Do PPWR Documents Expire? When a Packaging Change Calls for a New Declaration of Conformity
Do PPWR Documents Expire?
No. Regulation (EU) 2025/40 sets no validity period for an EU declaration of conformity, a test report or a supplier document, only a retention period. Under Article 15(3), the manufacturer keeps the technical documentation and the declaration for 5 years from the date the packaging was placed on the market, or 10 years for reusable packaging.
Brand owners and converters sent us four questions in 30 days, the last on 2 September 2026: does a test report or a supplier certificate expire, is a new declaration needed when the packaging or the supplier changes, and is conformity a one-off exercise? Our guides to what a declaration of conformity covers and to the Annex VII technical documentation describe both documents at the start; this article follows them afterwards.
Key Facts
- Under Article 15(3), the manufacturer keeps the technical documentation and the EU declaration of conformity for 5 years from the date the packaging was placed on the market, or 10 years for reusable packaging.
- Under Article 15(4), the manufacturer takes into account changes in packaging design or characteristics and in the standards or specifications behind the declaration, and carries out a re-assessment where conformity could be affected.
- Article 39(2) provides that the EU declaration of conformity has the model structure set out in Annex VIII, contains the elements specified in the module in Annex VII, and is continuously updated.
- Under Article 5(4), the 100 mg/kg limit on the sum of lead, cadmium, mercury and hexavalent chromium applies in the packaging or in any packaging component, and concentrations are never added up across components.
- Our dated PPWR referential (baseline reviewed 15 September 2026) confirms the third and fourth lines; the others are read on the linked text.
What Must a Manufacturer Keep, and for How Long?
Under Article 15(3) of Regulation (EU) 2025/40, the manufacturer keeps the Annex VII technical documentation and the EU declaration of conformity for 5 years from the date the packaging was placed on the market, or 10 years for reusable packaging. The clock starts when the packaging is placed on the market, not on the date of a document.
A retention period is the time during which a document must remain available to the authorities. A retention period says nothing about whether the document still describes the packaging sold.
Placing on the market is the first making available of packaging, whether empty or with a product, on the Union market, under Article 3(1)(10). The Commission's Blue Guide states that placing on the market refers to each individual product, not to a type of product, and whether it was manufactured as an individual unit or in series. In our reading, the file of a version made in series stays available until 5 years after its last unit was placed on the market, or 10 years for reusable packaging.
Under Article 15(10), the manufacturer makes the documents available within 10 days of receipt of a reasoned request from a national authority. In our reading, a superseded declaration stays in the file for the retention period of the packaging it covered.
Which Changes Call for a Re-Assessment Under Article 15(4)?
Article 15(4) of Regulation (EU) 2025/40 names two kinds of change: changes in packaging design or characteristics, and changes in the standards or technical specifications behind the declaration. Where the manufacturer finds that the packaging's conformity could be affected, the manufacturer carries out a re-assessment under the Article 38 procedure.
The paragraph reads in full: "Manufacturers shall ensure that procedures are in place for series production of packaging to remain in conformity with this Regulation. Manufacturers shall adequately take into account changes in packaging design or in characteristics, as well as changes in harmonised standards, common technical specifications or other technical specifications by reference to which conformity is declared or by application of which its conformity is verified. Where the manufacturers find that the packaging’s conformity could be affected, they shall carry out a re-assessment in accordance with the conformity assessment procedure referred to in Article 38, or have it carried out on their behalf."
Internal production control is the conformity assessment procedure in which the manufacturer ensures and declares on its sole responsibility that the packaging meets the requirements of Articles 5 to 12 that apply to it, under Annex VII, point 1. Article 38 refers to that procedure. In our reading, a re-assessment runs that procedure again on the changed packaging. Annex VII, point 3, still requires the manufacturing process and its monitoring to keep production in line with the technical documentation. PPWR conformity is maintained, not obtained once.
A new pigment, ink or recycled input can move a component above the Article 5(4) limit. A new coating in food-contact packaging can reach the PFAS limit values of Article 5(5), which have applied since 12 August 2026. A new material combination can affect recyclability. Under Article 6(1), all packaging placed on the market shall be recyclable, an obligation that has applied since 12 August 2026, transport packaging included. A new double wall or false bottom falls under the perceived-volume rule of Article 10(2).
The table is our reading of Article 15(4), Article 39(2) and Annexes VII and VIII, not a list from the Regulation. The manufacturer decides each case with the risk analysis that Annex VII, point 2, requires.
| Change | Re-assess under Article 15(4)? | Update the declaration? | What to keep |
|---|---|---|---|
| New material, pigment, ink or recycled input in a component | Yes, where Article 5(4), 5(5) or 6(1) could be affected | Yes, as a new dated version | Old and new evidence, each tied to its version |
| New supplier or second source for a component | Yes, where the new source could affect a requirement | Where an element the declaration states changes | The new supplier's evidence, filed against its version |
| Design change: shape, weight, wall, closure or label | Yes, where Article 6(1) or 10(2) could be affected | Yes, and a new packaging type gets its own declaration | Drawings and assessments per version |
| Revised standard or technical specification relied on | Take it into account; re-assess where conformity could be affected | Yes, point 6 of the Annex VIII model | Reports under the former and the current reference |
| No change, only time passing | No, time is not a change listed in Article 15(4) | No | The file, until its retention period ends |
When Must the EU Declaration of Conformity Be Updated?
Article 39(2) of Regulation (EU) 2025/40 provides that the EU declaration of conformity has the model structure set out in Annex VIII, contains the elements specified in the module in Annex VII, and is continuously updated. In our reading, an update is due whenever an element the declaration states no longer matches the packaging being placed on the market.
