What a PPWR Declaration of Conformity Covers: One Packaging, Not One Company

What a PPWR Declaration of Conformity Covers: One Packaging, Not One Company

Most questions about the EU declaration of conformity are not about how to write one. They are about how many are needed. A brand with a wide catalogue, an importer bringing in a container of mixed references, a converter asked to supply paperwork for a print run — each arrives at the same doubt. Is this document issued once, for the business? Once for a product family? Or once for every item that leaves the line? The answer decides how much work is in front of you, and it is the single point on which portfolios are most often mis-scoped — in both directions, by teams who are otherwise well organised. Getting the unit right before you start is worth more than any amount of speed afterwards, because a programme scoped against the wrong unit does not run late so much as it runs irrelevant.

The Object of the Declaration

Article 39 of Regulation (EU) 2025/40 is headed "EU declaration of conformity." Reading the article, the declaration is a written document drawn up in respect of packaging: it names an object, and it states that the object conforms. Article 39(2) provides that the declaration has the model structure set out in Annex VIII — that much is established by the text itself, and it is the reference point every other question hangs from.

What the declaration attaches to therefore matters more than what it says. The regulation's vocabulary is set out in Article 3, headed "Definitions", and the duties that fall on the party drawing the document up are gathered in Article 15, headed "Obligations of manufacturers." Read together, these give the shape of the exercise: a named party, a named object, a statement about that object. Nothing in the reading points to the business as the thing being declared.

Not a Certificate About Your Business

This is where the most expensive misunderstanding lives. Companies that already hold registration numbers, licence agreements and scheme memberships reasonably assume the declaration is one more item of the same kind — a credential the company earns once and then cites. On a reading of Article 39, it is not. The document is established for a packaging, not for a company, and a company that has done everything else correctly still has nothing to show for any particular pack until that pack has its own declaration.

The contrast with registration is worth holding onto, because the two are often handled by the same team in the same week and pull in opposite directions. Producer registration is done by legal entity and by market: one company, one country, one registration, repeated across the markets you sell into. The declaration runs the other way entirely — it does not care how many entities or countries are involved, only how many distinct packagings there are. Get the two confused and you will either register once and think you are finished, or attempt one declaration per market and produce a great deal of redundant paper. The confusion persists because the surrounding compliance landscape really is organised around the company: schemes enrol businesses, fees are invoiced to businesses, and auditors arrive to see a business. The declaration is the one obligation in the set whose unit is a physical object, and that is why it resists being delegated to whoever already handles the registrations.

Counting in Both Directions

Because the unit is the packaging, the count almost never matches the product count — and it can miss in either direction. Both surprises are common, and teams tend to anticipate only one of them.

Downward first. One portfolio we worked through recently held fifty-eight distinct sellable products and considerably fewer packaging references behind them. Several ranges shared one jar and one closure, changing only the label artwork; a whole seasonal line shipped in the same carton as the core range. Once the portfolio was described in packaging terms rather than commercial ones, the number of objects to declare fell well below the number of lines in the price list. Teams that budget one declaration per product routinely over-scope the work — sometimes by a wide margin — and the discovery is a pleasant one. It also tends to reveal that nobody owned the packaging inventory in the first place: the information existed, spread across specification sheets, purchasing records and the memory of two people in operations, but no single view of it had ever been assembled.

The symmetry is the part almost everyone misses, and it is not pleasant. A single product sold in three formats is three objects, not one. The same beverage in a small can, a large bottle and a multipack is three constructions with different materials, different weights and different behaviour at end of life; one entry in the product catalogue, three things to declare. The same applies as you move outward from the item on the shelf to the tray it is grouped in and the case it travels in. These are distinct packagings in their own right, which is why the distinction between sales, grouped and transport packaging is not a filing convention but the thing that determines your count.

So the honest answer to "how many declarations do we need?" is that nobody can tell you from the product list. The count comes out of a packaging inventory, and building that inventory is usually the real project hiding behind the paperwork.

