EU PPWR FAQs Updated August 2026 - Flipbook - Page 55
XV.
ASSESSMENT OF THE CONFORMITY OF PACKAGING
1) From which date will companies have to carry out the conformity assessment
procedure mandated by the PPWR?
In general, the Regulation applies from 12 August 2026 (Article 71). However, certain key
provisions will apply only from the date specified therein. In several cases, the entry into force of
the obligation is linked to the expiry of a certain time after the adoption of the necessary
implementing or delegated acts. This will give stakeholders and Member States sufficient time to
adapt. When a relevant provision does not specify a specific date for its entry into application, the
general application date applies, and companies will thus have to carry out the conformity
assessment procedure by 12 August 2026.
2) Annex VII refers to packaging 8type9. Does this wording mean the same as 8types9 in
Annex II, table 1?
The word 8type9 referred to in Annex VII concerning the conformity assessment procedure is not
the same as the packaging types referred to in Annex II. Annex VII refers to each packaging format
or each packaging batch/series and not to packaging materials, which are used for recyclability
assessment.
3) What is meant by 8the unique identification of the packaging9 referred to in Annex
VIII? Is the normal product traceability enough?
The Regulation does not define 8unique identification of the packaging=. This wording, referred
to in Annex VIII, means that the packaging itself needs to be identified in terms of the type, batch,
or serial number.
4) Is it sufficient that a single declaration of conformity is drawn up for packaging or a
packaged product? Or is it required that a dossier of all required declarations of
conformity is drawn up as a single document?
When a packaged product is subject to more than one Union act requiring an EU declaration of
conformity, such as the declaration of compliance under Article 15 of Regulation (EU) 10/2011 on
plastic materials and articles intended to come into contact with food or Article 16 of Regulation
(EC) No 1935/2004 on food contact materials, a single EU declaration of conformity may be drawn
up for all Union acts. That declaration must state the Union acts concerned and their publication
references. It may consist of a dossier of relevant individual EU declarations of conformity.
Therefore, manufacturers have a margin of discretion in assessing the necessity of drawing up a
single declaration of conformity. However, in case a single declaration of conformity is drawn up,
it must clearly distinguish the packaging from the packaged products. The manufacturer may decide
whether the single declaration of conformity is presented as a dossier with different declarations of
conformity or as a single document. If they are presented as a single document, the conformity
assessment for the packaged product and the packaging should still be done and presented
separately.
5) Is the assessment of conformity to be drawn up for each part of the packaging, such
as a bottle, closure and label, or for the entire packaging unit? UPDATED!
The assessment of conformity must be performed, and the declaration of conformity drawn up, for
the entire packaging unit. In other words, for a packaging unit made up of bottle, closure and label,
a single assessment of conformity and related declaration of conformity is sufficient for the unit as
a whole, though the declaration should include relevant information on all the separate components
used to make up that unit.
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