As businesses prepare for the first implementation phase of the EU Packaging and Packaging Waste Regulation (PPWR), one topic continues to generate significant discussion: the Declaration of Conformity (DoC).
During Greif’s recent webinar, Unpacking PPWR: From Greif Technical Statements to Your DoC, customers submitted more than 100 questions—many centred around documentation responsibilities, the roles of different economic operators, and how to prepare for the August 2026 requirements.
While further guidance and implementing acts are still expected, understanding the responsibilities already defined in the regulation is an important first step.
Why the Declaration of Conformity (DOC) Matters
From 12 August 2026, manufacturers placing packaging on the EU market will be required to prepare a Declaration of Conformity for the applicable PPWR sustainability requirements.
The Declaration of Conformity confirms that packaging has undergone a conformity assessment, is supported by technical documentation, and complies with the relevant provisions of the PPWR.
For many businesses, however, the biggest challenge isn’t understanding what a DoC is -it’s understanding who is responsible for creating it.
Understanding the Roles Across the Packaging Value Chain
One of the most common misconceptions is that the packaging supplier prepares the Declaration of Conformity. In most cases, this is not the case. Under PPWR, responsibilities are divided across the packaging value chain.
Packaging Suppliers
Packaging suppliers provide empty packaging or packaging components.
Their responsibility is to supply the technical information needed for manufacturers to demonstrate compliance with the relevant PPWR requirements.
Manufacturers (Packaging Fillers)
Once packaging is filled and placed on the market under the manufacturer’s name or brand, the manufacturer becomes responsible for:
- carrying out the conformity assessment
- preparing the technical documentation
- issuing the Declaration of Conformity
These responsibilities are defined within Articles 38 and 39 of the PPWR.
Importers and Distributors
Importers and distributors also have defined responsibilities within the regulation, including ensuring that the appropriate conformity assessment and supporting documentation have been completed before packaging is placed on the EU market.
Where Packaging Suppliers Add Value
Although packaging suppliers generally do not create the customer’s Declaration of Conformity, they provide much of the technical information required to complete it.
For example, Greif’s documentation can support information relating to:
- packaging descriptions
- material composition
- heavy metals
- PFAS (where applicable)
- reusability
- applicable standards and legislation
This technical information can then be incorporated into the customer’s own technical documentation and Declaration of Conformity.
What Does a Declaration of Conformity (DOC) Include?
The Declaration of Conformity is more than a simple compliance statement.
It includes information such as:
- unique packaging identification
- manufacturer details
- description of the packaging
- applicable legislation
- relevant standards
- supporting technical documentation
- signature of the responsible manufacturer
The webinar included a practical steel drum example demonstrating how these elements fit together in a completed DoC.
Four Practical Considerations for Businesses
As organizations prepare for August 2026, there are several important points to keep in mind.
- A supplier’s technical statement is not your Declaration of Conformity: Technical statements provide supporting evidence, but the Declaration of Conformity remains the manufacturer’s responsibility.
- Focus on today’s applicable requirements: Not every PPWR requirement applies immediately. Businesses should prepare documentation based on the requirements applicable from August 2026 while monitoring future delegated and implementing acts.
- Consider all packaging components: Transport packaging – including pallets, stretch wrap and straps – may require separate assessments.
- Keep documentation up to date: As additional EU guidance is published, technical documentation and conformity assessments may need to be updated.
Preparing for PPWR with Confidence
Although PPWR implementation will continue to evolve, businesses don’t need to wait to begin preparing.
Understanding the responsibilities of each economic operator, gathering technical documentation from suppliers, and establishing internal compliance processes now can help reduce uncertainty as the regulation develops.
At Greif, we continue to support customers by providing PPWR technical statements, technical datasheets, practical guidance and ongoing updates as additional guidance becomes available.
Check out our PPWR hub to learn more. Interested in our webinar, “Unpacking PPWR: From Greif Technical Statements to Your DoC?” Watch on demand in English or French.