PPWR Declaration of Conformity Template and Builder

Free PPWR declaration of conformity template — the Annex VIII model

The builder above is the template. It reproduces the model declaration set out in Annex VIII of Regulation (EU) 2025/40 — the eight numbered points plus the signature block — and expands them into the fourteen fields a packaging manufacturer actually has to fill. Leave a field blank and it stays as a bracketed placeholder, so what you take away is a genuine fill-in-the-blanks template rather than a half-empty document.

When the ledger reads ready to sign, use the buttons under the specimen to take it away:

• Word (.docx) — an editable document you can drop on your letterhead, translate, and sign. Opens in Word, Google Docs and LibreOffice.
• Plain text (.txt) — for pasting into a quality management system, a supplier portal or an existing DoC shell.
• PDF — choose Print / save as PDF; the print stylesheet strips the page down to the declaration itself.
• Clipboard — Copy specimen text for a one-click paste.

The template is assembled in your browser. Nothing you type is uploaded, there is no sign-up and no email wall, and the file is generated locally rather than fetched from a server.

One declaration covers one packaging: Annex VIII point 1 asks for a unique identification and point 4 for a description allowing traceability, so each distinct packaging format needs its own template instance — while Article 39(3) lets you draw up a single declaration where the packaging falls under several Union acts. Keep the signed declaration with the Annex VII technical documentation for 5 years (single-use) or 10 years (reusable) from placement on the market (Art. 15(3)). This is a document template, not legal advice.

What the Annex VIII model actually contains — point by point

The model declaration in Annex VIII of Regulation (EU) 2025/40 is short: eight numbered points plus a signature block. The builder above expands them into fourteen practical fields (a packaging type, role and grade are all part of “identifying the object of the declaration”), but what the law itself asks for is this:

Source: Annex VIII, Regulation (EU) 2025/40, OJ L, 22.1.2025 — points re-read verbatim 2026-07-04. A declaration missing a mandatory element is treated as if it did not exist, and the packaging may not be placed on the market (Art. 15(1)).

PPWR technical documentation template (Annex VII, Module A)

There is no official EU form for the PPWR technical documentation. Unlike the declaration of conformity — which has a fixed model in Annex VIII — Annex VII sets a content list, not a layout. So a “technical documentation template” is really a checklist: a file that contains the six elements below, in whatever structure your quality system already uses. Annex VII also names the conformity assessment procedure the declaration rests on: Module A, internal production control, under which the manufacturer assesses and declares conformity on its sole responsibility, with no notified body involved.

Annex VII adds two duties around that file. Point 2 requires the documentation to include “an adequate analysis and assessment of the risks of non-conformity” — a risk assessment, not just a document pile. Point 3 requires the manufacturing process and its monitoring to keep series production in line with what the file says. Point 4 then ties the two together: the manufacturer draws up a written declaration of conformity for each packaging type and keeps it with the technical documentation at the disposal of the national authorities for 5 years after single-use packaging, and 10 years after reusable packaging, has been placed on the market.

Source: Annex VII (Conformity assessment procedure — Module A, internal production control) and Art. 15(2)–(3) of Regulation (EU) 2025/40, re-read verbatim 2026-08-04. Note the direction of the reference: the declaration points at the technical file, not the other way round — you cannot sign a valid declaration before the Annex VII file exists.

Who signs the declaration — and who must keep it

The DoC is the manufacturer’s document. Article 15(2) requires the manufacturer to run the Article 38 conformity assessment (the internal-production-control module of Annex VII — it may be carried out on the manufacturer’s behalf, but not owned by anyone else), draw up the technical documentation and then draw up the declaration. By drawing it up, the manufacturer assumes responsibility for the packaging’s compliance (Art. 39(4)). The signature block does not name a required job title: it asks for a name, a function and a signature “for and on behalf of” the manufacturer — in practice, someone empowered to bind the company, such as a director or the compliance lead.

