What has happened since 12 August?
The EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) has applied generally since 12 August 2026. Much is phased in over time, but the first wave is already concrete: the EU Declaration of Conformity (DoC), technical documentation, and limits for heavy metals and for PFAS in food-contact packaging. Packaging placed on the EU market after that date must comply. The requirements are not tied to company size.
Who is the manufacturer, and why does it matter?
According to the Commission's guidance, there is in practice one manufacturer per packaging item in the PPWR sense. The manufacturer is responsible for conformity assessment, technical documentation and the DoC. A company that has packaging designed or manufactured under its own name or trademark may itself count as the manufacturer. Importers and distributors have their own duties to make sure the manufacturer has done its part.
So the first question is not "which documents are missing?" but "what is our role for this specific item?"
What needs to be in place?
- An EU Declaration of Conformity (DoC) following the regulation's model.
- Technical documentation supporting the declaration, including that the requirements on heavy metals and on PFAS in food-contact packaging are met.
- Traceability to the item: which packaging, which supplier, which evidence.
- Retention: documentation must be available to authorities on request, generally at least five years for single-use packaging.
Five steps that work in practice
1. Map your items. Which packaging do you place on the market, and which is food contact?
2. Determine your role per item: manufacturer, importer or distributor.
3. Request evidence from suppliers in one consistent format, not in free-form email threads.
4. Compile the technical documentation per item and flag gaps immediately.
5. Issue and store the DoC with a clear link to the evidence, and decide who owns updates when something changes.
Where it usually gets stuck
- Suppliers answer in different formats, languages and levels of detail.
- Item numbers on your side and the supplier's side do not match.
- The evidence exists, but in someone's inbox or in an Excel version nobody trusts.
- A DoC is issued before the evidence is complete, and then cannot be defended.
How CO2check helps
CO2check's PPWR portal is built for exactly this flow. Suppliers log in and upload incoming DoCs and technical specifications per item. The platform flags item numbers it cannot find, and an outgoing DoC is not generated if incoming documentation is missing, so you never issue a declaration on empty ground. The result is less manual administration and documentation you can actually show.
Read more on the PPWR page or download our PPWR checklist 2026.
This guide is general information and does not replace legal advice. Always check the regulation text and the Commission's guidance.