The declaration of conformity (DoC) is the document that says your packaging meets the PPWR's design and sustainability requirements. It is separate from EPR registration — and the two are easy to confuse. Here is the difference.
TL;DR — A Declaration of Conformity is a document the manufacturer (or their authorised representative) draws up, declaring that the packaging meets the PPWR's requirements on recyclability, recycled content, substance restrictions and labelling. It is not the same thing as EPR registration.
What a Declaration of Conformity is
The DoC is the manufacturer's formal statement that a packaging type satisfies the applicable requirements of the PPWR — the design-for-recycling criteria, recycled-content targets, restrictions on substances of concern, and the marking and labelling rules. It is the document that stands behind the claim "this packaging is compliant."
Who signs it
The manufacturer draws up and signs the DoC — or, where the manufacturer has appointed one, the authorised representative signs it on their behalf. For a non-EU producer with no EU presence, the authorised representative role matters here too: it is the locally reachable party that can hold and produce the document when an authority or a marketplace asks.
What it must contain
A valid DoC identifies the packaging it covers, states the requirements it complies with, and names the manufacturer with their address. It is dated and signed by a person authorised to act for the manufacturer. The exact fields follow the PPWR's annexes, but the principle is simple: it must be specific enough that a market-surveillance authority can trace a packaging type to a responsible party.
DoC vs EPR registration — two different workstreams
This is where sellers trip up. The DoC is about design conformity — whether the packaging itself meets the rules. EPR registration is about producer responsibility — being registered in the national register, joined to a producer responsibility organisation, and paying the eco-contributions that fund collection and recycling. You need both, but they are separate obligations with separate documents and separate deadlines.
When you will be asked for it
Market surveillance authorities can request the DoC at short notice, and marketplaces may ask for registration numbers first — but the DoC is what backs up any design claim you make about your packaging. Holding one, correctly drafted and readily available, is the difference between a quick answer and a compliance scramble.
The practical takeaway: treat the DoC as a live document, not a one-off. Keep it current with your packaging, keep it accessible to your authorised representative, and be ready to produce it the day someone asks.
Sources: PPWR (EU) 2025/40, Annex VIII (declaration of conformity).
Need help with your conformity documents? Get a quote — tell us your target countries and packaging types.