PPWR Declaration of Conformity Template and Builder
PPWR DoC = Annex VIII model · Article 39 obligation · retain 5 years (single-use) / 10 years (reusable).
Free Annex VIII template: complete the draft fields below, then download the declaration as an editable Word .docx, as plain text, or print it to PDF. No sign-up, no email wall.
Document structure, appointment and retention checked 2026-09-11 · Application date 2026-08-12
Annex VIII declaration of conformity template builder
Annex VIII · Art. 39
Specimen · 2026-08-12 application date
DRAFT — review evidence, applicable legislation and required languages before signature.
EU Declaration of Conformity No [Declaration number]
Regulation (EU) 2025/40 (PPWR) — Annex VIII model (Art. 39)
1. Unique identification of the packaging: [Packaging unit ID / SKU / GTIN]
2. Manufacturer: [Manufacturer name]
Address: [Postal address]
Appointed authorised representative, where applicable: [provide name and address if appointed; otherwise remove this line]
3. This declaration is issued under the sole responsibility of the manufacturer.
4. Object of the declaration: [Describe the packaging for traceability; include drawing or photograph references where useful]
Packaging type: [packaging type]; role: [packaging role].
5. [Issuer must confirm and evidence conformity with the applicable requirements of Regulation (EU) 2025/40 before making this statement.]
6. Standards, common specifications or other technical specifications used: [Identify the references actually used and their dates/versions]
7. Notified body, where applicable: [Name, address, number, intervention and certificate details; or confirm not applicable]
8. Additional information: [Add supporting technical-file references or other information as appropriate]
Market(s) for language review: [market(s)].
Signed for and on behalf of: [Manufacturer name]
Place and date of issue: [place], [valid YYYY-MM-DD]
Name and function: [name], [function]
Signature: [to be signed by the authorised signatory after review]
Draft preparation notes (remove after review): check the Annex VII technical documentation (Art. 38), other applicable Union acts, and the language(s) required by the destination member state(s) (Art. 39(2)). Keep the declaration updated.
Retention: 5 years from the date the packaging is placed on the market (Art. 15(3) and Annex VII point 4; single-use packaging). This is not calculated from the signature date.
Filling this form does not establish conformity or verify supporting evidence.
The file is built in your browser — nothing you type is uploaded, and there is no email wall. Retain 5 years from the date the packaging is placed on the market, per Art. 15(3) (single-use packaging).
Free PPWR declaration of conformity template — the Annex VIII model
The builder above is the template. It reproduces the model declaration set out in Annex VIII of Regulation (EU) 2025/40 — the eight numbered points plus the signature block — and expands them into a practical field checklist. Optional administrative details are separate from the declaration model. Leave a field blank and it stays as a bracketed placeholder, so what you take away is a genuine fill-in-the-blanks template rather than a half-empty document.
Use the buttons under the specimen to download a blank or completed draft. Review your evidence, applicable legislation and languages before signing; field completion does not establish conformity:
Word (.docx) — an editable document you can drop on your letterhead, translate, and sign. Opens in Word, Google Docs and LibreOffice.
Plain text (.txt) — for pasting into a quality management system, a supplier portal or an existing DoC shell.
PDF — choose Print / save as PDF; the print stylesheet strips the page down to the declaration itself.
Clipboard — Copy specimen text for a one-click paste.
The template is assembled in your browser. Nothing you type is uploaded, there is no sign-up and no email wall, and the file is generated locally rather than fetched from a server.
One declaration covers one packaging: Annex VIII point 1 asks for a unique identification and point 4 for a description allowing traceability, so each distinct packaging format needs its own template instance — while Article 39(3) lets you draw up a single declaration where the packaging falls under several Union acts. Keep the signed declaration with the Annex VII technical documentation for 5 years (single-use) or 10 years (reusable) from placement on the market (Art. 15(3)). This is a document template, not legal advice.
