Packaging Declaration of Conformity — what changes under PPWR
If you have placed packaging on the market before, you have probably already dealt with proving packaging conformity, most often through a heavy-metals certificate or, in some cases, a packaging declaration of conformity. PPWR does not scrap that logic, but it significantly broadens it: it introduces a single EU Declaration of Conformity for the whole EU market, on a prescribed model and backed by technical documentation.
What applied until now (the Croatian example)
Croatia's packaging regulation (Pravilnik, Narodne novine 137/2023) transposes the old Packaging Directive 94/62/EC. For packaging placed on the market it requires that the total content of heavy metals (lead, cadmium, mercury and hexavalent chromium) must not exceed 100 mg/kg.
How that was proven depended on the case: a heavy-metals certificate from an authorised person (the main instrument), a declaration of conformity as a permitted substitute for EU-sourced packaged goods, or a specific declaration for closed-loop returnable plastic crates and pallets. In other words, Croatian sellers knew a national heavy-metals regime, not a general declaration of conformity for all packaging. That is what PPWR changes.
What PPWR introduces: the EU Declaration of Conformity
Under PPWR, the EU Declaration of Conformity is the document in which the manufacturer, under its sole responsibility, confirms that the packaging meets the applicable requirements of the Regulation. It is no longer a narrow heavy-metals statement, but a declaration of conformity with a whole range of requirements (Articles 5–12), on a prescribed model (Annex VIII) and backed by technical documentation (Annex VII).
The key differences from the previous national document:
| Previous national document | EU Declaration of Conformity (PPWR) | |
|---|---|---|
| Legal source | National regulation (Directive 94/62/EC) | Directly applicable Regulation (EU) 2025/40 |
| What it covers | Mainly heavy metals | Conformity with the requirements of Articles 5–12 |
| Substances | Heavy metals (≤ 100 mg/kg) | Heavy metals plus PFAS in food-contact packaging |
| Format | Free-form / national form | Prescribed model (Annex VIII) |
| Who draws it up | Packer / producer of packaged goods | Manufacturer, under sole responsibility |
| Assessment | Third-party (authorised) certificate | Self-assessment (internal production control, Annex VII) |
| Retention | Case-dependent | 5 yrs (single-use) / 10 yrs (reusable) |
Who draws up the document matters too: the manufacturer. The importer obtains and keeps a copy and verifies the assessment was carried out; the distributor checks the required markings. If you place packaging on the market under your own name or brand, you are generally the manufacturer yourself and draw up the declaration. More on that in Importing packaging from China? Your PPWR obligations.
Same heavy-metals limit, new legal framework
The 100 mg/kg limit for the sum of heavy metals does not disappear. It carries over unchanged into Article 5 of PPWR and, from 12 August 2026, applies directly as EU law rather than via the national regulation. Alongside heavy metals, Article 5 also introduces, from the same date, the ban on PFAS in food-contact packaging.
Directive 94/62/EC itself is repealed with effect from 12 August 2026. What happens to the national regulation (whether and when it is amended, and how far the national certificate persists alongside PPWR) is a matter of national law and legal assessment; this guide does not claim PPWR "abolishes" the national document, only that the directly applicable Regulation now overtakes and absorbs it.
What to do now
- Establish your role for each type of packaging (manufacturer, importer, distributor).
- If you are the manufacturer, prepare the EU Declaration of Conformity under Annex VIII and the technical documentation.
- Check that the packaging meets the substance restrictions (heavy metals, PFAS).
- Retain the documentation for 5 or 10 years and provide it to the authorities on request.
For the full picture see the guide to Regulation (EU) 2025/40, and we're preparing a free EU Declaration of Conformity template following Annex VIII. Leave your email and we'll send it the moment it's ready.
This guide is informational, helps you prepare documentation, and is not legal advice. For an assessment of your situation, including how it relates to national rules, consult a professional.