satisfied by identification at type, batch or serial level — not necessarily every single unit and not every component. A yoghurt cup needs one marking, not one per element. Standardised items such as tapes or generic bags are traceable at batch level.
Components that are only ever placed on the market as part of an assembled packaging unit — such as a label on a bottle — are covered by the DoC of the overall packaging unit. Only components placed on the market individually require their own DoC from their manufacturer. The Commission has clarified that conformity assessment and the DoC operate at the level of the whole packaging unit: bottle plus closure plus label is one DoC, containing the information on each component. Transport packaging is the flip side of this — pallets, collars, wrappings and straps are separate units and each needs its own assessment and DoC, unless they are genuinely assembled into a new finished packaging item, in which case that item is treated as one.
The DoC is governed by Article 39 and the model in Annex VIII of Regulation (EU) 2025/40. It is a written self-declaration by the manufacturer confirming the packaging meets the requirements of Articles 5–12. Mandatory elements are:
By drawing up the DoC, the manufacturer assumes responsibility for the packaging's compliance (Art. 39(4)).
No. The PPWR does not require the DoC to be sent with every order or shipment. The binding obligation is to draw it up, keep it up to date, retain it (5 years for single-use / 10 years for reusable packaging), and make it available to market surveillance authorities on request.
Art. 39(2) does impose a language requirement: the DoC must be drawn up in, or translated into, the language(s) required by the Member State where the packaging is placed or made available on the market.
Yes. Art. 39(3) explicitly provides that where packaging is subject to more than one Union act requiring a DoC, a single combined DoC may be drawn up covering all applicable acts. Where you do this, the document must clearly distinguish the packaging from the packaged product, and the underlying assessments remain separate.
Under Art. 39(5), competent authorities are to control the accuracy of at least part of the declarations each year on a risk-based approach — not only in response to a complaint — and may withdraw non-compliant products from the market.
The DoC declares conformity with the requirements currently in force. The recyclability grading system (grades A–C under Art. 6) does not apply until 1 January 2030. In the interim, the Commission guidance confirms that manufacturers comply with the recyclability requirement under the old PPWD and harmonised standard EN 13430:2004. Until then, you declare conformity with the requirements that are in force — and must not make recyclability claims you cannot substantiate.
The TeDo is the evidence file that backs every claim in the DoC. It is drawn up under Annex VII (Module A — internal production control), held per packaging type, and must demonstrate compliance with Articles 5–12. It must contain:
The TeDo does not need to be submitted to any authority — it must be kept available and provided upon request.
5 years for single-use packaging and 10 years for reusable packaging after the packaging is last placed on the market (Art. 15(3)). On a reasoned request from a national authority, it must be made available within 10 days by manufacturers (Art. 15(10)), by importers (Art. 18(8), in electronic form) and by authorised representatives (Art. 17(2)).
The PPWR does not mandate accredited laboratory testing as the sole means of proof. A supplier declaration can be part of the evidence base — but the manufacturer bears ultimate responsibility for the accuracy of the TeDo. In practice, the strength of evidence required will depend on the risk profile of the packaging and the substance concerned.
Suppliers do not draw up your DoC, but Art. 16 obliges them to provide all information and documentation you need to demonstrate conformity, in paper or electronic form, and they cannot refuse. Where a supplier has disappeared or will not cooperate, you are expected to make best efforts: approach the former supplier, the company resulting from a merger or acquisition, or fall back on your own assessments.
Partly. By written mandate, an authorised representative (Art. 17) can keep the declaration of conformity and the technical documentation at the disposal of the national market surveillance authorities, cooperate with those authorities on any action taken against non-compliant packaging, and provide them — upon reasoned request — with all information and documentation needed to demonstrate conformity, within 10 days. The conformity assessment and the drawing-up of the DoC can likewise be carried out on the manufacturer's behalf. But two things are expressly excluded from the mandate: the Art. 15(1) duty to place only conforming packaging on the market, and the drawing-up of the Annex VII technical documentation (Art. 17(2), last subparagraph). Legal responsibility stays with the manufacturer regardless of what any contract says.
Not automatically because the operator responsible under the Food Information to Consumers Regulation and the packaging manufacturer under the PPWR may be different entities, and information supplied under one framework does not by itself satisfy Art. 15(5)-(6). Both sets of requirements have to be met.
No, not as a standalone. The PPWR requires compliance with substance thresholds — not just the absence of intent. For food-contact packaging, manufacturers should seek test data or more substantive supplier declarations covering the relevant PFAS thresholds.
Yes. All substances present in packaging must be assessed for compliance with Art. 5. There is no formal de minimis exemption in PPWR for adhesives or minor components. Adhesives must be declared in the material composition section of the TeDo, with confirmation of compliance with applicable substance restrictions.
From 12 August 2026, Art. 5 applies to all packaging types placed on the EU market and sets three distinct substance obligations:
The PPWR does not introduce specific threshold restrictions for SVHCs or CMR 1A/1B substances at that date. They are, however, caught through the first limb of Article 5: a broad obligation to minimise the presence and concentration of "substances of concern" in packaging - which applies from 12 August 2026 and must be documented in the TeDo.