Free PPWR declaration of conformity template: fill the Annex VIII model of Reg (EU) 2025/40 online, then download the editable Word file or print to PDF.
PPWR DoC = Annex VIII model · Article 39 obligation · retain 5 years (single-use) / 10 years (reusable).
Under the EU Packaging and Packaging Waste Regulation (Reg (EU) 2025/40, PPWR) the model Declaration of Conformity is set out in Annex VIII, and the manufacturer's obligation to draw it up in writing is Article 39. The declaration states that fulfilment of the requirements laid down in or pursuant to Articles 5 to 12 has been demonstrated, and is supported by the Annex VII technical documentation prepared under the Module A internal-production-control route of Article 38.
The DoC and supporting technical documentation must be retained for 5 years for single-use packaging and 10 years for reusable packaging, starting when the packaging is placed on the market (Article 15(3)). Use the language(s) required by the destination member state(s) (Article 39(2)). General application began on 12 August 2026; individual requirements have phased dates.
11Issuer confirms applicable requirements are evidencedArt. 39(1) · Annex VIII §5
12Standards / technical specifications usedAnnex VIII §6
13Market(s) for language reviewArt. 39(2)
14Signatory name, role, place and valid dateAnnex VIII signature block
15Description allowing traceabilityAnnex VIII §4
16Notified body details or confirmed non-applicabilityAnnex VIII §7
Document template, not legal advice
This free tool fills in a Declaration of Conformity template that follows the Annex VIII model of Regulation (EU) 2025/40 (PPWR); the manufacturer's obligation to draw it up is Article 39. Download it as an editable Word (.docx) or plain-text file, print it to PDF, or copy the text into your own document. It does not constitute legal advice. General application began on 12 August 2026; individual requirements have phased dates; consult qualified counsel before signing and filing.
What the Annex VIII model actually contains — point by point
The model declaration in Annex VIII of Regulation (EU) 2025/40 is short: eight numbered points plus a signature block. The builder above collects the information needed to prepare those points. Optional grade claims are additional information, subject to phased requirements. The document model asks for:
Point
What the model asks for
Practical note
No (header)
An identification number for the declaration itself
Your internal document reference — one per DoC version
1
Unique identification of the packaging
SKU, GTIN or internal packaging code
2
Name and address of the manufacturer and, where applicable, the authorised representative
The legal entity that answers for the packaging — a brand owner selling under its own name counts as manufacturer
3
The fixed sentence: issued under the sole responsibility of the manufacturer
Copied verbatim — it is a liability statement
4
Object of the declaration: identification of the packaging allowing traceability, with a description
Material, format, weight, a drawing or photo reference — enough to trace the exact packaging
5
Statement of conformity with the relevant Union harmonisation legislation applied
Reg (EU) 2025/40 plus any other EU acts the packaging falls under (e.g. food-contact rules)
6
References to harmonised standards, common specifications or other technical specifications used
Cite the specifications actually used, with dates and versions; verify any claimed presumption of conformity against current OJ references
7
Notified body details, where applicable
PPWR’s own Annex VII procedure is internal production control with no notified body, so for most packaging this point is simply “not applicable”
8
Additional information + signature block
“Signed for and on behalf of”, place and date of issue, name, function, signature
Source: Annex VIII, Regulation (EU) 2025/40, OJ L, 22.1.2025 — document structure checked 2026-09-11. Article 39(2) requires the Annex VIII model and continuous updating; a filled template does not replace the assessment and technical file.
PPWR technical documentation template (Annex VII, Module A)
There is no official EU form for the PPWR technical documentation. Unlike the declaration of conformity — which has a fixed model in Annex VIII — Annex VII sets a content list, not a layout. So a “technical documentation template” is really a checklist: a file that contains the six elements below, in whatever structure your quality system already uses. Annex VII also names the conformity assessment procedure the declaration rests on: Module A, internal production control, under which the manufacturer assesses and declares conformity on its sole responsibility, with no notified body involved.