The Declaration Is Not the Technical File

A client meeting earlier this summer turned entirely on this point, and it is worth separating the two documents carefully, because they are routinely spoken of as one. Annex VII of the regulation is headed "Technical documentation," while Article 39 governs the declaration itself, and Article 38 is headed "Conformity assessment procedure." On a reading of those provisions these are two distinct documents doing two distinct jobs.

The declaration is the short one. It follows the Annex VIII model, it identifies its object, it is signed, and it is the thing you hand over. The technical documentation is everything that makes the short document defensible: the description of the packaging, the composition and construction, and the assessments and supporting evidence behind each claim it rests on. One is an assertion; the other is the reason anyone should accept it. A signature over an empty file is not a shortcut — it is the whole exposure, concentrated onto one page with a name at the bottom.

This is also why the technical file, not the declaration, is where the effort actually goes. Assembling it means resolving what a packaging is made of and how it behaves, which draws on the structure of the Annex VII documentation, on what you know about the substances present in your materials, and on the reasoning behind how the packaging is sized and constructed. Those enquiries take weeks and involve suppliers who answer at their own pace and in their own formats. Drawing up the declaration afterwards takes an afternoon. Teams that plan the work the other way round — booking time to produce documents, then finding the documents need inputs nobody holds — lose the difference, and the loss surfaces at the end of the schedule rather than at the start.

When the Packaging Changes, So Does the Object

A prospect asked this in late August and it deserves a straight answer, because it is the question that turns a one-off exercise into an ongoing one. If the declaration is established for a packaging, then when the packaging changes the declared object is no longer quite the thing that was declared. A change of material, a change of weight, a change of supplier — each raises the question of whether the document on file still describes what is now being sold.

Two consequences follow. The first concerns the old declaration: it does not become false retroactively, because it described what was accurate for the packaging as it then stood, and units already placed on the market were covered by it. It simply stops describing current production, which means a superseded declaration is not waste paper to be deleted but a record of a state that once existed. The second concerns the evidence: supporting material does not automatically follow a specification change. Some of it survives — a composition statement for a component you did not touch is unaffected. Some of it falls the moment the specification moves, and an assessment carried out on the previous construction is no longer an assessment of the current one.

The practical consequence is that a declaration programme is not a project with an end date. It has a change-control shape: something has to notice when a specification moves, decide which evidence survives and which must be reworked, and re-establish the declaration for the object as it now is. Teams that treat the exercise as a one-time push produce a set of documents that quietly stops matching the packaging within a couple of specification cycles, and nobody notices until somebody asks. The trigger is worth naming, because it rarely announces itself as a compliance event: it arrives as a cost reduction on a substrate, a second source approved for a component, or a weight taken out of a bottle. Each is a routine commercial decision that changes a declared object, and the change reaches the packaging record only if someone has connected the two.

Five Questions That Fix Your Count

Before estimating effort, work through these in order. They resolve the scope of a declaration programme faster than any reading of the annexes, because each one is a question about your portfolio rather than about the text.

1. How many distinct packaging references do you have — not how many products? Start from the packaging inventory, never from the price list.
2. Is each reference sold at more than one level: as the item on the shelf, grouped, and again as it travels? Each level is its own object.
3. Do two products share exactly the same packaging, or a variant of it? Identical is one object; a different material, weight or construction is another.
4. Who, along the chain, draws up the declaration for each reference? Settle this per reference, not once for the company.
5. Where does the supporting evidence live, and who updates it when a specification changes? An unowned file is the failure mode, not a missing signature.

How PPWR Connect Helps You Count and Keep Count

PPWR Connect is a software publisher. We do not sign declarations on our customers' behalf, and we are not anyone's representative, compliance scheme or assessment body — the document is yours, the signature is yours, and the responsibility that comes with it stays where the regulation puts it. What the software does is hold the packaging inventory that the count depends on: one record per packaging reference rather than per product, the levels each reference is sold at, the evidence attached to each, and a history that shows when a specification moved and which supporting material moved with it. If you want to know how many objects are actually in your portfolio, start with a free PPWR readiness assessment — it works from your packaging, not your product list.