Three thresholds apply to food-contact packaging from 12 August 2026: 25 ppb for any individual PFAS (targeted analysis, polymeric PFAS excluded); 250 ppb for the sum of all PFAS by targeted analysis; and 50 mg/kg for total PFAS content.
On testing, the Commission guidance sets out a stepwise enforcement approach. Step 1 is total-fluorine quantification: if total fluorine comes in below 50 mg/kg, the sample can be considered compliant. Above that, targeted analysis follows. There is still no harmonised EU methodology for PFAS in food-contact packaging.
No. The 25% recycled content requirement for PET single-use plastic beverage bottles (including tethered caps) derives from the SUP Directive (Directive (EU) 2019/904), not from PPWR. PPWR introduces its own recycled content targets (Art. 7), but these apply from 2030 and are subject to delegated acts. These are two separate regulatory obligations — both may apply to the same packaging, but they have different legal bases, timelines, and documentation requirements.
The detailed implementing acts for the harmonised recyclability labelling system under Art. 12 have not yet been finalised. Manufacturers are not yet required to apply the full Art. 12 labelling. Existing obligations — including SUP Directive labelling and applicable national recycling labels - continue to apply in parallel and are not replaced by PPWR until the implementing acts are in force.
Art. 12 PPWR will eventually establish a harmonised EU-wide recyclability label, but does not automatically repeal existing obligations. Until the implementing acts are in force and transition periods have elapsed, existing labelling requirements remain in effect.
DRS labelling is not yet harmonised. You comply with the label required by the Member State where the packaging is marketed.
No. The PPWR does not introduce a CE mark or equivalent conformity marking for packaging. The DoC is a commercial and administrative document kept on file — it does not need to be referenced on the physical packaging.
From 12 August 2026:
What is not live on that date, but often assumed to be:
Key upcoming milestones:
For stock produced before 12 August 2026, there is no obligation to destroy it, remanufacture it, or re-label it. The identifier and the manufacturer's name and address under Art. 15(5)-(6) may be supplied via an accompanying document rather than printed on the pack. And packaging already placed on the market before the cut-off may remain on the market even if it does not meet the new requirements.
What this does not give you is a grace period for new packaging: anything placed on the market from 12 August 2026 must comply.
Yes. There is no B2B exemption — DoC, TeDo, and substance restriction obligations apply equally.
Yes. All transport packaging is within scope with no planned exemptions. DoC and TeDo obligations apply to all packaging types from 12 August 2026.
Mostly not — with one carve-out worth knowing. These standards were developed under the previous Packaging and Packaging Waste Directive (PPWD) and have not been formally harmonised under PPWR. Under the PPWR they serve only as guidance, and EN 13428:2004 specifically no longer creates a presumption of conformity for substances of concern, because the PPWR's scope is broader — lifecycle, REACH SVHCs, CLP classes and recyclability impacts. The carve-out: for the transitional PPWD minimisation duty, EN 13428:2004 keeps its presumption effect until the end of 2029 (Art. 70(1)(b)). Outside that carve-out, the standards remain valid methodological tools — but must be documented as technical methods, not as standards conferring a presumption of conformity. The distinction matters for how references are framed in the DoC and TeDo. The presumption is restored once new standards are cited in the Official Journal.
No confirmed date has been announced. The PPWR obliges the Commission to request CEN to update EN 13428:2004 by 12 February 2027 — adding an updated assessment method plus maximum adequate weight and volume limits for the most common packaging types and formats. In the interim, the EN 13428–13432 series and Commission Guidance C(2026) 2151 provide the best available technical framework. Documentation should be structured to be updatable once harmonised standards are published.
Enforcement under Art. 62 is designed to be non-punitive in the first instance: authorities should support operators, issue a warning and allow a reasonable timeline to correct, with sanctions such as withdrawal or recall following only where the non-compliance persists. The stated aim is not to disrupt trade flows.
Penalties themselves are determined by Member States. The PPWR (Art. 68) requires effective, proportionate, and dissuasive measures — without setting EU-level fines. Under Germany's VerpackDG, fines of up to €10,000 for minor breaches, up to €100,000 for standard violations, and up to €200,000 for serious or repeated violations are referenced — alongside the possibility of a market ban. Missing or inadequate DoC/TeDo is itself a violation subject to penalty once the correction window has passed.
No. Manufacturers do not need to notify authorities that they are compliant — the authorities will make contact if they carry out a check. The duty to inform arises only where you identify non-compliance yourself (Art. 15(8), Art. 19(5)).
No. The TeDo is not submitted proactively. It must be retained for 5 (single-use) or 10 (reusable) years (Art. 15(3)) and made available to market surveillance authorities within 10 days of a request (Art. 15(10)). There is no central EU registry or portal for DoC or TeDo submission under PPWR.
This article is based on Regulation (EU) 2025/40 (PPWR), EU Commission Guidance C(2026) 2151 (March 2026) and the Commission's PPWR Frequently Asked Questions, 2nd edition (August 2026). It reflects the regulatory framework as of August 2026.
Implementing acts and harmonised standards are still being developed — monitor the EU Official Journal for updates.
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