Annex VII, point 2
What the file must contain
What that means in practice
(a)
A general description of the packaging and its intended use
What it is, what it packs, which market role it plays — the same identification your declaration carries
(b)
Conceptual design, manufacturing drawings and materials of components
Drawings or specs down to component level: every layer, closure, label, adhesive and ink
(c)
Descriptions and explanations necessary to understand those drawings and the operation of the packaging
The written commentary that makes the drawings readable to a market surveillance officer who has never seen your product
(d)
A list of the harmonised standards (Art. 36), common specifications (Art. 37) and other technical specifications used — including which parts were applied where they were applied only in part, and a description of the solutions adopted where none were applied
This is the list you mirror in point 6 of the declaration. No PPWR harmonised standards are cited in the Official Journal yet, so most files land in the “solutions adopted” branch
(e)
A qualitative description of how the assessments provided for in Articles 6, 10 and 11 were carried out
Recyclability (Art. 6), packaging minimisation (Art. 10) and reusable packaging (Art. 11) — how you assessed each, not just the conclusion
(f)
Test reports
Lab results behind the claims: substance limits, PFAS in food-contact packaging, recycled content, recyclability
Annex VII adds two duties around that file. Point 2 requires the documentation to include “an adequate analysis and assessment of the risks of non-conformity” — a risk assessment, not just a document pile. Point 3 requires the manufacturing process and its monitoring to keep series production in line with what the file says. Point 4 then ties the two together: the manufacturer draws up a written declaration of conformity for each packaging type and keeps it with the technical documentation at the disposal of the national authorities for 5 years after single-use packaging, and 10 years after reusable packaging, has been placed on the market.
Source: Annex VII (Conformity assessment procedure — Module A, internal production control) and Art. 15(2)–(3) of Regulation (EU) 2025/40, re-read verbatim 2026-08-04. Note the direction of the reference: the declaration points at the technical file, not the other way round — you cannot sign a valid declaration before the Annex VII file exists.
Who signs the declaration — and who must keep it
The DoC is the manufacturer’s document. Article 15(2) requires the manufacturer to run the Article 38 conformity assessment (the internal-production-control module of Annex VII — it may be carried out on the manufacturer’s behalf, but not owned by anyone else), draw up the technical documentation and then draw up the declaration. By drawing it up, the manufacturer assumes responsibility for the packaging’s compliance (Art. 39(4)). The signature block does not name a required job title: it asks for a name, a function and a signature “for and on behalf of” the manufacturer — in practice, someone empowered to bind the company, such as a director or the compliance lead.
Around the signature sit three other roles with document duties of their own:
Role
DoC duty
Legal basis
Retention
Manufacturer
Runs the Annex VII assessment, draws up and signs the DoC, keeps it with the technical documentation
Art. 15(2)–(3), Art. 39
5 years (single-use) / 10 years (reusable) from placement
Authorised representative
Keeps the DoC + technical documentation at the disposal of market surveillance authorities; the mandate must cover this
Art. 17(2)(a)
Same 5 / 10 year periods
Importer
Verifies before placing on the market that the manufacturer ran the assessment and drew up the documentation, and keeps a copy of the DoC available
Art. 18(2), 18(7)
Same 5 / 10 year periods
Any economic operator
Keeps supply-chain identification records — who supplied them and whom they supplied
Art. 22
5 / 10 years from supply
Source: Reg (EU) 2025/40, Arts. 15, 17, 18, 22, verified 2026-07-04. Note the language rule while you are here: the DoC must be drawn up in, or translated into, the language(s) required by each member state where the packaging is placed or made available (Art. 39(2)) — and it must be continuously updated, not issued once and archived.
