We can assist you with preparing or reviewing all aspects of the declaration of conformity.
We draft the Declaration of Conformity, allowing you to formally confirm that your product meets the regulatory requirements.
We can compile all the labeling elements required for your packaging, or assist you with reviewing an existing label.
11 February 2026 Entry into force of the Packaging and Packaging Waste Regulation (PPWR)
12 August 2026 The Packaging Waste Regulation (PPWR) comes into effect and marks the end of the transition period
1 January 2028 Publication of the official ‘Design for Recycling’ criteria and exemptions for the use of recycled materials
Over the next few years, the Packaging and Packaging Waste Regulation will provide the framework for stricter requirements regarding the recyclability of packaging and the reduction of packaging waste, and will set progressively stricter limits to achieve these objectives.
We guide you safely through the entire CE marking process. We identify the relevant EU regulations for your product, carry out the necessary risk assessment and prepare the complete technical documentation.
We prepare and update your safety data sheets. With our many years of experience in chemicals legislation and the assessment of hazardous substances, we can assist you quickly, reliably and on time.
We conduct a systematic risk assessment on your behalf, identify potential sources of danger and develop practical solutions to minimise risk.
We can provide you with comprehensive support as an external dangerous goods safety advisor, or offer ad hoc assistance with specific requirements relating to your dangerous goods.
The obligation to issue an EU declaration of conformity comes into effect on 12 August 2026. It's the date of application of the PPWR.
From 12 August 2026, the EU Packaging and Packaging Waste Regulation (PPWR) will require an EU declaration of conformity for all packaging. The manufacturer or importer who places the packaging on the market in the EU is responsible for drawing up this document.
Packaging is an item used to contain, protect, handle, deliver or present products. The material used is irrelevant. The PPWR classifies different types of packaging according to their function, material, design and format.
A manufacturer within the meaning of the PPWR is any natural or legal person who manufactures packaging or a packaged product. If a natural or legal person has packaging or a packaged product designed or manufactured in their own name, they are considered a manufacturer. It is irrelevant whether other brands appear on the packaging or the packaged product.
An exception is made for companies that fall under the definition of a micro-enterprise (in accordance with Recommendation 2003/361/EC). In this case, the supplier of the packaging is considered a manufacturer, provided that they are established in the same Member State.
"‘Distributor’ means any natural or legal person in the supply chain, other than the manufacturer or importer, that
makes packaging available on the market."
For the purposes of the PPWR "‘importer’ means any natural or legal person established within the Union that places packaging from a third country
on the market"
Placing on the market means the first making available of filled (with a product) or unfilled packaging on the Union market. In this context, ‘any supply, whether in return for payment or free of charge, of filled or unfilled packaging for distribution, consumption or use on the Union market in the course of a commercial activity’ is considered to be making available on the market.
Put simply, any manufacturer, importer or distributor is considered a producer provided that they first make products available in a Member State or unpack packaged products without being an end-user.
The detailed definition can be found in Article 3(1)(15) of the Packaging Regulation.
By introducing the PPWR, the EU aims to strengthen the circular economy, prevent waste and improve environmental protection.
To protect human health and the environment, there are requirements regarding the constituents and bio-based raw materials used in plastic packaging.
At the same time, the aim is to ensure the sustainable use of materials. The key measures in this regard include requirements for recyclability and recycling targets, the minimum recycled content for plastic packaging, and the compostability of packaging.
In addition to requirements for the packaging itself, measures are also being implemented to reduce or optimise the use of packaging. These measures include, for example, the establishment of reuse systems.
Article 15(3) of the PPWR sets out the retention period for the EU Declaration of Conformity. In the case of single-use packaging, it must be retained for five years from the date on which the packaging was placed on the market. For reusable packaging, the retention period is ten years from the date on which it was placed on the market.
