Each packaging type needs a declaration of conformity on file

What changed

From 2026-08-12 a packaging producer placing packaging on the EU market must draw up an EU declaration of conformity and keep technical documentation covering the conformity assessment, the material composition and the recyclability of each packaging type. Market surveillance authorities can ask for both. A declaration is a document the producer signs and holds — it is not the same artefact as an EPR registration number, and holding an ERN does not substitute for it.

Who it catches

Businesses that place packaging, or packaged products, on the EU market, including non-EU sellers acting through an authorised representative.

What to do

Write one declaration per packaging type — not per SKU — and attach the material BOM and any test reports to it. Keep the file for at least five years; the deadline that matters is the date an authority asks, not the date on the file.

Source: Regulation (EU) 2025/40 on packaging and packaging waste · last verified 2026-10-31

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