What is the latest on the new Packaging and Packaging Waste Regulations legislation?
The European Union is intensifying efforts on single-use packaging for reusable and refillable packaging. There is a new provision from the new Packaging and Packaging Waste Regulations (PPWR) legislation effective from 12th Aug 2026.
Documentation called ‘Declarations of Conformity’ is now legally required for every packaging product type.
What is a Declaration of Conformity?
Historically, packaging legislation has focused primarily on waste management and recycling targets once packaging had already been placed on the market. The PPWR takes a different approach by placing greater emphasis on demonstrating compliance before packaging is sold or distributed.
A Declaration of Conformity (DoC) is a formal written statement that confirms a specific packaging type meets the requirements of the PPWR.
Who is responsible for the Declaration of Conformity?
Responsibility for the Declaration of Conformity sits with the party placing the packaging on the EU market under its own name or trademark – in practice, usually the brand owner or importer rather than the factory that physically produced the packaging.
If your brand appears on the packaging, the obligation is likely to be yours.
To ensure compliance, we recommend the following steps:
- Confirm your role. Establish whether you are the manufacturer, importer or distributor for each packaging type you place on the EU market, as this determines who must draw up and sign the declaration.
- Build a packaging inventory. List every packaging type and component used to protect your products – outer cartons, films, closures, labels, void fill and pallet wrap – as a declaration is required for each packaging type, not each product.
- Request Declarations of Conformity from your suppliers. Ask each packaging supplier for a signed declaration following the Annex VIII model, together with confirmation of the standards and test evidence relied upon.
- Check the technical file sits behind it. The declaration is only the front page; it must be supported by technical documentation evidencing compliance with the substance restrictions applying from 12th August 2026, including PFAS limits for food-contact packaging and heavy metal limits.
- Retain the documentation. Keep declarations and supporting files available for inspection by market surveillance authorities – five years after the last unit is placed on the market, or ten years for reusable packaging.
- Share the documentation with SEKO. Provide us with a copy of the declaration for each packaging element so that we hold it on file, helping to avoid inadvertent delays.
If you have any questions in relation to the new legislation, please don't hesitate to get in touch.
