Regulation (EU) 2025/40 · applies from 12 Aug 2026
PPWR calls for three documents. Issue them from your own data, not from three files
For packaging manufacturers who heard „please send the declaration of conformity” from a customer and realised they had nothing to issue it from. We provide the tool that assembles the documents from your material and construction data. The substance stays yours.
Thirty minutes online, no sales deck. You leave with a list of gaps whether or not we end up working together.
Three documents, not one
The most common gap we find on the shop floor: the company has the third row and not the first two — because it has always sent a datasheet and the topic looks closed.
Technical documentation
Description of the packaging, materials, assessment against articles 5–12, test and calculation results, plus the documents from your material suppliers.
Stays with the manufacturer, shown to market surveillance on request.
Annex VII · art. 38 · module A
EU declaration of conformity
A one-page statement issued under the manufacturer's sole responsibility: packaging identification, company details, standards referenced.
Issued to customers — per packaging type, not per SKU.
art. 39 · template per Annex VIII
Product datasheet
Commercial specification: internal and external dimensions, weight with tolerance, board parameters, blank drawing.
Goes to the B2B customer and replaces neither of the above.
commercial document · not required by PPWR
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 covers a packaging type, not a line in your price list.
- The unit of conformity is a combination of construction, material grade and supplier — a different size alone does not create a new type.
- You can work out the ceiling in two minutes: number of material grades times the number of construction classes you actually run. The real figure is lower, because not every combination occurs.
- A plant with three thousand SKUs usually ends up with a few dozen declarations, not a few thousand.
- Datasheets run the other way — as many as you have customers and products. And those, not the declarations, are the argument for a tool.
That single number changes the whole conversation: from „we need to hire someone full time for paperwork” to „this is a week of work plus tidying up the material database”.
What the work looks like
The office picks a material index and a construction. Composition, grammage, ECT and thickness come from the database, external dimensions and weight are calculated from the geometry, and the document takes shape in front of the operator.
Mockups show the layout of the screens and documents from the rollout. Customer names and indexes are illustrative. The interface is shown in Polish, as it runs at the client.
What you get
The scope mirrors a rollout at a corrugated board manufacturer. The material database and document styling change; the rest is the same.
EU declaration generator
Annex VIII template, grouping by packaging type, your own numbering, issue date editable backwards.
Datasheet generator
A commercial document in your own layout, with internal and external dimensions and weight with tolerance.
Material database
Picking an index fills in composition, grammage, ECT, flute type and thickness. One place instead of three price lists.
Construction dictionary
FEFCO codes or the equivalent for other materials, with a blank drawing generated from the dimensions.
Register with an immutable archive
An issued document is stored as a file with a checksum. Retention of 5 years (single use) and 10 years (reusable).
Rollout and office training
Launch on your data, two hours of training and support through the first week of live work.
Out of scope — deliberately and in writing
ERP integration, normalising several supplier databases at once, back-filling existing SKUs and — above all — responsibility for the substance of the documents. The engine and formulas are ours; what you declare is yours.
Rollout
OPAK KREFT — corrugated board packaging manufacturer
Thirty years in business, made-to-order production only, around three thousand items in the system and two hundred customers on file. The data needed for the documents lived in spreadsheets of board compositions, in three suppliers' price lists and in a die-cut program with no API. Today the office issues a full set of documents from one index and one construction.
items in the system
declarations instead of thousands
archive retention
We are a fit if
- You make packaging to order — corrugated and solid board, plastics, wood, labels.
- You have more than two hundred active SKUs and buy material from more than one supplier.
- Your B2B customers — food, pharma, automotive, EU exports — are already asking for documents.
- You currently assemble a document by copying data out of at least three different files or programs.
We are not a fit if
- You only buy and resell packaging — that role carries different obligations, and the work starts with establishing them.
- You are looking for legal advice or a conformity assessment. We are not a law firm and we do not assess your packaging.
- You have a dozen SKUs and one supplier. A spreadsheet and a decent procedure will do — revisit this in a year.
- You expect the tool to fill in fields you have no supplier document for. That we will not do.
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 the generator's.
„PPWR compliance: Yes” as a field
Conformity is not a tick box. It is the result of an assessment under articles 5–12, recorded in the technical documentation.
„Recyclability class: A” today
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%” with no basis
A marketing claim with no backing in a supplier declaration is an unfair commercial practice, not a formality.
PFAS on a transport box
The PFAS limit applies to food-contact packaging. 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 the one signing it.
An archive that is a folder on a drive
A year later nobody can reconstruct which version went to whom. You have to archive the generated file, not just the data behind it.
A rule worth writing into your own procedure: a field with no backing in a supplier declaration stays empty or reads „to be confirmed”. Never „Yes”.
Go deeper
EU declaration of conformity
What the Annex VIII template must contain, who signs it, and how many you actually need.
Read onTechnical documentation
The file that stays with you and that market surveillance asks for. Annex VII and module A.
Read onPackaging datasheet
A commercial document PPWR does not require — and one the other two do not replace.
Read onPPWR deadlines
What applies from 12 August 2026 and what waits until 2030.
Read onFrequently asked questions
Is a datasheet enough as a PPWR document?+
No. A datasheet is a commercial document and is not required by PPWR. The regulation calls for technical documentation, which stays with the manufacturer, and an EU declaration of conformity, which you issue to customers.
I have three thousand SKUs — do I need three thousand declarations?+
No. A declaration covers a packaging type, meaning a combination of construction, material and supplier. A difference in dimensions does not create a new type. A plant with a few thousand items usually ends up with a few dozen declarations.
Can I state a recyclability class and recycled content?+
Design-for-recycling criteria take effect on 1 January 2030, and recycled-content targets mainly concern plastics. Declaring those values without backing in a supplier document is a claim without a basis — leaving the field blank is safer.
Do you take responsibility for the content of the documents?+
No. We provide the engine, the formulas and the templates; the substance and what the company declares stay on its side. We do not invent values — we carry them over from the material supplier's declaration, and fields with no backing stay empty.
Do we have to replace our ERP?+
No. At the manufacturer where we rolled this out, the ERP kept invoicing and the PPWR documents are produced in a separate browser application, on material and construction data. No revolution — an extension.
How long must the documents be kept?+
Five years for single-use packaging and ten years for reusable packaging. You have to archive the generated file in the version that reached the customer — regenerate it after a material change and it comes out different.
How long does it take?+
Getting the generator running on your data is a matter of weeks, not quarters. The longest critical path is usually not on our side but in waiting for declarations of conformity from your material suppliers — which is why the first email to them is worth sending before you talk to us.
Show us what you have — we will tell you what is missing
Thirty minutes online. We walk through your documents and material data, establish whether you are a manufacturer in the PPWR sense at all, and you leave with a list of gaps.
Reference material written during a real rollout, based on Regulation (EU) 2025/40. It is not legal advice or a conformity assessment. Confirm labelling deadlines with your legal adviser.