PPWR Declaration of Conformity: Do You Need One for Every Packaging SKU?
Do you need a separate PPWR Declaration of Conformity for every packaging SKU? What if several packaging variants share the same material but differ in size or weight? Learn how packaging types, conformity assessments and technical documentation fit together under Regulation (EU) 2025/40, and what to consider before grouping packaging SKUs.
PPWR Declaration of Conformity: Do You Need One for Every Packaging SKU?
If your company manages 200 packaging SKUs, does that mean you need 200 EU Declarations of Conformity under the Packaging and Packaging Waste Regulation (PPWR)?
Not necessarily.
Under Regulation (EU) 2025/40, conformity documentation must relate to clearly identifiable packaging and demonstrate compliance with the applicable requirements. Annex VII refers to a Declaration of Conformity for each packaging type, while Annex VIII specifies how the packaging must be identified in that declaration.
However, a commercial SKU and a packaging type are not automatically the same thing.
That distinction matters for manufacturers, importers, packaging suppliers and brands managing large packaging portfolios.
Does PPWR require a Declaration of Conformity for every SKU?
Short answer: The PPWR does not explicitly require a separate EU Declaration of Conformity for every commercial SKU. It requires conformity to be demonstrated for the packaging concerned, with the declaration identifying the packaging covered.
Article 38 establishes the conformity assessment procedure, while Article 39 governs the EU Declaration of Conformity.
Annex VII sets out the assessment framework and refers to the declaration for each packaging type. Annex VIII requires a unique packaging identification and a description that allows traceability.
The important distinction is between commercial inventory management and regulatory conformity.
A company may assign multiple SKUs to packaging variants that share relevant characteristics. But whether those variants can be covered together depends on the conformity assessment and how the declaration's scope is defined.
The regulation does not establish a general rule allowing companies to group all packaging made from the same material into a single packaging type.
What is the difference between a packaging SKU and a packaging type?
A Stock Keeping Unit (SKU) is a commercial identifier used for inventory, procurement and product management.
A packaging type, in the context of PPWR conformity assessment, refers to the packaging for which compliance is being demonstrated and documented.
For example, consider a packaging supplier offering three corrugated cardboard boxes:
Characteristic | Box A | Box B | Box C |
|---|---|---|---|
Material | Corrugated cardboard | Corrugated cardboard | Corrugated cardboard |
Dimensions | 200 × 150 × 100 mm | 300 × 200 × 150 mm | 400 × 300 × 200 mm |
Weight | 85 g | 140 g | 220 g |
Supplier | Same | Same | Same |
Intended use | Transport | Transport | Transport |
These are three commercial SKUs.
But do they represent three distinct packaging types for conformity documentation purposes?
The fact that they use the same material and supplier does not resolve the question.
The manufacturer must examine whether the differences between them affect applicable PPWR requirements and whether the assessment adequately covers every variant.
Can multiple packaging sizes share one PPWR Declaration of Conformity?
Potentially, but grouping packaging variants should be supported by a documented conformity assessment rather than assumed from similar materials or designs.
A declaration may identify multiple variants where its scope is clear and each covered variant has adequate supporting evidence. This is a possible documentation approach, not an automatic permission to consolidate different packaging types.
For example, a manufacturer could maintain a technical documentation structure containing:
A common material specification
Individual packaging dimensions and weights
Information about coatings, inks, adhesives and other relevant components
Applicable test reports and technical assessments
An identification system linking packaging variants to their supporting evidence
A clearly defined scope for the relevant declaration
However, sharing a material specification is not necessarily enough.
Different packaging dimensions, constructions and intended uses can affect conformity.
Where those differences require distinct assessments, the documentation structure must reflect that.
Which PPWR requirements can be affected by packaging variations?
Several PPWR provisions are relevant when evaluating packaging variants.
Article 5: Substances in packaging
Changes to inks, coatings, adhesives, additives or other materials can affect the evidence needed to demonstrate compliance with restrictions on substances in packaging.
Two cardboard boxes may look identical but have different material compositions.
Article 6: Recyclable packaging
Article 6 establishes recyclability requirements with phased application dates.
Differences in material combinations, coatings, labels and other packaging characteristics may affect recyclability assessments.
Article 10: Packaging minimization
Article 10 introduces requirements concerning packaging minimization, with application from 1 January 2030.
Dimensions, weight, design and intended function can become particularly relevant when demonstrating that packaging has been minimized appropriately.
Article 15: Manufacturer responsibilities
Manufacturers must demonstrate conformity with the applicable requirements and take adequate account of changes to packaging design, characteristics and relevant technical specifications.
If changes could affect conformity, reassessment is required.
This means packaging grouping is not simply an administrative decision.
It must remain consistent with the characteristics and evidence underlying the conformity assessment.
What technical documentation is needed when grouping packaging SKUs?
