PPWR declaration of conformity: who signs it, what it contains

A PPWR declaration of conformity is a short document in which the manufacturer of the packaging states, under its own signature, that the packaging meets the requirements of Articles 5Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 5Click opens the article on EUR-Lex. to 12Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12Click opens the article on EUR-Lex. of Regulation (EU) 2025/40Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationThe whole regulationClick opens the law on the EU Publications Office. (Art. 39(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 39, paragraph 1Click opens the article on EUR-Lex.). Nobody issues it to you. You write it from the model in Annex VIII once the conformity assessment is done, and the duty has run since 12 August 2026 (Art. 15(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15, paragraph 2Click opens the article on EUR-Lex., Art. 71Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 71Click opens the article on EUR-Lex.). If your own name or brand is on the packaging or on the packaged product, you are the manufacturer, and the declaration is yours to sign.

What you do:

1. Settle whether you are the manufacturer. You are if you manufacture the packaging or the packaged product, or have either one designed or made under your own name or trademark, whatever other trademark is visible (Art. 3(13)(a)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 13, point (a)Click opens the article on EUR-Lex.). There is one manufacturer per packaging in the supply chain. A business that only resells another company’s branded goods is not the manufacturer.
2. Your packaging suppliers must give you the information and documentation you need to show conformity (Art. 16(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 16, paragraph 1Click opens the article on EUR-Lex.).
3. Carry out the conformity assessment of Annex VII, Module A, or have it carried out for you, and write the technical documentation (Art. 15(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15, paragraph 2Click opens the article on EUR-Lex., Art. 38Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 38Click opens the article on EUR-Lex.). Both come before the packaging is placed on the market.
4. Draw up the declaration on the Annex VIII model, one for each packaging type (Art. 39(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 39, paragraph 2Click opens the article on EUR-Lex., Annex VII point 4). Write it in, or translate it into, the language the EU country of sale requires. Cover only the requirements that apply to the packaging today.
5. Give the packaging a type, batch or serial number or another identifying element. Show your name and postal address on the packaging or in a QR code or another data carrier. Only where that is not possible, give them in a document that comes with the packaged product (Art. 15(5)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15, paragraph 5Click opens the article on EUR-Lex., Art. 15(6)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15, paragraph 6Click opens the article on EUR-Lex.).
6. Keep the declaration and the technical documentation for 5 years from the date single-use packaging was placed on the market, and 10 years for reusable packaging (Art. 15(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15, paragraph 3Click opens the article on EUR-Lex.). Hand them to an authority within 10 days of a reasoned request (Art. 15(10)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15, paragraph 10Click opens the article on EUR-Lex.).
7. Update the declaration when the packaging design, its characteristics or the standards you applied change, and assess again where the change could affect conformity (Art. 15(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15, paragraph 4Click opens the article on EUR-Lex., Art. 39(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 39, paragraph 2Click opens the article on EUR-Lex.).

The PPWR conformity assessment is internal control, and the declaration records it

The declaration states that “the fulfilment of the requirements laid down in or pursuant to Articles 5 to 12 has been demonstrated” (Art. 39(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 39, paragraph 1Click opens the article on EUR-Lex.). It follows a conformity assessment, and the assessment is internal production control: the manufacturer does it and declares “on his sole responsibility” that the packaging satisfies the requirements of Articles 5 to 12 “that apply to it” (Annex VII, Module A, point 1). By drawing the declaration up, the manufacturer takes responsibility for the packaging’s compliance (Art. 39(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 39, paragraph 4Click opens the article on EUR-Lex.).

No CE marking goes on the packaging to show this. A CE marking on packaging says only that the packaged product meets its own EU product law, where that law asks for one. The declaration alone shows that the packaging meets the PPWR (recitals 109 and 110).

The manufacturer draws up the declaration, and there is one per packaging

A manufacturer is anyone who manufactures packaging or a packaged product. A person who has packaging or a packaged product designed or made under its own name or trademark is the manufacturer, whatever other trademark is visible (Art. 3(13)(a)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 13, point (a)Click opens the article on EUR-Lex.). In practice:

• Sales and grouped packaging: normally the company that fills it and places the packaged product on the market, often the brand owner.
• Transport and service packaging: normally the company that makes it, unless the user’s own name or trademark is on it. Then the user is the manufacturer.
• Packaging with no name or trademark: the person who places the order and decides the design specifications.

