Knowledge

The Declaration of Conformity for packaging: who signs, what it says

Since 12 August 2026, packaging placed on the EU market must be covered by a Declaration of Conformity. It is one of the first PPWR obligations to apply, with no transitional period — and it is the document that most often decides whether an import file is complete.

The obligation in one paragraph

Under Article 15 of Regulation (EU) 2025/40, the manufacturer of packaging must carry out the conformity assessment procedure and draw up a Declaration of Conformity before the packaging is placed on the market. Article 15(12) adds a condition that matters for buyers sourcing from outside the EU: under the circumstances set out there, the person who supplies the packaging can be regarded as the manufacturer — which puts the obligation on the supplier, not only on the buyer's EU entity.

What it contains

Identification of the packaging and the economic operator responsible for it
The EU regulation the declaration refers to (Regulation (EU) 2025/40 and the requirements applied)
The harmonised standards or other technical specifications used in the assessment
Where applicable, the notified body involved and the certificate reference
Place and date of issue, plus the name and signature of the person authorised to bind the organisation

Why a supplier's letter is not enough

A one-page confirmation on company letterhead that the packaging "complies with EU regulations" does not demonstrate anything: it names no regulation, no standard, no conditions of use. Under Article 15 the file has to be traceable. In practice, market surveillance authorities and retail compliance teams ask for the declaration plus the technical documentation behind it, and importers must be able to produce them on request.

What we hand over

Declaration of Conformity naming the packaging, the material and the requirements applied
Technical documentation: composition by layer with material codes, grammage, adhesives, coatings and inks, plus statements on substances of concern
Migration test reports from accredited laboratories where food contact applies
Recyclability statement and the material and weight data your national registration needs

Timing

The declaration must exist before the packaging is placed on the market — so it belongs with the quotation and the pre-production sample, not with the shipping documents. Ask for the file before you pay the deposit: a supplier who can produce it then, can produce it when the authority asks.

Frequently asked questions

Do I need a Declaration of Conformity for every order?

It applies to the packaging as placed on the market. If the structure and material are unchanged, the declaration covers the packaging; if the specification changes, the documentation is updated. We reissue the file when the specification changes.

Can a Chinese supplier issue the Declaration of Conformity?

Article 15(12) provides for the supplier to be treated as the manufacturer in the circumstances it sets out — so in many structures the supplier does issue it. In other cases the EU importer is the responsible manufacturer. Either way, the supplier must provide the technical evidence behind the declaration, which is the part that cannot be improvised.

What happens if the documentation is incomplete?

In practice the goods are held up: customs or a retail customer's compliance team requests the file, the missing test data has to be commissioned retrospectively, and the shipment waits. That is why we build the file before production.

Request a quotation

Send your item, size, quantity, artwork status and destination country — we reply with price, lead time and the compliance documents you need for your market (PPWR, food contact, Declaration of Conformity).

Send your RFQ or email sales@huaxinjiayuan.com