PPWR Declaration of Conformity

Compliance Technical Documentation & Declaration of Conformity template in accordance with Regulation (EU) 2025/40 (PPWR)

USER GUIDE: EU DECLARATION OF CONFORMITY (DoC)

Step-by-Step Instructions for Compliance under Regulation (EU) 2025/40 (PPWR)

This guide is designed for importers to successfully request, review, and verify the Declaration of Conformity (DoC) provided by their packaging manufacturers.

Critical Legal Mandate (Article 21)

The Private Label Rule: If you place packaging on the EU market under your own name or trademark, you are legally classified as the manufacturer.
The Requirement: You cannot use this importer collection template; you must self-issue the DoC instead.
Support: Please consult the internal guidelines of Complico Consulting GmbH for self-issuance frameworks.

Comprehensive Section Breakdown

  • 1. Reference & Metadata (Sections 2 & 3): DoC Number: Assign a unique alphanumeric identification number to ensure traceability (e.g., DOC-2026-001). Manufacturer Details: Enter the complete, legally registered corporate name and physical address of the production facility.
  • 2. EU Authorized Representative (Section 4): Non-EU Production: Mandatory if the manufacturer is based outside the European Union (per Article 7). Pre-Filled Data: Ensure the legal entity details of Complico Consulting GmbH are correctly maintained in this block.
  • 3. Packaging Technical Profiling (Section 5): Traceability Codes: Provide exact SKU, batch, or article codes. Material Breakdown: List all materials (e.g., Cardboard, PET laminate, water-based inks) alongside precise physical dimensions and weight.
  • 4. Regulatory Conformity & Technical Standards (Sections 6, 7 & 8): Applicability Mapping: Check "Yes" or "N/A" for each PPWR Article based on your specific packaging format. Harmonized Standards: Reference official EN standards applied (e.g., EN 13428:2004 for packaging minimization). Qualitative Evidence: Provide brief engineering descriptions of how the packaging complies with recycling criteria, minimization rules, and chemical safety limits.
  • 5. Technical Documentation & Final Sign-Off (Sections 9 & 11): Annex VII File Location: Specify exactly where the full technical construction file is securely stored. Retention Clause: Document the mandatory retention period (minimum of 5 to 10 years). Legal Validation: The document must be concluded with the place, date, printed name, and hand-signed signature of the manufacturer's authorized corporate officer.

Pre-Submission Quality Gate

Before accepting the document, verify the following:

  • Is the unique DoC Identification Number clearly present?
  • Are all material layers and technical dimensions fully declared?
  • Are the relevant harmonized EU standards explicitly referenced?
  • Has the manufacturer applied a valid corporate signature, date, and place?

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