EU compliance
Packaging Conformity
Packaging conformity determines whether packaging itself meets the applicable PPWR product requirements and whether the evidence needed to demonstrate that compliance is in place. It is a separate compliance layer from national packaging EPR registration, financing and reporting.
Overview
Packaging conformity under Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) concerns the packaging as a product placed on the EU market. The manufacturer must determine which requirements laid down in or pursuant to Articles 5 to 12 apply to the packaging and demonstrate conformity through the procedure set out in Article 38 and Annex VII.
PPWR uses Module A — internal production control. The manufacturer establishes the technical documentation, ensures that the packaging complies with the applicable requirements and, once conformity has been demonstrated, draws up the EU Declaration of Conformity under Article 39.
This product-conformity process is separate from extended producer responsibility. A packaging portfolio can therefore require both PPWR conformity documentation and national EPR registrations, producer-responsibility arrangements, records and reporting.
Who is affected
- Packaging manufacturers
- Businesses having packaging manufactured under their own name or trademark where the PPWR manufacturer rules apply
- Importers placing packaging from a third country on the Union market
- Distributors making packaging available on the market
- Suppliers of packaging or packaging materials that provide information and documentation needed by the manufacturer
- Importers or distributors that may become subject to manufacturer obligations where Article 21 applies
- The PPWR economic-operator role must be identified before the conformity workflow is established. The company responsible for packaging conformity is not determined by the same test as the producer responsible for national EPR.
Key obligations
- Identify the applicable PPWR requirements for the packaging and the implementation dates relevant to those requirements.
- Establish the conformity-assessment route under Article 38 and Annex VII and define the evidence needed to demonstrate compliance.
- Compile and maintain technical documentation covering the applicable requirements and the relevant design, material, assessment, calculation and test evidence.
- Ensure that the required packaging identification, manufacturer information, labelling and other traceability elements are addressed.
- Draw up and maintain the EU Declaration of Conformity once compliance with the applicable requirements has been demonstrated.
- Maintain procedures so that changes to packaging design, materials, specifications or relevant technical standards are reviewed where they may affect conformity.
Documentation and data requirements
The technical documentation must make it possible to assess the packaging's conformity with the applicable PPWR requirements and include an adequate analysis and assessment of the risks of non-conformity.
As relevant to the assessment, the file can include the identification and description of the packaging, information on its design and manufacture, material and supplier information, the applicable legal requirements, harmonised standards, common specifications or other technical specifications used, calculations, assessments, test reports and other supporting evidence.
Supplier documentation is an important input. Under Article 16, suppliers of packaging or packaging materials must provide the manufacturer with the information and documentation necessary for the manufacturer to demonstrate conformity.
The technical documentation supports the EU Declaration of Conformity but is not the same document. The manufacturer remains responsible for establishing the technical documentation required by PPWR.
Conformity assessment
PPWR conformity assessment follows the internal production control procedure in Annex VII (Module A). Under this procedure, the manufacturer assesses the packaging against the applicable PPWR requirements and remains responsible for ensuring and declaring its conformity.
The conformity assessment may use external technical work, testing or other specialist evidence where appropriate, and Article 15 allows the assessment to be carried out on the manufacturer's behalf. This does not transfer the manufacturer's legal responsibility for placing compliant packaging on the market.
PPWR does not establish a general requirement for third-party certification of every packaging item. The evidence required depends on the packaging and the specific PPWR requirements being demonstrated.
Importers
An importer must only place compliant packaging on the Union market. Before placing packaging on the market, the importer must verify, among other applicable requirements, that the manufacturer has carried out the required conformity assessment and drawn up the technical documentation, and that the applicable labelling, documentation and manufacturer-identification requirements have been addressed.
The importer also has its own identification, document-availability and cooperation obligations under PPWR.
Distributors
Distributors have a separate due-care and verification role. Before making packaging available on the market, they must perform the checks assigned to them by PPWR, including relevant labelling and economic-operator checks and verification of the applicable EPR producer registration.
Where an importer or distributor places packaging on the market under its own name or trademark, or modifies packaging in a way that may affect conformity, manufacturer obligations may apply under Article 21, subject to the Regulation's specific rules.
Relationship with EPR
Packaging conformity and packaging EPR are parallel compliance layers. Packaging conformity asks whether the packaging itself meets the applicable PPWR product requirements and whether conformity can be demonstrated.
EPR asks who is the producer for the relevant Member State and what registration, representation, fulfilment, financing, record-keeping and reporting obligations apply. Completing one layer does not complete the other.
CE marking
PPWR conformity does not create a CE-marking requirement for packaging itself. Where a CE marking appears on packaging because the packaged product is subject to other Union product legislation, that marking relates to the relevant product-law requirements and must not be treated as evidence that the packaging complies with PPWR.
How we assist
- Identify the relevant PPWR conformity requirements for the packaging portfolio
- Define the conformity-documentation workflow
- Map available packaging specifications, material information and supplier evidence
- Identify missing evidence or data
- Structure the technical-documentation file
- Review documentation for apparent completeness against the identified requirements
- Coordinate external testing or specialist input where needed
- Prepare the information structure needed for the manufacturer's EU Declaration of Conformity
- Align packaging conformity work with the separate national EPR setup
EPR Entry is the commercial coordination platform. Packaging-conformity support is delivered through the legal service provider identified for the relevant engagement.
The manufacturer remains responsible for placing compliant packaging on the market and for the EU Declaration of Conformity. Where specialist testing, technical assessment or formal legal interpretation is required, that work is identified separately.
Frequently asked questions
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