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PPWR Article 38: Conformity assessment procedure

Article 38 of Regulation (EU) 2025/40, the EU Packaging and Packaging Waste Regulation.

Applies fromAugust 12, 2026
BindsManufacturers
EvidenceLocked read in the EUR-Lex text

What it requires

Conformity of packaging with Articles 5 to 12 is assessed under the procedure in Annex VII. Annex VII is Module A, internal production control, under which the manufacturer ensures and declares on its sole responsibility that the packaging meets the requirements of Articles 5 to 12 that apply to it. Recital (109) says CE marking on packaging should not indicate the packaging's compliance with this Regulation, only the packaged product's compliance with the applicable Union product law.

What the declaration of conformity covers on each date, and who signs and keeps it, is on the declaration of conformity page.

This is a plain-English summary for planning, not legal advice, and it is not a substitute for the text. Read Article 38 in full at EUR-Lex, and verify against the Official Journal before any compliance decision.

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