PPWR DoC = Annex VIII model · Article 39 obligation · retain 5 years (single-use) / 10 years (reusable).
Regulation reference last verified 2026-06-16 · Application date 2026-08-12
Annex VIII Declaration of Conformity builder
Annex VIII · Art. 39
Specimen · 2026-08-12 application date
Declaration of Conformity
Regulation (EU) 2025/40 (PPWR) — Annex VIII model (Art. 39)
1. Unique DoC identifier: [DoC-YYYY-NNNN]
2. Manufacturer name: [Manufacturer name]
3. Manufacturer address: [Postal address]
4. Economic operator identity (Annex VIII §2): [EORI / VAT]
5. Authorised representative: n/a (EU-established manufacturer)
6. Packaging unit identifier: [SKU / GTIN]
7. Packaging type (Art. 3(1), Annex II): [packaging type]
8. Packaging role (Art. 3(1)(b–d)): [packaging role]
9. Recyclability performance grade (Art. 6, Annex II): [performance grade A / B / C]
10. Recycled-content share (Art. 7): n/a (non-plastic packaging)
11. Restricted substances declaration (Art. 5): [compliance statement required]
12. Harmonised standards applied (Art. 36): none cited
13. EU member state(s) of placement (Art. 4): [country of placement]
14. Signatory: [name], [role], [place], [YYYY-MM-DD]
Application date: 2026-08-12 (no grace period).
Technical documentation: Annex VIII DoC supported by the Annex VII technical file (Module A, Art. 38).
Retain until: [signature date + 5y] (PPWR Art. 39, 5-year retention for single-use packaging).
Retain 5 years per Art. 39 (single-use packaging).
Free EU PPWR (Reg (EU) 2025/40) Annex VIII Declaration of Conformity builder — a live 14-clause ledger and signable specimen for EU packaging.
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 must be retained for 5 years for single-use packaging and 10 years for reusable packaging (Article 15(3)), and drawn up in or translated into the language(s) required by each member state where the packaging is placed on the market (Article 39(2)). PPWR applies from 12 August 2026 with no grace period.
02Manufacturer name and registered trade nameArt. 39(1) · Annex VIII §2
03Manufacturer postal addressArt. 39(1) · Annex VIII §2
04Economic operator identity (EORI / VAT)Annex VIII §2
06Packaging unit identifier (SKU / GTIN)Annex VIII §3
07Packaging type (rigid plastic / flexible plastic / paper / metal / glass / composite)Art. 3(1) · Annex II
08Packaging role (sales / grouped / transport)Art. 3(1)(b–d)
09Recyclability performance grade (A / B / C)Art. 6 · Annex II
11Restricted substances declarationArt. 5
13EU member state(s) of placementArt. 4
14Signatory name, role, place and dateAnnex VIII §6
Document builder, not legal advice
This free tool generates an on-screen Declaration of Conformity specimen aligned with the Annex VIII model of Regulation (EU) 2025/40 (PPWR); the manufacturer's obligation to draw it up is Article 39. Copy the specimen text into your own document. It does not constitute legal advice. The application date is 12 August 2026 with no grace period; 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 expands them into fourteen practical fields (a packaging type, role and grade are all part of “identifying the object of the declaration”), but what the law itself asks for is this:
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
See the standards-status section below — no PPWR harmonised standards exist yet, so cite what you actually used
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 — points re-read verbatim 2026-07-04. A declaration missing a mandatory element is treated as if it did not exist, and the packaging may not be placed on the market (Art. 15(1)).
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
Recyclability becomes substantive: only grades A–C may be marketed (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
“Recycled at scale” is added to the recyclability assessment — design compliance alone stops being enough
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. The recyclability-grade field exists on the specimen from day one, but the substantive grade obligation only binds from 2030 — which is exactly why Article 39(2) requires the declaration to be continuously updated as each wave lands.
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?
A manufacturer established outside the EU must work with an EU-established economic operator — typically an authorised representative under Article 17 — so the DoC and technical file are accessible to EU authorities. This builder blocks the declaration until that representative is named.
When does PPWR apply, and is there a grace period?
PPWR applies from 12 August 2026 with no grace period. It entered into force in February 2025 after an 18-month transition; packaging placed on the EU market from 12 August 2026 must already meet the applicable requirements and carry a valid DoC.
Is this DoC builder free?
Yes. The builder is free and runs entirely in your browser — nothing you type is sent to a server. It produces an on-screen specimen you copy into your own document; it does not generate a downloadable PDF and is 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.