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) and the EU Commission Guidance of March 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 and EU Commission Guidance C(2026) 2151 of March 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.
Who is the "manufacturer" under PPWR, and how is the role determined?
The manufacturer is the legal entity that places packaging on the EU market under its own name or trademark (Art. 3(14)). The decisive criterion is not who produces - but whose name or trademark appears on the packaging. This means: if your brand is on the packaging, you are the manufacturer. If packaging is unbranded and imported, the EU importer takes on the manufacturer role (Art. 44(4)).
Can the manufacturer role be transferred contractually?
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.
In a private label arrangement, who is the manufacturer?
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.
What happens when packaging is imported from outside the EU?
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.
What are the obligations of distributors and wholesalers?
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.
Does a single DoC cover all EU Member States?
Yes. A single DoC is valid across all EU Member States - no separate document is required per country or per customer. The DoC must be available in a language understood by the requesting surveillance authority. That is a translation obligation, not a requirement to issue separate declarations.
Does PPWR apply to intra-group supply chains - e.g. a German HQ importing from its own Asian factory?
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.
What is a "packaging type" - and does one DoC cover multiple SKUs?
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.
Is a grouping like "Primary Packaging – Polyethylene" sufficient?
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.
Is a DoC per SKU acceptable?
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.
Should each packaging component (bottle, label, outer box, film) have its own DoC?
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.
What must a DoC contain - and is there an official template?
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:
Must the DoC be shared with customers on every order?
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.
Must the DoC be translated into the language of each Member State?
The PPWR does not impose a mandatory language requirement for the DoC itself. It must be provided to authorities in the language required by the Member State where market surveillance takes place (Art. 38(9)) — a translation obligation on request, not a requirement to issue multiple declarations.
Can one DoC cover multiple EU regulations simultaneously?
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.
Can conformity be declared when packaging is not yet recyclable?
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. Until then, you declare conformity with the requirements that are in force — and must not make recyclability claims you cannot substantiate.
What must the Technical Documentation (TeDo) contain?
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.
How long must the TeDo be retained?
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.
Is a supplier's self-declaration sufficient to prove substance compliance — or are laboratory tests required?
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.
Is it enough for a supplier to state "not intentionally added" for PFAS?
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.
Do adhesives in cartons need to be declared in the TeDo?
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.
Which substance restrictions apply from 12 August 2026?
From 12 August 2026, Art. 5 applies to all packaging types placed on the EU market:
Are SVHCs and CMR substances (categories 1A/1B) also restricted from August 2026?
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.
What are the PFAS thresholds - and how stable is the current regulation?
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 ppm total fluorine. The 50 ppm threshold acts as a screening gate - if total fluorine content is below 50 ppm, the material can be considered compliant without further testing. The regulatory picture may evolve through delegated acts (Art. 5(5)).
What labelling is required from 12 August 2026?
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.
Will PPWR labelling replace existing SUP and national recycling labels?
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.
Do cartons need a printed conformity mark?
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.
What applies from 12 August 2026 - and what comes later?
From 12 August 2026:
Key upcoming milestones:
Is there a transition period for packaging already in stock on 12 August 2026?
The PPWR does not include an explicit sell-through period for non-compliant packaging already in stock. The obligation attaches to packaging "placed on the market" — packaging manufactured and released before the applicable date is generally considered already placed on the market. There is no guaranteed legal grace period.
Does PPWR apply to B2B packaging?
Yes. There is no B2B exemption. Secondary and transport packaging used in B2B supply chains is fully within scope — DoC, TeDo, and substance restriction obligations apply equally.
Does PPWR apply to transport packaging such as pallets, stretch film, and pallet corners?
Yes. All transport packaging is within scope with no planned exemptions. DoC and TeDo obligations apply to all packaging types from 12 August 2026.
Do existing EN standards (EN 13428, 13430, 13431, 13432) give a presumption of conformity under PPWR?
Not yet. These standards were developed under the previous Packaging and Packaging Waste Directive (PPWD) and have not been formally harmonised under PPWR. They 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.
When will PPWR-specific harmonised standards be published?
No confirmed date has been announced. The Commission has mandated CEN to develop harmonised standards under PPWR, but the process typically takes 2–4 years. 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.
What are the consequences of non-compliance with DoC and TeDo obligations?
Penalties are determined by Member States. The PPWR (Art. 68) requires effective, proportionate, and dissuasive measures — without setting EU-level fines. Under Germany's draft Verpackungsrecht-Durchführungsgesetz (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.
Must the TeDo be submitted to authorities?
No. The TeDo is not submitted proactively. It must be retained for 5 (single-use) or 10 (reusable) years and made available to market surveillance authorities within 10 days of a request (Art. 38(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) and EU Commission Guidance C(2026) 2151 (March 2026). It reflects the regulatory framework as of June 2026. Implementing acts and harmonised standards are still being developed — monitor the EU Official Journal for updates.
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