That list is the Commission’s reading of the definition, which adds that “there is always only one manufacturer in a supply chain” (Commission Notice C/2026/3084, section 2; guidance, not law).

A micro-enterprise with a packaging supplier in the EU hands the paperwork to that supplier. Where the person who has the packaging made under its own name or trademark is a micro-enterprise under Recommendation 2003/361/EC, and the supplier of the packaging is located in the Union, the supplier is the manufacturer for the purposes of Article 15Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15Click opens the article on EUR-Lex., the assessment, the documentation and the declaration included (Art. 15(12)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15, paragraph 12Click opens the article on EUR-Lex.). What that rule does to producer registration and to the other duties is on PPWR.

An importer checks the declaration and keeps a copy. An importer does not repeat the assessment. Before placing packaging on the market it makes sure the manufacturer carried it out and drew up the technical documentation. It keeps a copy of the declaration at the disposal of the market surveillance authorities and ensures the technical documentation can be made available to them on request (Art. 18(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 18, paragraph 2Click opens the article on EUR-Lex., Art. 18(7)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 18, paragraph 7Click opens the article on EUR-Lex.). A distributor checks the producer’s registration, the labelling and the manufacturer’s and importer’s identification details; the list in its Article carries no duty to draw up or keep the declaration (Art. 19(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 19, paragraph 2Click opens the article on EUR-Lex.).

An importer or distributor that sells under its own name becomes the manufacturer. So does one that modifies packaging already on the market in a way that could affect compliance. It is then “considered to be a manufacturer” and carries the duties of Article 15 (Art. 21Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 21Click opens the article on EUR-Lex.). There is one exception. Where that importer or distributor is a micro-enterprise and the person that supplies it the packaging is located in the Union, the supplier is the manufacturer instead (Art. 21Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 21Click opens the article on EUR-Lex.).

An authorised representative can draw up the declaration or keep it for the authorities, and the manufacturer stays responsible. A manufacturer may appoint one by a written mandate, and the mandate lets it keep the declaration and the technical documentation at the disposal of the national authorities, cooperate with them and hand over documents within 10 days (Art. 17(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 17, paragraph 1Click opens the article on EUR-Lex., Art. 17(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 17, paragraph 2Click opens the article on EUR-Lex.). The Commission’s guidance says the declaration is drafted by the manufacturer or by an authorised representative appointed by written mandate, and that the manufacturer remains the sole economic operator bearing legal responsibility (Commission Notice C/2026/3084, section 2; guidance, not law). The manufacturer’s duty to place on the market only conforming packaging, and its duty to draw up the technical documentation, are not part of the mandate (Art. 17(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 17, paragraph 2Click opens the article on EUR-Lex.). The role of an EU representative in general is on EU authorised representative.

A seller outside the EU is the manufacturer when its own brand is on the goods

If you ship from outside the EU and your name or trademark is on the packaged product or its packaging, you are the manufacturer under Article 3(13)(a), and the declaration is yours. An offer online counts as making the packaging available in the EU when it is directed at end users in an EU country (Art. 6Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 6Click opens the article on EUR-Lex.), and the first making available is placing on the market (Art. 3(10)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 10Click opens the article on EUR-Lex.). The Commission’s guidance gives the moment for imported goods as their release for free circulation at the end of the customs procedure (Commission Notice C/2026/3084, section 5; guidance, not law).

Three points follow from the text.

