PPWR declaration of conformity: who issues it and who collects it

Manufacturer and producer are two different roles

The PPWR separates the manufacturer (Art. 3(1)(13)) from the producer (Art. 3(1)(15)). The manufacturer is responsible for conformity. The producer carries extended producer responsibility: registration, reporting and fees. According to the Commission’s guidance there is one manufacturer EU-wide, and one producer per Member State.

German-language readers should note a trap: the German text calls the manufacturer “Erzeuger” and the producer “Hersteller”. Sources that disagree on who issues the declaration are often just translating differently.

Who is the manufacturer?

It is not necessarily whoever physically makes the packaging. If you have packaging or a packaged product designed or made under your name or trademark, you are the manufacturer (Art. 3(1)(13)(a)). Guidance document C/2026/3084 applies this by packaging type.

• Sales and grouped packaging: normally the filler, often also the brand owner
• Transport, service and primary production packaging: normally whoever makes it, unless the user’s name or trademark is on it
• No name or trademark: whoever places the order and sets the design specifications
• Importer or distributor using its own brand, or modifying packaging in a way that could affect compliance: treated as the manufacturer (Art. 21)
• Micro-enterprise brand: under conditions, the packaging supplier (see the FAQ below)

Who supplies, checks or keeps what

The Regulation has no general duty to collect the declaration along the chain. Each role has its own narrower task.

• Supplier: gives the manufacturer all necessary information and documentation, on paper or electronically (Art. 16). The Commission’s FAQ says suppliers cannot refuse.
• Manufacturer: carries out or commissions the conformity assessment, draws up the technical documentation and the declaration, and assumes responsibility (Art. 15, Art. 39(4)).
• Authorised representative: may draft and keep the declaration under mandate, but cannot draw up the technical documentation (Art. 17). Responsibility stays with the manufacturer.
• Importer: ensures assessment and documentation exist, and keeps a copy of the declaration for the authorities (Art. 18(2) and (7)).
• Distributor: checks producer registration, labelling and the manufacturer and importer details before selling (Art. 19(2)). The declaration is not on that list.
• Fulfilment service provider: makes sure storage and shipping do not jeopardise compliance (Art. 20).

What the declaration contains

Annex VIII sets out eight points: identification of the packaging, name and address of the manufacturer, the sole responsibility statement, object of the declaration, Union law applied, standards and specifications, the notified body if any, and additional information. Then place, date, name, function and signature.

You need one declaration per packaging type (Annex VII point 4). The Commission’s FAQ reads “type” as the format or the batch or series, not the material types in Annex II. A packaging unit of bottle, closure and label gets one declaration that names all components. Keep it up to date and available in the language of the market (Art. 39(2)).

How long you keep it and for whom

Keep the declaration and technical documentation for five years for single-use packaging and ten years for reusable packaging, from placing on the market (Art. 15(3)). When an authority makes a reasoned request, the documents are due within ten days, electronically and on paper if asked (Art. 15(10)).

The Regulation does not require publishing the declaration. Where customers demand it, that comes from contracts, not from the PPWR.

Example: tile adhesive in a 25 kg sack

A construction chemicals company fills tile adhesive into sacks ordered from a packaging plant, with its brand printed on them (invented example). It is the manufacturer of the packaging. The plant is the supplier and provides material data and test reports. The DIY store is a distributor. It may ask for the declaration by contract, but the PPWR does not oblige it to collect one.

What to do now

• List your packaging by format or series, with components and suppliers.
• Decide who is the manufacturer per packaging. Sales packaging with your brand: you.
• Request the Art. 16 documents from suppliers and record when they arrive.
• Draw up the technical documentation and declaration under Annexes VII and VIII, in-house or with a test provider.
• Name who updates the declaration when packaging, supplier or standard changes.

Frequently asked questions