PPWR Declaration of Conformity: Packaging Evidence
A packaging declaration of conformity addresses packaging compliance. It is not an EPR registration confirmation, and an EPR representative appointment does not by itself prove authority to perform manufacturer tasks.
Use the correct legal route
Article 15 addresses manufacturer obligations, Article 38 the conformity assessment and Article 39 the declaration. Annex VII concerns technical documentation and Annex VIII the declaration model. The manufacturer remains responsible for the declaration. Check the applicable requirements before completing a template.
Identify the actual packaging and responsible entity
Link the packaging type to a clear description, component specifications and the company assessed as manufacturer. Record who designs or brands the packaging and any changes made after purchase. Keep product and packaging evidence distinguishable, especially where the appliance inside the box has its own conformity documents.
Prepare evidence before the signature
Gather relevant specifications, supplier information, assessments and test evidence. Check that they relate to the final packaging configuration and the requirements being declared. A supplier’s generic statement should not be relabelled as a completed assessment of a different packaging design. Resolve gaps before asking the responsible company to sign.
Keep the file current and the appointment precise
Record the version, approval date, packaging identifier, linked evidence and responsible contact. Reassess changes in materials, design or suppliers. If a representative holds documents or performs a task, confirm the specific mandate and responsibilities; do not infer that authority from a packaging EPR contract or a separate GPSR service.