The Declaration of Conformity: a step-by-step guide for brands
From 12 August 2026, any packaging placed on the EU market must be backed by a Declaration of Conformity (DoC). This is not a registration — it's a document you hold on file that declares your packaging complies with Regulation (EU) 2025/40.
Here's exactly what it must contain and how to create one.
What the DoC is (and isn't)
It is:
A formal written declaration, signed by an authorised representative of your company
A statement that specific packaging types comply with PPWR requirements (Articles 5–10)
A document you keep in your records for at least 10 years
Something that must be produced "upon request" to national market surveillance authorities
It is not:
Something you submit proactively to a regulator
A certification from a third party (though you may choose to use one to support the declaration)
A LUCID registration, Citeo contract, or other EPR registration
A substitute for EPR registration
Think of it as similar to the CE Declaration of Conformity for physical products — you're making a legal statement that your product (in this case, your packaging) meets specific regulatory requirements.
What PPWR requires the DoC to cover
Under PPWR Article 6(7) and Annex VII, the Declaration of Conformity must include:
Identification of the packaging: What packaging types the DoC covers (corrugated box 320×240×150mm, polybag mailer, glass jar, etc.). You can create one DoC covering multiple packaging items if they share compliance characteristics.
Identification of the producer: Legal name, address, and contact details of the responsible economic operator (that's you, the brand).
Statement of compliance: A declaration that the packaging meets the requirements of PPWR, specifying which articles apply (typically Art. 5 for prohibited substances, Art. 6 for recyclability, Art. 7 for recycled content if applicable, Art. 10 for minimisation).
Technical basis for the declaration: Reference to the Annex VIII technical documentation that supports the declaration. This documentation must be maintained separately (see below).
Responsible signatory: Name, position, date, and signature of the person taking legal responsibility for the declaration.
The content of Annex VIII technical documentation
The DoC references Annex VIII documentation — the supporting evidence file. This file must contain:
Packaging description: Detailed description of the packaging format, dimensions, weight, and intended use
Material composition: Complete material declaration — which materials are used, in what quantities, and in what parts of the packaging (e.g., "outer box: FSC-certified corrugated board, 250g/m², weight 185g")
Compliance evidence for Art. 5 (prohibited substances): Supplier declarations confirming absence of PFAS, or lab test results; confirmation of no heavy metals above limits; confirmation of no prohibited substances from Annex I
Recyclability evidence for Art. 6: Assessment of recyclability against current EU sorting and recycling infrastructure, referencing the applicable harmonised standard or assessment methodology (CEFLEX, RecyClass, or national equivalent); expected recyclability grade (once A–E grades are formally adopted)
Minimisation evidence for Art. 10: Confirmation that void space is within acceptable limits; confirmation that no unnecessary packaging elements are present; any optimisation measures taken
Any relevant test reports or certifications
The Annex VIII documentation doesn't need to be sent anywhere — it's an internal file. But if a national market surveillance authority inspects your packaging and requests documentation, this is what you hand over. Maintain it for 10 years.
How to create your DoC: step by step
Step 1: Inventory your packaging
List every packaging format you use. For DTC e-commerce this typically means:
Product packaging (if the product's primary container is also shipped to consumers)
Labels, tape, stickers
You need one DoC that covers all of them, or separate DoCs per format — your choice.
Step 2: Collect supplier declarations
Contact your packaging suppliers and request:
Material composition declarations (what materials, what specifications)
Absence of prohibited substances (PFAS, specific heavy metals, substances listed in PPWR Annex I)
Any recyclability certifications they hold (e.g., RecyClass assessment for plastic packaging)
Most established packaging suppliers already have this documentation prepared, especially for EU customers.
Step 3: Assess recyclability
For each packaging format, assess whether it meets the PPWR recyclability requirements. The key questions:
Is this packaging sorted in EU recycling systems? (Cardboard: yes. LDPE polybags: depends on local infrastructure. Clear PET: yes. Black plastic: generally no.)
Does it contain any components that inhibit recycling? (Non-detachable plastic film on cardboard; dark colourants in PET; PVC components; PVDC coatings)
Until the formal A–E grade system is adopted (expected 2028), recyclability assessment is based on current harmonised standards and the PPWR's definition of recyclability. For most standard packaging formats used by DTC brands (corrugated cardboard, clear glass, standard HDPE/PET), compliance is straightforward. Non-standard or problematic formats need more careful assessment.
Step 4: Assess minimisation (Article 10)
Check your packaging against the minimisation requirements:
Void space: measure your inner box dimensions and estimate fill percentage. If it's above 40% void, right-size the box.
Unnecessary packaging elements: is every component functional? Is there secondary packaging that serves no protection or information purpose?
Step 5: Write the DoC
The DoC can be written in any EU official language or English. It doesn't need to be long — typically 1–2 pages. Here's the structure:
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DECLARATION OF CONFORMITY
(Regulation (EU) 2025/40 — Packaging and Packaging Waste Regulation)
Producer:
[Company legal name]
[Registered address]
[Company registration number]
[Contact email]
Packaging covered by this declaration:
[Description of packaging types — e.g., "Corrugated cardboard shipping boxes (FSC-certified, 250g/m² board, dimensions 320×240×150mm, weight 185g); Kraft paper tissue insert (30g per sheet); BOPP adhesive tape (6g per box)"]
Declaration:
We declare that the packaging identified above complies with Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste, specifically:
Article 5 (Packaging containing prohibited substances): The packaging does not contain PFAS, lead, cadmium, mercury, hexavalent chromium, or other substances prohibited under Annex I at concentrations exceeding applicable limits.
Article 6 (Recyclable packaging): The packaging is designed to be recyclable in accordance with criteria applicable under Article 6, and is assessed as [recyclable / compliant with current recyclability requirements based on existing EU infrastructure].
Article 10 (Packaging minimisation): The packaging has been designed to minimise weight and volume while maintaining its functional purpose. Void space does not exceed applicable limits.
Technical documentation:
This declaration is supported by Annex VIII technical documentation maintained at [company address / document reference].
Signed:
[Name], [Title]
[Company name]
[Date]
[Signature]
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Step 6: Compile your Annex VIII file
Create a folder (physical or digital) containing:
Copy of the signed DoC
Supplier material declarations
Any recyclability assessments or certifications
Photographs of packaging with dimensions noted
Internal analysis of void space (photos of packed orders helps)
Any supplier test reports for substance compliance
Label it clearly. Store it for 10 years.
Common questions
Do I need a new DoC when I change my packaging?
Yes. If you change packaging materials, dimensions, or suppliers in a way that affects compliance, update your DoC and Annex VIII file. The old version should be retained (with dates) alongside the new one.
Do I need a DoC for packaging I receive as a consumer (product packaging from my suppliers)?
No. Your obligation covers packaging you place on the market — packaging you use to ship your products to EU customers. If your products arrive from a manufacturer in packaging, that manufacturer holds the DoC for that packaging.
Can one DoC cover multiple markets?
Yes. The DoC is based on EU regulation, not national regulation. One DoC covers all EU markets.
What if I use a fulfilment centre that packs for me?
You're still the producer — EPR obligations and the DoC responsibility rest with the brand, not the fulfilment centre. The fulfilment centre may provide packaging specifications that feed into your Annex VIII documentation.