The packaging Declaration of Conformity

Since 12 August 2026, packaging placed on the EU market needs an EU Declaration of Conformity behind it, supported by technical documentation.

Most of the documents circulating under that name are not one. They are supplier letters — a page of assurances on headed paper, unsigned or signed by somebody unidentified, stating that the goods “comply with all relevant legislation”. That sentence is worth nothing, and if you are the importer it is your name on the obligation, not theirs.

Who draws it up

Whoever places the packaging on the EU market.

• Packaging made in the EU: the manufacturer.
• Packaging imported from outside the EU: the importer. That is you, if you buy direct from a non-EU factory.
• Packaging bought from an EU distributor who imported it: the distributor who imported it — but you should still hold a copy.

This is the point that catches people. Buying from a factory in Asia and having the goods shipped to your warehouse makes you an importer with the full obligation, and no amount of documentation from the factory transfers it.

Buying the same goods from an EU supplier who imports them makes them the importer. That difference is worth real money in administrative cost, and it is one of the reasons to buy inside the single market.

What it must contain

A declaration of conformity follows the same pattern as every other EU product declaration. If a document is missing any of these, it is not one:

Element	What it means in practice
A unique identifier for the declaration	A number, so a specific version can be cited
Name and address of the manufacturer or importer	A legal entity with an address, not a brand
A statement that it is issued under the sole responsibility of that party	The sentence that makes it a legal act
Identification of the packaging	Enough to trace it: description, product code, dimensions, material, and usually a photograph
The Union legislation it conforms to	Regulation (EU) 2025/40, and any other instrument that applies
References to the standards or specifications used	Harmonised standards where they exist, or the technical specification relied on
Additional information	Test reports, notified body involvement where required
Place and date of issue	A declaration without a date cannot be checked against a specification change
Name, function and signature	A named person who holds a position, not “Sales Department”

The technical documentation behind it

The declaration is the summary. The technical documentation is what makes it true, and it stays with whoever drew up the declaration — it is produced on request from a market surveillance authority, not shipped with every order.

It normally covers:

• a general description of the packaging and what it is for,
• design and manufacturing drawings, and the composition,
• the requirements the packaging is assessed against, and how,
• test reports and measurements,
• for plastic packaging, the evidence of recycled content — which from 2030 becomes the part people wish they had started earlier.

You are entitled to ask whether it exists. You are not normally entitled to a copy of all of it, because it contains formulation detail that is genuinely commercially sensitive.

How to tell a real one

Four checks, in about ninety seconds:

1. Is there a named signatory with a function? “J. Kowalski, Quality Manager” is a declaration. “Sales Department” is a letter.
2. Does it identify the specific packaging? A declaration covering “all our polyethylene products” covers nothing you can rely on.
3. Does it cite the legislation by number? “Complies with EU regulations” is not a citation. “Regulation (EU) 2025/40” is.
4. Is it dated, and does the date come after the specification you were quoted? A declaration issued before a material change describes a different product.

What to do with it

Keep it with the purchase record for the batch, not in a general file. If a market surveillance authority asks, the question is about a specific consignment and the answer has to be traceable to it.

Where you are the importer, you have to be able to produce the declaration and, on request, the technical documentation — which means you need an arrangement with the manufacturer to obtain it, agreed before the order rather than after the question.

What we do

For goods we import into the EU, we are the importer and we draw up the declaration. It is issued per specification, identified by product code, signed by a named person, and reissued whenever the specification changes.

The technical documentation sits with us and with the manufacturer, and it is available to a market surveillance authority on request. Customers receive the declaration with the first delivery of a specification and again whenever it is reissued.

This is one of the more concrete reasons to buy through an EU entity rather than direct from a factory outside it: the obligation, the paperwork and the exposure sit with somebody whose business it is.