Who signs the PPWR declaration of conformity?

The manufacturer, after running the Annex VII self-assessment and drawing up the technical documentation (Articles 15(2) and 38). No notified body is involved. Where the brand is a micro-enterprise and its packaging supplier is in the same member state, the supplier is the manufacturer.

What does the PPWR declaration of conformity cover today?

From August 12, 2026 it covers the Article 5 substance limits, including PFAS in food-contact packaging and the 100 mg/kg heavy-metals limit, recyclability under Article 6(1), and minimization, the last two assessed against the Directive 94/62/EC requirements and their standards. Compostability, labels, recycled content and the recyclability grades join it on the dates they apply.

How long must the declaration be kept?

Five years after the packaging is placed on the market, or 10 years for reusable packaging (Article 15(3)). Importers keep a copy for the same period (Article 18(7)).

PPWR Atlas / Declaration of Conformity

PPWR Declaration of Conformity: What It Covers and When

Since August 12, 2026, a manufacturer must draw up an EU declaration of conformity before placing packaging on the EU market. It covers each requirement of Articles 5 to 12 once that requirement applies, so it must be kept up to date as its coverage grows.

Who signs, keeps, and checks it

The manufacturer runs the Annex VII self-assessment (Module A), draws up the technical documentation, and signs the declaration (Arts. 15(2) and 38), with no notified body and no CE mark.
The manufacturer is the company that has the packaging made under its own name or trademark; where that company is a micro-enterprise and its packaging supplier is in the same member state, the supplier is the manufacturer, and both conditions must hold (Art. 3(1)(13)(b)).
Suppliers must give the manufacturer the information it needs (Art. 16).
An authorized representative appointed by written mandate may keep the declaration and documentation (Art. 17), a different role from the EPR representative under Art. 45.
The manufacturer keeps both for 5 years after the packaging is placed on the market, or 10 for reusable packaging, and importers keep a copy for the same period (Arts. 15(3) and 18(7)).
The declaration is in the language each member state requires, and one declaration may cover several Union acts (Art. 39(2) and (3)).
It is not filed anywhere; authorities are to endeavor to check part of the declarations each year, on a risk basis (Art. 39(5)).

What the declaration covers, date by date

Where a date depends on a Commission act, the row gives the condition and the act's status.

Applies from	Requirement
August 12, 2026	Substances of concern in packaging minimized Art. 5(1)Applies with the Regulation (Art. 71).
August 12, 2026	Lead, cadmium, mercury and hexavalent chromium at 100 mg/kg or less in total Art. 5(4)Applies with the Regulation (Art. 71).
August 12, 2026	PFAS limits for food-contact packaging Art. 5(5)Fixed in the Regulation.
August 12, 2026	Packaging is recyclable Art. 6(1)Until Art. 6(2)(a) applies, assessed against Directive 94/62/EC and EN 13430:2004 (C/2026/3084).
August 12, 2026	Packaging claimed as reusable meets the Art. 11(1) conditions Art. 11(1)Applies with the Regulation (Art. 71).
August 12, 2026	No misleading marks on matters with harmonized labeling Art. 12(8)Its reach widens when the Art. 12(1) label applies (a reading of the text).
August 12, 2026 to December 31, 2029	Minimization under the Directive 94/62/EC essential requirements Art. 70(1)(b)Assessed with EN 13428:2004 until Art. 10 applies (C/2026/3084).
February 12, 2027	EPR-scheme marks only through a QR code or other open digital marking Art. 12(9)Fixed in the Regulation.
February 12, 2028	Listed packaging and fruit and vegetable stickers compatible with industrial composting Art. 9(1)Fixed in the Regulation.
February 12, 2028	Other packaging, including biodegradable plastic, designed for material recycling Art. 9(3)Fixed in the Regulation.
August 12, 2028 or later	Harmonized material-composition sorting label Art. 12(1)Or 24 months after the Art. 12(6) or 12(7) implementing acts enter into force, whichever is the latest. Acts due August 12, 2026 (deadline missed, as at October 1, 2026).
August 12, 2028 or later	A recycled-content label, where used, follows the Art. 12(6) specifications Art. 12(4)Or 24 months after the Art. 12(6) implementing act enters into force, whichever is the latest. Act due August 12, 2026 (deadline missed, as at October 1, 2026).
January 1, 2029 or later	Recycled-content calculation and verification follow the Art. 7(8) rules Art. 7(11)Or 24 months after the Art. 7(8) implementing act enters into force, whichever is the latest. Act due December 31, 2026 (call for evidence closed, as at October 1, 2026).
February 12, 2029 or later	Reusable packaging labeled as reusable, with a QR code or data carrier Art. 12(2)Or 30 months after the Art. 12(6) implementing act enters into force, whichever is the latest. Act due August 12, 2026 (deadline missed, as at October 1, 2026).
January 1, 2030 or later	Packaging designed for recycling Art. 6(2)(a)Or 24 months after the Art. 6(4) delegated acts enter into force, whichever is the latest. Acts due January 1, 2028 (pending, as at October 1, 2026).
January 1, 2030 or later	Only packaging recyclable within grades A, B or C Art. 6(3)Or 24 months after the Art. 6(4) delegated acts enter into force, whichever is the latest. Acts due January 1, 2028 (pending, as at October 1, 2026).
January 1, 2030 or later	Minimum post-consumer recycled content in plastic packaging, first tier Art. 7(1)Or 3 years after the Art. 7(8) implementing act enters into force, whichever is the latest. Act due December 31, 2026 (call for evidence closed, as at October 1, 2026).
January 1, 2030	Weight and volume reduced to the minimum necessary Art. 10(1)Fixed in the Regulation.
January 1, 2035 or later	Packaging collected, sorted and recycled at scale Art. 6(2)(b)Or five years after the Art. 6(5) implementing acts enter into force, whichever is the latest. Acts due January 1, 2030 (pending, as at October 1, 2026).
January 1, 2038	Only packaging recyclable within grades A or B Art. 6(3)Fixed in the Regulation.
January 1, 2040	Minimum post-consumer recycled content in plastic packaging, second tier Art. 7(2)Fixed in the Regulation.

Built from the PPWR Atlas duty records. Not legal advice. Every dated obligation is on the timeline; the declaration's structure is on Annex VIII and the self-assessment on Annex VII.