EU PPWR FAQs Updated August 2026 - Flipbook - Page 41
scheme). In relation to the EU declaration of conformity: as per Article 17, this may be drafted by
the manufacturer (based on the information and documentation provided by suppliers pursuant to
Article 16(1)) or drafted by an authorised representative, appointed by the manufacturer by a
written mandate (in which case overall responsibility for the compliance of the EU declaration of
conformity will still remain with the manufacturer). In relation to the technical documentation: as
Article 17 sets out, the obligation to draw this up cannot be delegated. Manufacturers must therefore
assume this responsibility themselves.
Article 16 of the PPWR requires suppliers to provide manufacturers with the relevant information
and documentation necessary to prove compliance. The Regulation therefore establishes a system
whereby the packaging supplier provides the technical information necessary
to demonstrate compliance, while the manufacturer remains the economic operator legally
responsible for placing compliant packaging on the market.
As Article 17(2) also makes clear however, an authorised representative appointed by a
manufacturer may be made responsible for certain other tasks, including keeping the declaration of
conformity and technical documentation at the disposal of the national authorities for the required
amount of time, cooperating with the national authorities and making relevant documents available
to them, on the manufacturer9s behalf.
Regardless of who the manufacturer may appoint to carry out some of the above-mentioned tasks,
the manufacturer will remain the sole economic operator bearing legal responsibility for packaging
compliance under the PPWR, and this legal responsibility cannot be transferred by means of
contractual arrangements.
10) Manufacturers and importers are required to keep records of the 8conceptual design,
manufacturing drawings and materials of components9 of their packaging. Is it
sufficient if the suppliers retain this design information, and make it available to
authorities upon request? NEW!
The manufacturer bears legal responsibility for ensuring that the packaging it places on the market
is compliant with the obligations in the PPWR, including those stemming from Articles 5-12. To
document compliance to national authorities, Articles 15(3) and 18(7) establish that manufacturers
and importers of packaging must keep the technical documentation referred to in Annex VII for 5
years for single use packaging and 10 years for reusable packaging.
Annex VII sets out that the technical documentation must at least include