Around the signature sit three other roles with document duties of their own:

Source: Reg (EU) 2025/40, Arts. 15, 17, 18, 22, verified 2026-07-04. Note the language rule while you are here: the DoC must be drawn up in, or translated into, the language(s) required by each member state where the packaging is placed or made available (Art. 39(2)) — and it must be continuously updated, not issued once and archived.

Timeline: what applies on 12 August 2026 — and what comes later

The PPWR entered into force on 11 February 2025 and applies from 12 August 2026, with no general grace period for packaging placed on the market from that date. But not every obligation starts then — several of the headline requirements phase in years later:

The practical consequence for the declaration: the DoC you draw up for 12 August 2026 declares conformity with the requirements that apply on that date. The recyclability-grade field exists on the specimen from day one, but the substantive grade obligation only binds from 2030 — which is exactly why Article 39(2) requires the declaration to be continuously updated as each wave lands.

Sources: Commission press release IP/26/664 and the PPWR guidance document (C(2026) 3702), 30 March 2026; Coolset, PPWR compliance deadlines explained (March 2026); dates cross-checked against the regulation text 2026-07-04. Sell-through of stock already in distribution before 12 August 2026 is generally possible, but member-state practice varies — check the Commission FAQ for your case.

Harmonised standards: what you can cite in point 6 (July 2026)

Point 6 of the model asks for references to “harmonised standards or common specifications used, or other technical specifications”. Here the regulatory reality matters: as of early July 2026 no harmonised standards have been cited in the Official Journal under PPWR Article 36, so there is no presumption-of-conformity route yet. What exists today:

• The legacy EN 13427–13432 series (2000/2004) — harmonised under the old Packaging Directive 94/62/EC, still the reference set most packaging DoCs cite while the PPWR successors are prepared. The builder above lists them as candidates for the same reason.
• EN 18120, design for recycling of plastic packaging — a new series developed under CEN/TC 261 and published in spring 2026, running to 15 parts (EN 18120-1 principles and terminology, parts for recyclability evaluation and sortability, then material-stream guidelines for PET bottles, rigid PET, rigid and flexible PE/PP, PS/XPS and EPS). CEN positions it as the technical bridge to the PPWR recyclability rules, but it has not been cited in the Official Journal, so it supports your Annex VII file as state-of-the-art evidence rather than granting presumption of conformity. Source: CEN-CENELEC, June 2026.
• More is scheduled, not shipped: the Commission’s March 2026 guidance flags that implementing acts, delegated acts and further standardisation requests will follow over the next two to three years — including the recyclability grading methodology due by 1 January 2028. Source: Commission PPWR guidance.

Until citations land in the Official Journal, the honest way to fill point 6 is to reference the technical specifications you actually tested or designed against — and to avoid wording that implies a presumption of conformity that does not exist yet.

What marketplaces will check from 12 August 2026

If you sell through Amazon or another platform, two separate paper-trails matter, and sellers routinely mix them up. The EPR producer registration (the Article 44 national registers, with the data set of Annex IX) is what marketplaces verify — platform-side checks of sellers’ registration status are part of the same enforcement wave. The declaration of conformity is not uploaded to a marketplace: it is the Article 39 document that market surveillance authorities can demand, and Article 39(5) obliges them to spot-check a share of declarations every year on a risk basis.

The registration side is heavier than most sellers expect. Amazon’s own May 2026 study of ten EU markets found registration forms averaging 16 fields per country (from 11 in Belgium and Spain to over 20 in Sweden), completion timelines of two to six weeks, portals often available only in the local language, and authorised-representative requirements that multiply costs for non-resident sellers — while marketplaces must verify sellers’ registration status before allowing sales. Its Pay-on-Behalf programme already reports and pays eco-fees for over 300,000 sellers in five countries, at a surcharge.

Sources: Amazon, “Why small businesses struggle with EU packaging rules” (15 May 2026); Reg (EU) 2025/40, Arts. 39(5), 44 + Annex IX. For per-country fees and scheme contacts, use the packaging EPR fees tool in this family.