• You are not an importer. An importer is a person “established within the Union” that places packaging from a third country on the market (Art. 3(17)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 17Click opens the article on EUR-Lex.). The Commission reads that as a person with a registered address in an EU country, so a branch without its own legal personality is not an importer (Commission Notice C/2026/3084, section 4; guidance, not law). Where an EU importer sits between you and the buyer, it checks your declaration and keeps a copy (above). Where you ship straight to consumers and no EU-established person places the packaging on the market, there is no importer, and the declaration stays with you.
• Articles 15 to 22 ask for no EU-based holder of the declaration. They name no operator in the Union that a manufacturer outside the Union must have for it. Appointing an authorised representative is a choice (Art. 17(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 17, paragraph 1Click opens the article on EUR-Lex.).
• The EU operator rule of the Market Surveillance Regulation does not list the PPWR. Article 4Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office. of Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office. requires an operator in the Union for products under the acts listed in its paragraph 5 (Art. 4(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 1Click opens the article on EUR-Lex., Art. 4(5)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 5Click opens the article on EUR-Lex.). That list, as published, names no packaging law, and the PPWR amends only Annexes I and II of that Regulation (Art. 66Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 66Click opens the article on EUR-Lex.).

Do not mix this up with the representative that producer registration needs. Registering as a producer in each EU country, and any representative a country asks for in the producer register, are separate duties under Articles 44Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44Click opens the article on EUR-Lex. and 45Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45Click opens the article on EUR-Lex., set out on PPWR and EPR for online sellers. The authorised representative of Article 17Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 17Click opens the article on EUR-Lex. holds the declaration. The one of Article 3, point 20Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 20Click opens the article on EUR-Lex. handles the producer’s extended-producer-responsibility duties (Art. 3(19)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 19Click opens the article on EUR-Lex., Art. 3(20)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 3, point 20Click opens the article on EUR-Lex.).

The technical documentation behind the signature has six elements

Before it signs, the manufacturer establishes technical documentation that makes it possible to assess the packaging’s conformity, with “an adequate analysis and assessment of the risks of non-conformity” (Annex VII, point 2). It contains, wherever applicable, at least:

1. a general description of the packaging and its intended use;
2. conceptual design, manufacturing drawings and materials of components;
3. descriptions and explanations needed to understand the drawings and the operation of the packaging;
4. a list of the harmonised standards, common specifications and other technical specifications used, which parts of them, and where none was applied, the solutions adopted to meet the requirements;
5. a qualitative description of how the assessments under Articles 6Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 6Click opens the article on EUR-Lex., 10Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 10Click opens the article on EUR-Lex. and 11Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 11Click opens the article on EUR-Lex. were made;
6. test reports.

The manufacturer also takes all measures needed so that the manufacturing process and its monitoring keep the packaging in line with the documentation (Annex VII, point 3). Where other articles want a point shown in this file, they say so: PFAS compliance (Art. 5(6)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 5, paragraph 6Click opens the article on EUR-Lex.), the minimisation assessment (Art. 10(4)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 10, paragraph 4Click opens the article on EUR-Lex.), and the conditions for reusable packaging (Art. 11(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 11, paragraph 3Click opens the article on EUR-Lex.). The format of the file for recycled content is still to be set by the Commission (Art. 7(8)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 7, paragraph 8Click opens the article on EUR-Lex.).

The standards and the file are your own: the declaration lists the harmonised standards or common specifications used, or other technical specifications (Annex VIII, point 6). On the file in general, see technical file.

What the PPWR declaration of conformity contains: the eight points of Annex VIII

The model in Annex VIII has eight points and a signature block (Art. 39(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 39, paragraph 2Click opens the article on EUR-Lex., Annex VIII):

1. The number identifying the packaging, so that it can be traced. Match it to the number or other element you give the packaging under Art. 15(5)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15, paragraph 5Click opens the article on EUR-Lex..
2. The name and address of the manufacturer and, where there is one, of its authorised representative.
3. The statement “This declaration of conformity is issued under the sole responsibility of the manufacturer.”
4. The object of the declaration: a description of the packaging that allows traceability.
5. A statement that the object is in conformity with the relevant Union harmonisation legislation, with the other Union acts applied.
6. The harmonised standards or common specifications used, or the other technical specifications by reference to which conformity is declared.
7. Where applicable, the notified body: its name, address and number, what it did, and the certificate it issued, with date, duration and conditions of validity.
8. Additional information.

Then the signature block: signed for and on behalf of whom, place and date of issue, name and function, and the signature. The model also leaves a place for the identification number of the declaration itself.