An EU declaration of conformity is the document by which the manufacturer states that the fulfilment of the requirements of Articles 5 to 12 has been demonstrated, under Article 39(1). The Annex VIII model shows which elements a change can move:
- point 1, the unique identification of the packaging;
- point 2, the name and address of the manufacturer;
- point 4, the object of the declaration, allowing traceability;
- point 6, the harmonised standards, common specifications or other technical specifications relied on;
- the place and date of issue.
Annex VII, point 4, provides for a declaration for each packaging type, identifying the packaging it covers. In our reading, a new packaging type calls for a new declaration, and a change within the same type for an updated one with a new date of issue. Our article on the unit of PPWR conformity explains how to version a packaging reference.
Does an Old Test Report Still Count as Evidence?
Yes, if the old test report still describes the packaging placed on the market. Regulation (EU) 2025/40 sets no expiry date for a test report. A test report shows what was tested, by the stated method, on the date of the test. After a change of component, supplier or method, an old test report describes a different packaging.
Under Annex VII, point 2, test reports belong to the technical documentation wherever applicable, with the list of standards and other technical specifications used for measurement or calculation. Under Article 35, tests, measurements and calculations use reliable, accurate and reproducible methods.
An old test report still proves which component and material were tested, by which method and when. An old test report proves nothing about a component, a supplier or a formulation that came later: for substances, each component carries its own concentration under Article 5(4). Our guide to what counts as supplier evidence covers such statements.
Private schemes, laboratories and suppliers may print their own end date on a certificate, and that date belongs to whoever issued it. The only mention of a certificate's validity we found in Regulation (EU) 2025/40 is point 7 of the Annex VIII model, which concerns a notified body's certificate, where applicable. Annex VII, the procedure to which Article 38 refers, names no notified body.
Who Keeps What Along the Supply Chain?
Regulation (EU) 2025/40 sets retention periods of 5 years, or 10 years for reusable packaging, for the manufacturer under Article 15(3), the authorised representative's mandate under Article 17(2), the importer under Article 18(7) and every economic operator's record of its suppliers under Article 22(2). Articles 16 and 19, on suppliers and distributors, set no period of their own.
| Role | What it keeps or provides | For how long | Provision |
|---|---|---|---|
| Manufacturer, often the brand owner | Annex VII technical documentation and EU declaration of conformity | 5 years from placing on the market, or 10 years for reusable packaging | Article 15(3) |
| Authorised representative, where appointed | Declaration and documentation, a minimum task of its mandate | 5 years, or 10 years for reusable packaging | Article 17(2)(a) |
| Importer | A copy of the declaration; the documentation available on request | 5 years from placing on the market, or 10 years for reusable packaging | Article 18(7) |
| Distributor | Information and documentation to which it has access, on a reasoned request | No period set | Article 19(6) |
| Supplier, often the converter | Information and documentation the manufacturer needs to demonstrate conformity | No period set | Article 16(1) |
| Every economic operator | The identity of whoever supplied it with packaging | 5 years from supply, or 10 years for reusable packaging | Article 22(2) |
Under Article 21, an importer or distributor that modifies packaging already placed on the market in a way that could affect compliance is considered to be a manufacturer. For converters, a change notice sent before a new formulation or source ships lets the manufacturer apply Article 15(4) in time. Our role-by-role PPWR checklist lists each role's other duties.
What Does the Referential Not Confirm?
Our dated PPWR referential (baseline reviewed 15 September 2026) confirms Key Facts three and four and the Article 6(1) sentence. The points below are read on the Official Journal text or the Commission page cited.
- Articles 3(1)(10), 5(5), 10(2), 15, 16(1), 17(2)(a), 18(7), 19(6), 21, 22(2), 35, 38, 39(1) and 39(2) as worded in the answers; Annex VII, points 1 to 4; Annex VIII, points 1, 2, 4, 6 and 7.
- Readings: no validity period for these documents, after a search of the text for valid, validity and expiry; time is not a change under Article 15(4); new or updated declaration; superseded versions kept; no retention period in Articles 16 and 19.
- The Blue Guide sentence, read on EUR-Lex on 27 September 2026, and our reading of it for packaging made in series. Nothing here is legal advice.
Frequently Asked Questions
Does a supplier certificate with an end date expire under the PPWR?
The end date belongs to whoever issued the certificate. Regulation (EU) 2025/40 sets no validity period for supplier documents. Under Article 15(4), what matters is whether the certificate still describes the component you buy.
Do we need a new declaration when only the supplier changes?
Not always. A new supplier for an unchanged specification is a change the manufacturer takes into account under Article 15(4) of Regulation (EU) 2025/40, with the new supplier's evidence filed per component. The declaration is updated when an element it states changes.
How PPWR Connect Helps
PPWR Connect is software: it does not decide whether a re-assessment is needed, and it is not a notified body, a laboratory or a legal adviser. Since 24 August 2026, PPWR Connect keeps dated packaging versions and models the configurations of one SKU. Each recorded value keeps where it came from: manual entry, import or supplier document. A supplier PDF such as a test report, a certificate or a datasheet is read by the platform and filed as evidence against the SKU for the Declaration of Conformity. A declaration or certificate can state which market it covers. Outgoing webhooks send workspace events, such as a document about to expire, to an HTTPS endpoint. Since 13 September 2026, the Impact screen lists the declarations of conformity touched by a data change. To find declarations that no longer match what you ship, start with our PPWR compliance software or the PPWR readiness assessment.
Published by
Rutherford (rutherford.fr) develops production control software for offset printers and converters, including ColorLoop. Veoria (veoria.com) develops inline colour measurement for label and packaging presses, including DeltaOne.