The PPWR Declaration of Conformity (DoC) Field-by-Field Guide

The PPWR Declaration of Conformity (DoC) Field-by-Field Guide

Who signs it, the ten mandatory elements of Annex VIII, and why a signature makes the signer legally responsible.

The document nobody wants to sign - and why it matters

The Declaration of Conformity (DoC) is the producer's signed statement that a specific packaging type meets the applicable requirements of Articles 5-12 of Regulation (EU) 2025/40; it follows the ten mandatory elements of Annex VIII, and the signature makes the signer legally responsible. It is not a quality certificate and it is not a test report. It is the legal sentence "I vouch for this packaging" - which is exactly why factories that sign it casually are the ones who learn the hard way.

Who is the producer: the question that decides the signature

The producer is whoever places the packaging on the market under its own name or brand. It is not automatically the factory.

One clarification worth repeating: a non-EU manufacturer can sign a DoC directly - no EU entity is required for the signature itself. The EU authorised representative under Article 17 is an optional tool, not a precondition. What is non-negotiable is the signature, the file, and the ability to produce both when asked.

The ten mandatory elements of Annex VIII

Why Module A makes the signature heavier

PPWR's default conformity route is internal production control (Article 38, Module A): the producer assesses, files and signs without a notified body. That saves money - and shifts risk. There is no third party standing between you and the signature. The signer carries full responsibility, which is why the first question before signing is always: is the technical documentation complete? A DoC without its Annex VII file is a signature floating without evidence.

Language, retention and version control

Language: the DoC must be in a language easily understood in the member state where the packaging is placed. English plus German covers most of the EU in practice.
Retention: five years for single-use packaging, ten years for reusable, counted from the last placing on the market. Keep the DoC and the technical documentation together.
Versions: any packaging change - material, supplier, print - creates a new variant or a new version with its own number and date. Never overwrite the old file; traceability means the right version can be matched to the right batch.
Response: market surveillance can request the technical documentation within 10 days. The file must be findable the same day, not reconstructed under pressure.

Common mistakes that invalidate a DoC

A blanket declaration covering "all our packaging" - Annex VIII requires unique identification.

Substituting a test report for a DoC - the report is evidence, the DoC is the statement.

Substituting an ISO 9001 certificate - a quality-system certificate is not a packaging DoC.

An unsigned DoC - the signature is the legal act.

Overwriting old versions - batches still in the market need the version that covered them.

About this series

Written by the team behind a luggage factory in Jiangxi, China, for importers, factories and component suppliers who want the same working knowledge. No promotion, just what we'd tell a friend who asked. Author: CLK Luggage Academy —

Scenario	Producer	Who signs
Packaging carries CLK's brand, sold to the EU	CLK (the factory)	CLK signs
Private label (OEM/ODM), buyer's brand on the packaging	The brand owner	Brand signs; factory supplies the evidence pack
EU importer resells under its own brand	The importer	Importer signs

#	Element	What to write
1	Unique declaration number	Internal ID, e.g., CLK-PPWR-DOC-2026-001
2	Producer name and address	Full legal name and registered address; private label = brand owner
3	Sole responsibility statement	Standard sentence: issued under the sole responsibility of the producer
4	Unique packaging identification	Type, batch or serial number per variant - "all our packaging" is not valid
5	Packaging description	Material composition and essential characteristics (dimensions, weight, layers)
6	Reference to the legislation	Regulation (EU) 2025/40 and the applicable Articles 5-12
7	Standards or specifications applied	Harmonised standards where they exist; otherwise technical specifications or internal methods
8	Notified body details	Normally "not applicable" under Module A
9	Supplementary information	Test report numbers, material declaration numbers
10	Signature, place, date	Unsigned = invalid

FAQ

For private-label orders, does the factory sign the DoC?

Usually not. The brand on the packaging defines the producer, so the brand owner signs and the factory delivers the evidence pack - test reports, material declarations and the packaging list. Agree this in the contract, not in an email after the goods are made.

Can one DoC cover several products?

Yes, per packaging variant. A variant used across multiple SKUs can share a DoC if the packaging is identical; a blanket statement covering every packaging type cannot.

Does a non-EU factory need an EU authorised representative to sign?

Not for the DoC itself. Article 17 makes the authorised representative an option. GPSR (product safety) has a separate EU-representative requirement for direct sales - do not confuse the two systems.

Does the DoC need notarisation or certification?

No. Signature and file retention are enough - but the signer must be able to defend the content, so confirm the technical documentation is complete before signing.

Who keeps the DoC?

The producer keeps the original (5 or 10 years); the EU importer keeps a copy and verifies it before placing goods on the market; distributors do not have to hold it but must not place visibly non-compliant packaging.

What happens if the packaging changes after signing?

The change creates a new variant or version, and the DoC must be updated with history preserved. Do not just change the date on the old file - traceability needs the version that matches each batch.