Timeline: what applies on 12 August 2026 — and what comes later
The PPWR entered into force on 11 February 2025 and applies from 12 August 2026, with no general grace period for packaging placed on the market from that date. But not every obligation starts then — several of the headline requirements phase in years later:
Date
What starts applying
30 Mar 2026
Commission publishes its PPWR guidance communication and a companion FAQ to support uniform interpretation ahead of the application date
12 Aug 2026
General application: DoC + Annex VII technical documentation for packaging placed on the market; substance rules under Art. 5, including the PFAS thresholds for food-contact packaging (25 ppb targeted PFAS / 250 ppb PFAS sum / 50 ppm total fluorine); economic-operator obligations (Arts. 15–22)
12 Aug 2028
Harmonised labelling of material composition on the packaging itself (Art. 12)
1 Jan 2030
For recyclability, grades A–C apply from the later of this date and 24 months after the relevant delegated act enters into force (Art. 6); minimum recycled-content shares for plastic packaging (Art. 7); the 50% empty-space cap for grouped, transport and e-commerce packaging; the Annex V single-use format restrictions
1 Jan 2035
Recycling at scale applies from the later of this date and five years after the relevant implementing act enters into force (Art. 6)
1 Jan 2038
Grade C is phased out; only grades A and B remain
The practical consequence for the declaration: the DoC you draw up for 12 August 2026 declares conformity with the requirements that apply on that date. A recyclability grade is not an unconditional Annex VIII field in 2026. Verify the phase dates and relevant acts, and update the declaration as required by Article 39(2).
Harmonised standards: what you can cite in point 6 (July 2026)
Point 6 of the model asks for references to “harmonised standards or common specifications used, or other technical specifications”. Here the regulatory reality matters: as of early July 2026 no harmonised standards have been cited in the Official Journal under PPWR Article 36, so there is no presumption-of-conformity route yet. What exists today:
The legacy EN 13427–13432 series (2000/2004) — harmonised under the old Packaging Directive 94/62/EC, still the reference set most packaging DoCs cite while the PPWR successors are prepared. The builder above lists them as candidates for the same reason.
EN 18120, design for recycling of plastic packaging — a new series developed under CEN/TC 261 and published in spring 2026, running to 15 parts (EN 18120-1 principles and terminology, parts for recyclability evaluation and sortability, then material-stream guidelines for PET bottles, rigid PET, rigid and flexible PE/PP, PS/XPS and EPS). CEN positions it as the technical bridge to the PPWR recyclability rules, but it has not been cited in the Official Journal, so it supports your Annex VII file as state-of-the-art evidence rather than granting presumption of conformity. Source: CEN-CENELEC, June 2026.
More is scheduled, not shipped: the Commission’s March 2026 guidance flags that implementing acts, delegated acts and further standardisation requests will follow over the next two to three years — including the recyclability grading methodology due by 1 January 2028. Source: Commission PPWR guidance.
Until citations land in the Official Journal, the honest way to fill point 6 is to reference the technical specifications you actually tested or designed against — and to avoid wording that implies a presumption of conformity that does not exist yet.
What marketplaces will check from 12 August 2026
If you sell through Amazon or another platform, two separate paper-trails matter, and sellers routinely mix them up. The EPR producer registration (the Article 44 national registers, with the data set of Annex IX) is what marketplaces verify — platform-side checks of sellers’ registration status are part of the same enforcement wave. The declaration of conformity is not uploaded to a marketplace: it is the Article 39 document that market surveillance authorities can demand, and Article 39(5) obliges them to spot-check a share of declarations every year on a risk basis.
The registration side is heavier than most sellers expect. Amazon’s own May 2026 study of ten EU markets found registration forms averaging 16 fields per country (from 11 in Belgium and Spain to over 20 in Sweden), completion timelines of two to six weeks, portals often available only in the local language, and authorised-representative requirements that multiply costs for non-resident sellers — while marketplaces must verify sellers’ registration status before allowing sales. Its Pay-on-Behalf programme already reports and pays eco-fees for over 300,000 sellers in five countries, at a surcharge.
Which PPWR Annex sets the Declaration of Conformity model?
