Who Signs the PPWR Declaration of Conformity and How to Do It

The legal manufacturer of the packaging – or their appointed EU authorised representative – signs the PPWR Declaration of Conformity. If your brand appears on the packaging, or you commissioned it under your own trademark, that is you and not your overseas box supplier. The signature is only valid if a complete Annex VII technical file sits behind it; it must follow the 10-element Annex VIII model, and you keep both for 5 to 10 years.

Updated 19 August 2026: revised now that the PPWR (Regulation (EU) 2025/40) applies, since 12 August 2026.

The requirement has applied since 12 August 2026, and the signature binds your company to real legal liability for the packaging's compliance.

Key takeaways

• The legal manufacturer or their authorised representative must sign the Declaration of Conformity.
• Signing it takes on full legal liability that the packaging meets the PPWR requirements applicable to it.
• The declaration is completely invalid if not backed by a complete Annex VII technical file.
• It must follow the specific 10-element model outlined in Annex VIII of the regulation.

Who exactly signs the PPWR Declaration of Conformity?

Under the new law, the legally defined manufacturer or their appointed EU authorised representative must sign the EU Declaration of Conformity. If your e-commerce business brands the packaging, or commissions its production under your own trademark, you are considered the legal "manufacturer" under PPWR and must provide the signature.

You cannot force the overseas factory that physically glued the cardboard boxes together to sign the Declaration of Conformity on your behalf. Because your brand name is on the item, the European Union views you as the entity responsible for its design and material safety.

If you import packaging or packaged goods from outside the EU, the importer duties in Article 18 require you to verify that the conformity assessment happened, keep a copy of the declaration and be able to make the technical file available. And under Article 21, an importer or distributor that puts packaging on the market under its own name or trademark is treated as the manufacturer, which means the signature is yours.

What does signing the EU Declaration of Conformity mean legally?

Signing this document is not an administrative formality. It is a legally binding self-declaration that the packaging meets the requirements of Articles 5 to 12, as far as each of them applies at the time you place it on the market.

By signing, you take full liability for the claims made within the document. If market surveillance authorities pull your packaging from a fulfillment center and test it, any discrepancies fall on you. This means if the laboratory detects substances of concern under Article 5 – such as heavy metals exceeding 100 mg/kg or restricted PFAS chemicals – the signatory faces the resulting penalties and product recalls. You are personally attesting that the physical item perfectly matches the compliance claims.

Signing the declaration puts the legal liability on you, so the paperwork behind it has to be right. Let Gramta handle it to automate your compliance file generation before the deadlines arrive.

Can you issue the declaration without technical documentation?

Absolutely not. You must complete the internal production control procedure first. The declaration is essentially just the cover sheet that summarizes the Annex VII technical documentation file.

Since 12 August 2026, every packaging type placed on the EU market needs a signed EU Declaration of Conformity backed by the technical documentation for the requirements that apply to it.

If you sign the declaration but do not actually possess the laboratory test reports, bills of materials, and recyclability assessments in your evidence vault, your signature is legally invalid. Authorities can request your technical files to verify your declaration at any time. If you cannot produce the underlying data, the authorities will treat the packaging as non-compliant and ban it from the market.

What are the 10 mandatory elements of the declaration?

You cannot invent your own format for this document. The law strictly requires that you follow the Annex VIII EU Declaration of Conformity requirements. This specific model mandates 10 concrete legal elements that must be present on the page.

First, you must include specific product identification, detailing the exact packaging type, batch, or serial number. Second, you must clearly state the name and address of the manufacturer or the authorised representative issuing the document. The text must include a formal statement declaring that the document is issued under the sole responsibility of the manufacturer. You must also list the object of the declaration, allowing authorities to easily trace the document back to the physical box or mailer.

Crucially, the PPWR Declaration of Conformity must state that the packaging complies with Regulation (EU) 2025/40, and provide references to the relevant harmonized standards applied to assess the packaging. Finally, the document requires the date, place of issue, and the physical signature of the legally responsible individual.

How long must you retain the signed document?

The paperwork burden extends far beyond the day you place the packaging on the market. Depending on the specific packaging category, you must hold the signed EU Declaration of Conformity and its supporting technical file for 5 to 10 years after the packaging format was last manufactured.

You must be prepared to present these files immediately. If an inspector requests the conformity files for a specific custom mailer you used three years ago, you must provide the exact signed document and the corresponding heavy metal test reports. You cannot simply rely on your supplier's word that they kept a copy.

What should you do right now?

Determine exactly who in your supply chain holds the legal manufacturer status. If your e-commerce brand carries the liability, start gathering material safety data from your suppliers to build the technical files behind each declaration.

If your suppliers are based outside the EU, walk them through the PPWR compliance rules for importers: they will need to run chemical testing and provide exact material weights before you can sign anything. The duty is live, so an unanswered supplier email is now an open compliance gap rather than a task for later.

Don't let compliance paperwork stall your European expansion. See Gramta in action to organise your supplier data and securely store your declarations of conformity in a central, audit-ready platform.

Sources:

• Regulation (EU) 2025/40 – Article 18: Obligations of Importers
• Regulation (EU) 2025/40 – Article 5: Substances of Concern
• Regulation (EU) 2025/40 – Annex VIII: EU Declaration of Conformity
• The European Packaging and Packaging Waste Regulation (PPWR): A Strategic Compliance Framework for Global Supply Chains
• PPWR compliance deadlines explained: what applies from August 2026 and what comes later