Annex VIII has no line for the Regulation itself, and Art. 39(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 39, paragraph 1Click opens the article on EUR-Lex. says the declaration states that Articles 5Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 5Click opens the article on EUR-Lex. to 12Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12Click opens the article on EUR-Lex. are fulfilled. Point 5 is the line for the legislation, so name Regulation (EU) 2025/40Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationThe whole regulationClick opens the law on the EU Publications Office. there, with the articles that apply to the packaging.

A PPWR declaration of conformity template to fill in

Square brackets are what you fill in. The eight points follow Annex VIII of Regulation (EU) 2025/40Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationThe whole regulationClick opens the law on the EU Publications Office..

EU DECLARATION OF CONFORMITY No [number of the declaration]

1. No [ ] (unique identification of the packaging: type, batch or
   serial number)
2. Name and address of the manufacturer and, where applicable, the
   manufacturer's authorised representative:
   [ ]
3. This declaration of conformity is issued under the sole
   responsibility of the manufacturer.
4. Object of the declaration (identification of the packaging allowing
   traceability): description of the packaging:
   [ ]
5. The object of the declaration referred to in point 4 is in
   conformity with the relevant Union harmonisation legislation:
   Regulation (EU) 2025/40, Articles [5 to 12 as they apply to this
   packaging]; [other Union acts applied, with their publication
   references]
6. References to the relevant harmonised standards or the common
   specifications used or references to the other technical
   specifications in relation to which conformity is declared:
   [ ]
7. Where applicable, the notified body [name, address, number]
   performed [description of intervention] and issued the
   certificate(s): [details]
8. Additional information:
   [ ]

Signed for and on behalf of: [company]
(place and date of issue): [ ]
(name, function) (signature): [ ]

EU DECLARATION OF CONFORMITY No PKG-2026-001

1. No PKG-2026-001-A (sales packaging), batch number printed on the
   underside
2. Manufacturer: [Your Company Ltd], [street, city, postcode, country]
3. This declaration of conformity is issued under the sole
   responsibility of the manufacturer.
4. Object of the declaration: sales packaging, one-piece folding box of
   uncoated paperboard, 90 x 90 x 120 mm, for a glass candle jar.
5. The object of the declaration is in conformity with the relevant
   Union harmonisation legislation: Regulation (EU) 2025/40 (OJ L,
   2025/40, 22.1.2025), Articles 5 to 12 as they apply to this
   packaging.
6. Specifications used: [standards, common specifications or other
   technical specifications, with year; if none was applied, say so and
   refer to the technical documentation]
7. Notified body: not applicable (Annex VII, Module A).
8. Additional information: technical documentation held at
   [address]; declaration also available at [web address].

Signed for and on behalf of: [Your Company Ltd]
[City], [date of issue]
[Name], [Managing Director]   [signature]

EU DECLARATION OF CONFORMITY No PKG-2026-002

1. No PKG-2026-002-A (transport packaging), batch number printed on the
   underside
4. Object of the declaration: transport packaging, corrugated mailer
   box, 300 x 200 x 120 mm, with our logo printed on the lid.

Points 2, 3 and 5 to 8, and the signature block, as in declaration one.

What the declaration covers on 12 August 2026, and what comes later

The declaration covers the requirements of Articles 5Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 5Click opens the article on EUR-Lex. to 12Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12Click opens the article on EUR-Lex. “that apply to it” (Annex VII, Module A, point 1). A requirement that has not started is not in it yet. The table gives the date each one starts.

On Article 10(2), the text carries no date of its own, so it applies from the date of the Regulation, 12 August 2026 (Art. 71Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 71Click opens the article on EUR-Lex.). Only Article 10(1) has a later date. The one thing kept to the end of 2029 is the old Directive’s minimisation requirement (Art. 70(1)(b)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 70, paragraph 1, point (b)Click opens the article on EUR-Lex.). The Commission’s guidance reads it differently: after the end of 2029, “both paragraphs 1 and 2 of Article 10 will apply (from 1 January 2030)” (Commission Notice C/2026/3084, section 10; guidance, not law). Guidance is not law, so put the Annex IV assessment in the file now.