Annex VIII of Regulation (EU) 2025/40 sets the model structure for the EU packaging Declaration of Conformity. Earlier draft and interim references to other annex numbers do not reflect the adopted text — the final PPWR places the DoC model in Annex VIII.
Which Article obliges the manufacturer to draw up the DoC?
Article 39. The manufacturer must draw up a written Declaration of Conformity confirming the packaging meets the applicable requirements. Article 38 is the conformity-assessment procedure (Module A, internal production control); it is not the DoC obligation itself.
What is the difference between the DoC and the technical documentation?
They are separate. The Declaration of Conformity (Annex VIII / Art. 39) is the short signed statement of conformity. The technical documentation (Annex VII), prepared under the Article 38 Module A procedure, is the underlying evidence file the DoC references and that competent authorities can request.
How long must I keep the Declaration of Conformity?
Under Article 15(3), 5 years for single-use packaging and 10 years for reusable packaging, counted from the date the packaging is placed on the market, together with the supporting technical documentation. The same 5/10-year periods apply to the authorised representative (Article 17) and the importer (Article 18).
Does a non-EU manufacturer need an EU authorised representative?
Article 17 allows a manufacturer to appoint an authorised representative by written mandate; it does not impose a blanket appointment requirement on every non-EU manufacturer. Include a representative where appointed. Separately assess importer, responsible economic operator and EPR representation obligations for your supply chain; they are not interchangeable with this field.
When does PPWR apply, and is there a grace period?
General application began on 12 August 2026. Some substantive requirements have later dates or depend on implementing or delegated acts. The declaration must address requirements applicable to the particular packaging when it is placed on the market and remain updated (Article 39).
Is this DoC template free, and is there an email wall?
Yes, it is free, and there is no email wall or sign-up. The builder runs entirely in your browser — nothing you type is sent to a server. You can download the finished declaration as an editable Word (.docx) or plain-text file, print it to PDF, or copy the text into your own document. It is a document template, not a substitute for legal advice.
Do I need a separate declaration for each packaging type or SKU?
The Annex VIII model is written per packaging: point 1 asks for a unique identification and point 4 for a description that allows traceability, so identical packaging used across several products can share one declaration, while each distinct packaging format needs its own. Separately, Article 39(3) lets you draw up a single DoC where the packaging falls under several Union acts — that single declaration can be a dossier of the relevant individual declarations.
Do the new EN 18120 standards give a presumption of conformity?
Not yet. The EN 18120 design-for-recycling series for plastic packaging was published by CEN in spring 2026, but as of July 2026 it has not been cited in the Official Journal under PPWR Article 36, so it does not grant a presumption of conformity. It is still worth citing in your Annex VII technical documentation as state-of-the-art evidence of recyclable design.
Is my EPR registration number the same thing as the DoC?
No — they are two separate obligations that both bite on 12 August 2026. The EPR producer registration (Article 44, with the Annex IX data set) is a per-country register entry that marketplaces verify before allowing sales. The declaration of conformity (Article 39) is the manufacturer's signed compliance document, kept with the technical documentation for market surveillance authorities — who must spot-check a share of declarations each year on a risk basis.
Is there an official EU template for the PPWR declaration of conformity?
There is an official model, not an official file. Annex VIII of Regulation (EU) 2025/40 sets out the structure the declaration must have — eight numbered points plus a signature block — but the Commission does not publish a downloadable Word or PDF form. Any template you find, this one included, is somebody reproducing the Annex VIII model. What matters is that every mandatory element is present: a declaration missing one is treated as if it did not exist. The technical documentation behind it (Annex VII) has no model structure at all, only a content list.
What formats can I download the declaration template in?
Editable Word (.docx), plain text (.txt), PDF via your browser’s print dialog, or straight to the clipboard. The .docx opens in Word, Google Docs and LibreOffice, so you can put it on your letterhead, translate it into the languages your member states require (Art. 39(2)) and sign it. All four are produced in your browser from what you typed — there is no upload, no account and no email wall.