Annex VII requires technical documentation that allows assessment of conformity with the relevant PPWR requirements.
Depending on the packaging and applicable obligations, documentation may include:
Packaging identification, description and intended use
Design information and component-material specifications
Relevant drawings and technical details
Applicable standards and technical specifications
Assessments, calculations and test reports
Evidence demonstrating compliance with applicable requirements
Traceability between packaging variants and the evidence supporting them
A single supplier certificate does not automatically establish conformity for every packaging SKU supplied.
Similarly, a generic statement that a packaging family is “PPWR compliant” may be insufficient if it does not identify the packaging covered and the basis for the conformity assessment.
For a detailed explanation, see our guide: PPWR Technical Documentation: What Evidence Must Support Packaging Conformity?.
Five questions to ask before grouping packaging variants
Before deciding whether several packaging SKUs can be addressed together, manufacturers should consider five practical questions.
1. Do the packaging variants share equivalent material and design characteristics?
Examine the complete material composition, not only the primary material.
2. Do the variants have the same intended function?
Packaging that serves different functions or operates under different conditions may require distinct assessments.
3. Could variations in size, weight or construction affect PPWR conformity?
Review the relevant requirements and their application dates.
4. Does the supporting technical documentation cover every variant?
Common evidence may be reusable, but differences requiring additional evidence must still be addressed.
5. Can every SKU be traced to the correct packaging specification and Declaration of Conformity?
A clear connection between the commercial SKU, packaging identification, conformity assessment and declaration is essential.
If these questions cannot be answered confidently, the proposed grouping should be reviewed before relying on it for conformity documentation.
What does this mean for packaging suppliers and importers?
Packaging suppliers often manufacture numerous variants of similar packaging designs.
Under Article 16, suppliers must provide manufacturers with the information and documentation necessary for the manufacturer to demonstrate packaging conformity.
This makes structured, variant-specific packaging information important.
However, supplying evidence does not automatically make the supplier the manufacturer legally responsible for the EU Declaration of Conformity.
That depends on the economic operator's role under the PPWR.
Importers, meanwhile, have verification responsibilities under Article 18, including ensuring that the manufacturer has carried out the required conformity assessment and prepared the relevant technical documentation.
For organizations working with multiple suppliers, the practical challenge is connecting the right evidence to the right packaging, without relying solely on supplier names or broad product categories.
Frequently asked questions about PPWR Declarations of Conformity
Is a PPWR Declaration of Conformity required for each packaging type?
Yes. Annex VII provides for a written EU Declaration of Conformity for each packaging type following the applicable conformity assessment. The packaging must be identifiable, and the declaration must conform to Article 39 and Annex VIII.
Can different packaging sizes be considered the same packaging type?
Different sizes do not automatically establish separate packaging types, nor does identical material automatically establish one common type. The manufacturer must determine the appropriate assessment and declaration scope based on the packaging characteristics and applicable requirements.
Can one Declaration of Conformity list several packaging SKUs?
A declaration may identify several variants where they can legitimately be covered by the same conformity assessment and are clearly traceable. This should not be interpreted as a blanket exemption from packaging-type requirements.
Does each packaging SKU need its own technical file?
The PPWR does not prescribe a separate physical or electronic folder for every commercial SKU. Documentation may be organized in a shared system, provided the required conformity evidence for each relevant packaging type remains complete, traceable and accessible.
What happens if a packaging supplier changes a material or design?
Under Article 15, the manufacturer must take adequate account of changes affecting the packaging and reassess conformity where it could be affected. Existing evidence should not automatically be assumed to cover a modified packaging specification.
How long must PPWR conformity documentation be retained?
Manufacturers must retain the required technical documentation and EU Declaration of Conformity for five years for single-use packaging and ten years for reusable packaging, calculated from the date the packaging was placed on the market.
The real challenge is not the number of declarations
For companies managing hundreds or thousands of packaging SKUs, the objective should not be to create as many compliance documents as possible.
It should be to establish a defensible connection between:
Packaging identification → Packaging specifications → Supporting evidence → Conformity assessment → EU Declaration of Conformity
One commercial SKU does not necessarily require one separate declaration. But one shared material does not automatically make several packaging variants one packaging type.
The important question is whether the packaging has been correctly identified and whether its conformity can be demonstrated using the evidence and assessment supporting the declaration.
As PPWR implementation progresses, organizations that structure packaging information properly will be better equipped to manage supplier changes, maintain documentation and respond to regulatory requirements.
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Regulatory references
Regulation (EU) 2025/40, particularly Articles 5, 6, 10, 15, 16, 18, 38 and 39, and Annexes VII and VIII.
Official regulation: https://eur-lex.europa.eu/eli/reg/2025/40/oj
Published by PPWR Academy | 12 October 2026
This article provides general educational information and does not constitute legal advice. The scope of conformity documentation should be established for the relevant packaging and applicable requirements.