Other rules in the PPWR are not part of the declaration, because it covers Articles 5Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 5Click opens the article on EUR-Lex. to 12Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 12Click opens the article on EUR-Lex. only: the empty-space cap of Article 24Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 24Click opens the article on EUR-Lex., the format bans of Article 25Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 25Click opens the article on EUR-Lex., the re-use targets of Article 29Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 29Click opens the article on EUR-Lex. and the producer duties of Articles 44Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 44Click opens the article on EUR-Lex. and 45Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 45Click opens the article on EUR-Lex.. Their dates and tests are on PPWR.

One declaration can cover the packaging and the product’s other EU laws

Where the packaging or the packaged product falls under more than one Union act that asks for a declaration, a single declaration is drawn up for all of them “where appropriate”. It names the acts and their publication references, and it may be a dossier made up of the individual declarations (Art. 39(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 39, paragraph 3Click opens the article on EUR-Lex.). The reason the Regulation gives: a single declaration gives market surveillance one place to look, and the dossier form lightens the burden on operators (recital 111).

A toy, a lamp or a battery sold in its own box can carry the declaration for the product’s law and the one for the packaging under the PPWR in one document, or in a dossier that holds both. What the product’s own declaration holds is on declaration of conformity, and why the CE marking on the box belongs to the product and not to the packaging is on CE marking.

Keep the declaration for 5 or 10 years and show it on request

The manufacturer keeps the declaration and the technical documentation for 5 years from the date single-use packaging was placed on the market, and for 10 years for reusable packaging (Art. 15(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15, paragraph 3Click opens the article on EUR-Lex.). An importer keeps a copy of the declaration and ensures the technical documentation can be made available to the authorities on request, for the same periods (Art. 18(7)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 18, paragraph 7Click opens the article on EUR-Lex.). So does an authorised representative under its mandate (Art. 17(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 17, paragraph 2Click opens the article on EUR-Lex.).

On a reasoned request from a national authority, the manufacturer provides the information and the documentation, including the technical documentation, in a language the authority easily understands, in electronic form and on request on paper, and “within 10 days of receipt of the request” (Art. 15(10)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 15, paragraph 10Click opens the article on EUR-Lex.). The Regulation names the authorities as the ones who receive the declaration on request (Annex VII, point 4); it sets no rule for sending it to buyers or platforms.

Harmonised standards and implementing acts are still awaited

A harmonised standard whose reference is published in the Official Journal gives a presumption of conformity with the requirements it covers, and a common specification does the same where the Commission adopts one because standards are missing (Art. 36(3)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 36, paragraph 3Click opens the article on EUR-Lex., Art. 37(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 37, paragraph 1Click opens the article on EUR-Lex.). The Commission’s list of harmonised standards for packaging, read on 5 October 2026, holds only six standards under the old Directive 94/62/EC, EN 13427 to EN 13432, and no entry under the PPWR (European Commission; web page, which says it may not be complete and has no legal validity).

That does not stop you from signing. The technical documentation lists the standards used, and where none applied it describes “the solutions adopted to meet the requirements” (Annex VII, point 2(d)(v)), and the declaration can cite “other technical specifications” (Annex VIII, point 6).

What the Regulation still leaves to the Commission, with its own deadline:

The Commission’s guidance of 10 June 2026 puts the rest on a long road: “Further details will be proposed via several implementing measures, such as implementing acts, delegated acts, standardisation requests and guidelines, to be proposed by the Commission in the coming 2-3 years” (Commission Notice C/2026/3084; guidance, not law). Where a date in the table above is tied to one of these acts “whichever is the latest”, the later date counts.

A missing or wrong declaration must be put right

An EU country that finds the declaration has not been drawn up, or not drawn up correctly, or that the technical documentation is not available, is not complete or contains errors, requires the economic operator to end the non-compliance (Art. 62(1)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 62, paragraph 1Click opens the article on EUR-Lex., points (a), (b) and (d)). If it persists, the EU country takes all appropriate measures to prohibit the packaging from being made available, or to have it recalled or withdrawn (Art. 62(2)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 62, paragraph 2Click opens the article on EUR-Lex.).