art. 39 · template per Annex VIII
EU declaration of conformity for packaging
The document your customer asks for. One page, issued under the manufacturer's sole responsibility and — against first impressions — needed in dozens, not thousands.
In short
The EU declaration of conformity is the manufacturer's statement that a given packaging meets the requirements of Regulation (EU) 2025/40. It is short, has a fixed list of clauses and contains no evidence — the evidence lives in the technical documentation that stays with you.
- It is issued by the manufacturer, meaning whoever places the packaging on the market under their own name.
- The unit is a packaging type: a combination of construction, material grade and supplier.
- It has no expiry date — you issue a new one after a change of material composition or construction.
- The layout is not prescribed; the list of clauses in Annex VIII is.
What it must contain
The Annex VIII template lists clauses you cannot skip. Their order and numbering are part of the template — a document missing a clause, or with the clauses shuffled, is worse than an ugly one.
In practice most of these fields are fixed company data and packaging-type data. You type them once; after that only the subject of the declaration and the number change.
- Unique identification of the packaging — type, model or marking that lets anyone find it.
- Name and address of the manufacturer and, where applicable, their authorised representative.
- A statement that the declaration is issued under the manufacturer's sole responsibility.
- The subject of the declaration — a description sufficient to identify and reconstruct the packaging.
- A statement of conformity with the relevant requirements of Regulation (EU) 2025/40.
- References to the harmonised standards or other technical specifications you rely on.
- Notified body details and any certificate issued — where such a body is involved at all.
- Place and date of issue, and the signature of the person acting for the manufacturer.
Who issues it and who signs
The packaging manufacturer issues the declaration. Your board supplier issues their own documents for their material — those do not replace your declaration for the finished packaging, although they are its material basis.
This is the point that surprises people most often. On the rollout this page comes from, the starting assumption was „the supplier will give us the declaration”. Working through the template made it clear that the plant issues the declarations, and what arrives from the supplier is input data, not a finished document.
It is signed by a person acting for the manufacturer. In a small plant that is usually the owner or a suitably authorised person from customer service — the regulation requires neither a second reviewer nor a separate power of attorney.
How many declarations you need
This is where calm and panic part ways. A declaration covers a packaging type — a combination of construction, material grade and supplier — not a line in your price list.
A manufacturer with three thousand items in the system but realistically a dozen board grades and a handful of construction classes issues a few dozen declarations. Everything else is a difference in size, and size does not create a new type.
An example from the plant: one delivery note had eight lines and required ten datasheets but only two declarations — because all but two lines sat on the same construction and the same board.
- Count the material grades you actually run in production, not the ones in your price list.
- Count the construction classes that appear in the last three months of orders.
- Their product is the ceiling. The real figure is lower, because not every combination occurs.
- Limiting yourself to one supplier per material cuts that number fastest — and that is exactly what plants do when they do not want to drown in documents.
When a new one is required
A declaration does not expire. Issued today or a year from now for the same packaging type, it is the same document as long as nothing has changed.
You issue a new one when anything underpinning the assessment changes: material composition or grammage, the material supplier, the construction, or the standards referenced. Which is why the way your supplier notifies parameter changes matters so much — without it you find out by accident, and every document based on that material is already out of date.
Good practice: put the declaration number next to the line on the invoice or delivery note. The customer then links the delivery to the document without calling your office, and you keep a trace of which version went where.
Four things that spoil a declaration
We have seen all of them on documents circulating in the industry. Each one lands on the manufacturer, not on whoever wrote the template.
One declaration per SKU
Issued separately for every line in the price list, you end up with thousands of documents nobody will update after a supplier change. That is not diligence, that is future chaos.
The supplier's declaration, retyped
The supplier's document covers their material, not your packaging. Signing it under your own name means declaring something you never assessed.
Standards referenced with no basis
Citing a standard you did not actually apply in the assessment is misleading. Better one standard you truly use than three that look impressive.
No number and no version trail
Without numbering and an archive you cannot show which version the customer received in March. Regenerated from current data, it will come out different.
Frequently asked questions
Who issues the declaration of conformity for packaging?+
The manufacturer, meaning whoever places the packaging on the market under their own name. It is issued under their sole responsibility. Your board supplier issues documents for their material, not for the finished packaging.
Is the layout of the declaration prescribed?+
The regulation gives a template and required clauses, not a graphic layout. You can produce the document in your own styling as long as it contains every element from Annex VIII.
Does the declaration have to be filed with an authority?+
No. You make it available to customers and to market surveillance authorities on request. There is no register to submit it to.
Can a declaration be back-dated?+
The issue date is the date on which the manufacturer actually declares conformity. If the document is produced later than the delivery it covers, settle the rule internally and write it down rather than improvising per document.
What if we are both a manufacturer and a distributor?+
Very common. The same company is often a manufacturer for most of its range and a distributor for packaging bought finished and resold. Roles are decided per product, and it is that smaller share everyone forgets about.
Related topics
We will work out how many declarations you actually need
Thirty minutes online. We look at your material grades and constructions, count the packaging types, and tell you what can be issued straight away and what waits on a supplier document.
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.