In this article
Regulation (EU) 2025/40, known as PPWR, applies from 12 August 2026. The typical reaction from a packaging manufacturer is not „I am afraid of a fine”. It is: a customer emailed asking for a declaration of conformity and I have nothing to issue it from.
This is not a summary of the regulation. It is a list of the things somebody will ask about and the places where it is easy to trip — written during a real rollout at a corrugated board packaging manufacturer, not at a webinar. Three points below are worth the rest: there are three documents, a declaration covers a packaging type, and half the fields competitors put on datasheets only start to exist in law in 2030.
Start by asking whether this applies to you at all
PPWR places different obligations on different roles. Before you fill anything in, establish who you are for a given product — because on one you may be the manufacturer and on another the distributor.
- You make the packaging and place it on the market under your own name — you are the manufacturer and everything below applies.
- You buy finished packaging and resell it under your own index — that usually changes the role and who issues the declaration. Settle it before the first delivery.
- You buy packaging and pack your own goods in it — you are the end user, the obligations differ and largely sit with your supplier.
The trap: many plants do both. The same company is often the manufacturer for ninety per cent of its range and a distributor for ten — and it is those ten everyone forgets. At the manufacturer we worked with it applied to packaging bought finished and resold under their own brand: they had to produce their own datasheet instead of passing on the supplier's.
Three documents — and which one you probably already have
This is the heart of it. People speak about PPWR „documentation” in the singular, while the regulation and commercial practice produce three different things, each going somewhere else.
- 1
Technical documentation
Description of the packaging, materials, assessment against art. 5–12, test and calculation results. Stays with you, shown to market surveillance on request. Basis: Annex VII, art. 38, module A.
- 2
EU declaration of conformity
Number, description of the packaging, manufacturer details, standards referenced, statement of sole responsibility. Issued to customers, per packaging type. Basis: art. 39, template per Annex VIII.
- 3
Product datasheet
Commercial specification: dimensions, material, execution parameters. Goes to the B2B customer and does not follow from PPWR — it is the document you have been sending for years.
That is gap number one and the easiest to close, because you mostly hold the data already. We wrote up both missing documents separately: what goes into the technical documentation and how the datasheet differs from the documents the regulation requires.
How many declarations you actually need
The most common question and the biggest needless panic: „I have three thousand SKUs, do I issue three thousand declarations?”. No.
A declaration of conformity covers a packaging type, not a line in your price list. All packaging made from the same material, in the same construction and with the same material properties falls under one declaration — a difference in dimensions does not create a new type. A new material or a different construction class means a new declaration.
Work it out in two minutes: the number of material grades you actually run times the number of construction classes appearing in the last three months. That is the ceiling, and the real figure is lower, because not every combination occurs. A plant with three thousand items usually ends up with a few dozen declarations. More on the template and who signs it: the EU declaration of conformity.
Half the fields cannot be filled from your own data
Composition, material code, recycled content and substance statements have to come from your material supplier's declaration of conformity. That is not work you can schedule — it is waiting for a reply from someone with a hundred such emails in their inbox right now. If you have not sent it, you have not started. Email every supplier separately and ask for:
- a declaration of conformity or material sheet for every material index you order from them,
- information on recycled content and on the material code,
- a statement on the sum of heavy metals — lead, cadmium, mercury and hexavalent chromium — confirming it does not exceed 100 mg/kg,
- information on PFAS, if the material goes into food-contact packaging,
- the process by which they will notify updates to this data when parameters or composition change.
What applies now and what waits four more years
This is where the industry carries the most misinformation. Some of the requirements you hear about at seminars only take legal effect in 2030 — and writing them on documents today lands on you, not on the seminar's author.
- From 12 Aug 2026: technical documentation and the EU declaration of conformity. The basis for everything else.
- From 12 Aug 2026: the sum of heavy metals up to 100 mg/kg — applies to every packaging. Plus the PFAS limit, but only for food-contact packaging.
- 2027–2028: identification for extended producer responsibility, and harmonised material labelling with a QR code. Dates depend on implementing acts.
- From 1 Jan 2030: recyclability class under art. 6 and Annex II. Recycled-content targets also aim at 2030 and mainly concern plastics.
The practical consequence is one: until you hold a supplier statement, you do not declare a recyclability class or recycled content. We collected the full timeline on a separate page: PPWR deadlines.
Five entries you must not make
We see them on documents produced by tools and templates circulating in the industry. The signature at the bottom is yours — not that of whoever generated it.
- „PPWR compliance: Yes” as a field on the datasheet. Conformity is not a tick box. It is the result of an assessment under art. 5–12, recorded in the technical documentation.
- „Recyclability class: A”. Design-for-recycling criteria take effect on 1 January 2030. Today it is a voluntary claim that still needs backing from a supplier document.
- „Recycled content: 100%” on board, with no supplier declaration. A marketing claim with no basis is an unfair commercial practice, not a formality.
- „PFAS limit: compliant” on a B2B transport box that will never touch food. Filling in a field that does not apply is worse than leaving it blank.
- Auto-filling fields with no source. If a tool writes a value that appears in no supplier document, it is inventing it — and you are signing it.
The archive — nobody talks about it and it changes the most
You keep documentation and declarations for five years for single-use packaging and ten years for reusable. That is not a system feature, it is an obligation — and it is what breaks solutions based on a folder on a network drive.
Why this is not a detail: a customer asks for the document they received in March. If the supplier changed the grammage in the meantime, a document generated today from the same data will be different. So you archive the generated PDF, not just the data behind it — and you must be able to show which version went to whom.
A two-minute test: is a spreadsheet enough
The honest answer is „it depends” — and it can be worked out. Count how many times you answer yes:
- I have more than 200 active SKUs.
- I buy material from more than one supplier, and each codes composition their own way.
- I issue documents for more than 20 customers, and material parameters change at least once a quarter.
- I assemble a document by copying data from at least three different files or programs.
- Customers have already asked for PPWR documents, and I have nobody doing this full time — nor do I intend to hire them.
Zero or one yes — a spreadsheet and a decent procedure will do. Seriously, do that and revisit in a year. Two or three — the spreadsheet will hold for the first quarter and fall apart at the first parameter change at a supplier; price the tool before that, not after. Four or five — doing this by hand is a full-time job, not because there are many documents but because every supplier change triggers a review of everything.
Takeaways
Three sentences worth keeping. There are three documents, and the one you have been sending for years is the only one the regulation does not require. A declaration covers a packaging type, so there are dozens of them, not thousands. A field with no backing in a supplier declaration stays empty — and that is a safeguard, not carelessness.
If you want to see this in a working system, we described it in a case study at a corrugated board packaging manufacturer. The offer and the topic pages are collected on the PPWR for packaging manufacturers page, and our broader approach to systems for production plants on the manufacturing page.
Mateusz Kozłowski
Founder of flowbiz · Process automation expert
I implement automations, integrations and AI in mid-sized companies across Pomerania and Kuyavia-Pomerania.
