When a Declaration is drawn up
Article 15 requires the manufacturer to carry out the Annex VII conformity assessment before placing packaging on the market. Where the applicable requirements have been demonstrated, the manufacturer draws up the EU Declaration under Article 39.
Importers keep a copy and verify the manufacturer’s work. Distributors carry out their own pre-supply checks. They should not replace a missing manufacturer Declaration with one issued in their own name unless the facts make them the manufacturer under Article 21.
The Annex VIII model structure
The model identifies the Declaration number, packaging, manufacturer, object of the Declaration and the manufacturer’s sole responsibility. It references the Regulation, relevant harmonised standards or common technical specifications, additional information and the authorised signatory.
- Declaration number
- Manufacturer name and address
- Clear packaging identification
- Statement of sole manufacturer responsibility
- Object description allowing traceability
- Applicable Union legislation
- Standards or specifications relied upon
- Additional information, place, date, signatory and signature
Language, updates and retention
Article 39 requires the Declaration to be continuously updated and drawn up or translated into languages required by the Member State where the packaging is placed or made available on the market.
The manufacturer retains it with the technical file for five years for single-use packaging and ten years for reusable packaging. A changed packaging construction or evidence basis should trigger review.
Do not sign while required evidence or assessment decisions remain unresolved. PPWR Docs labels the output as a draft for manufacturer review and signature.