What the official text says
Articles 38 and 39 and Annex VII — Regulation (EU) 2025/40
Each manufacturer must draw up an EU declaration of conformity for every packaging format placed on the market and compile the corresponding technical documentation. The documentation must be available to market surveillance authorities on request.
What it really means
The PPWR introduces a documentary regime modelled on EU product regulations. Each packaging format becomes a regulated product with its own file. This is a new obligation with no equivalent in Directive 94/62/EC, which it replaces.
The notion of manufacturer is broader than people think. A company that has its packaging designed or made by a subcontractor and sells it under its own brand is treated as a manufacturer under the PPWR, even if it produces nothing physically itself. The brand owner carries responsibility for the file. That is the case for the vast majority of food and drink producers in France.
The March 2026 guidance clarifies that, where several regulations apply at once — for example the PPWR and the food-contact regulation simultaneously — a combined declaration is permitted, provided that each applicable regulation is explicitly named in the document.
Area of uncertainty as it stands
Standardised templates for the declaration of conformity are to be published by the Commission through implementing acts, the date of which is not yet known. In the meantime, build your own format while respecting the minimum content set out in Annex VII. The required retention period is not yet specified; apply a minimum of ten years as a precaution.
Impact by sector
How to prepare
To do now
Identify the company's legal status: manufacturer, producer, importer or distributor
List every packaging reference placed on the EU market
Short-term actions
Compile the minimum technical file for each reference
Put in place the documentary system for storage and versioning
Ongoing
Update the files whenever a formulation or supplier changes
Pass the documentation on to any link in the chain that requests it
Is your situation more complex? Get an action plan tailored to your plant's constraints
See the available tools