How to Prepare a PPWR Declaration of Conformity: A Step-by-Step Guide for Manufacturers
A defensible DoC starts before the document itself
The Declaration of Conformity is the legal cornerstone of PPWR. Every packaging type placed on the EU market from 12 August 2026 requires one. The signatory bears personal liability. The document must be kept current every time materials, design, or suppliers change. And if a regulator, customer, or auditor asks to see it, you need to be able to produce it alongside the full evidence file that backs every claim inside it.
Most manufacturers understand the obligation in broad terms. What is less clear is the actual sequence of work required to produce a DoC that would survive scrutiny. This post walks through that sequence in practical terms.
Before getting into the steps, one framing point is worth making. The DoC is not the starting point. It is the output of a process that begins with supplier data collection and runs through material verification, conformity assessment, and document governance. Companies that try to start with the document and work backwards will find the gaps quickly.
Step 1: Map your packaging portfolio
Before any assessment can happen, you need a complete and current inventory of every packaging type you place on the EU market. This means primary packaging, secondary packaging, transport packaging, e-commerce packaging, and service packaging. Each distinct packaging type requires its own DoC, so the portfolio map directly determines the scope of work. For most global manufacturers, this step surfaces packaging types that are not centrally documented, have unclear ownership, or have changed without a corresponding update to records.
Step 2: Assign legal accountability per packaging type
PPWR defines the legal manufacturer as the entity whose name or trademark appears on the packaging, regardless of who physically produces it. For every packaging type in your portfolio, you need to confirm which legal entity in your organisation is the manufacturer of record, who within that entity will sign the DoC, and whether any packaging types involve shared accountability with importers or distributors that needs to be resolved before the assessment begins.
Step 3: Collect the required supplier data
This is where most compliance programmes slow down. The technical file requires material-level evidence that can only come from suppliers. Under Article 16 of PPWR, suppliers are legally required to provide it, but the structured requests still need to be designed and sent. For each packaging type, you need a layer-by-layer bill of materials with material weights and mass percentages, substance compliance test reports confirming PFAS absence and heavy metals below 100 ppm combined, verified post-consumer recycled content percentages with the calculation methodology and accepted certification standard, and chain-of-custody documentation linking recycled content claims to plant-level sources. Generic supplier questionnaires are not sufficient.
Step 4: Conduct the recyclability assessment
Every packaging type must be assigned a recyclability grade of A, B, or C using a methodology that follows harmonised EU standards. Grade A requires 95 percent or more of packaging weight to be recyclable at scale, Grade B 80 percent or more, and Grade C 70 percent or more. Grade C packaging will be banned from the EU market from 2030. The assessment must be documented and referenced in the technical file.
Step 5: Check empty-space compliance for relevant packaging types
For secondary packaging, transport packaging, and e-commerce packaging, the empty-space ratio must not exceed 50 percent of total package volume from 2030. If you are preparing DoCs now and your packaging design decisions are still open, factoring this in now avoids a redesign cycle closer to the deadline.
Step 6: Compile the technical file
The technical file is the evidence package that makes the DoC defensible. It should contain the completed bill of materials, all substance compliance test reports, recycled content certification with calculation methodology, the recyclability assessment and grade, any empty-space measurements for applicable formats, and the supplier documentation that underpins each of the above. The file must be versioned, dated, and retained for five years for single-use packaging and ten years for reusable.
Step 7: Draft and sign the Declaration of Conformity
With the technical file complete, the DoC itself can be produced. It must include a unique document identifier, the name, address, and contact details of the signatory manufacturer, the legal basis for conformity citing the relevant articles of EU Regulation 2025/40, the harmonised standards applied, a dated reference to the technical file, and the signature of the individual accepting personal liability. A separate DoC is required for each packaging type, not for each SKU or each market.
Step 8: Build a process to keep it current
A DoC signed once and filed is not a compliant DoC. The regulation requires that it be updated every time materials, design, or suppliers change. That means the governance process matters as much as the document itself. You need a clear trigger system that flags when a change has occurred, an owner responsible for initiating the update, and a version control process that maintains the history of every previous iteration.
For manufacturers with large and complex packaging portfolios, steps three through eight cannot be run manually at scale without significant risk of gaps, delays, and errors. We built carbmee EIS specifically to automate the supplier data collection process, structure it at the packaging-type level, connect it to recyclability assessments and DoC generation, and keep the full evidence chain current as requirements evolve and packaging changes. The companies that are most prepared for August 2026 started building that infrastructure early. For those that have not, the window is still open, but it is closing.
Read our Ultimate Guide to PPWR for the full picture on deadlines, recyclability grades, EPR registration, enforcement risk, and the 14-point action checklist for procurement and sustainability leaders.
