A Declaration of Conformity (DoC) can be prepared quickly. The real challenge arises when a company needs to demonstrate exactly what the declaration is based on for a specific packaging item. Which packaging is covered? Which components does it include? What technical evidence supports its compliance? If these elements cannot be clearly linked, simply having a formal Declaration of Conformity (DoC) is not enough.
Under the Packaging and Packaging Waste Regulation (PPWR), the ability to provide this evidence becomes a practical compliance requirement.
The key question is therefore not: "Do we have a DoC?" Instead, it is: "Can we clearly and reliably demonstrate why each relevant packaging item is compliant?"
Packaging Must Be Clearly Identifiable
The PPWR requires manufacturers to carry out the prescribed conformity assessment procedure and prepare the technical documentation before placing packaging on the market. By issuing the EU Declaration of Conformity, the manufacturer assumes responsibility for ensuring that the packaging concerned meets the applicable requirements.
What matters is the clear link to the specific packaging. The template provided in Annex VIII of the PPWR requires, among other things, unique identification of the packaging and a description of the object of the declaration that enables its traceability.
This makes one thing clear: A DoC should not simply be regarded as a general corporate declaration. It must be traceably linked to the packaging items whose conformity it declares.
Primary, Secondary and Transport Packaging: When Is a Separate Assessment Needed?
In practice, packaging solutions often consist of several layers. For example, a product may be contained in primary packaging, several products may be grouped together in secondary packaging, and additional packaging may then be used for transport.
These packaging levels can differ significantly in terms of materials, structure, function and regulatory characteristics.
The first question should therefore not be: "How many DoCs do we need?" Instead, it should be:
"Which packaging units do we actually have, and which of them can reasonably and transparently be assessed together?"
A one-size-fits-all approach can quickly become problematic. If very different packaging items are covered by a single declaration, it must still be possible to clearly identify which packaging items the declaration applies to and which technical documentation supports their respective compliance.
Conversely, this does not necessarily mean that every minor packaging variation automatically requires a completely separate document.
What matters is a robust structure that enables packaging items to be uniquely identified and linked to the relevant supporting evidence.
The Real Project Starts with Packaging Data
For companies with extensive packaging portfolios, the DoC quickly becomes a matter of data management and processes.
Key questions include:
Companies that currently manage this information across product databases, supplier documentation, Excel spreadsheets and different departments will need to consolidate it systematically to meet PPWR requirements.
It is also worth looking beyond individual packaging items. A structured packaging database can support other regulatory tasks in the future, such as Extended Producer Responsibility (EPR) quantity reporting or the calculation of financial contributions.
The Right Starting Point: Packaging Mapping
Before preparing Declarations of Conformity, companies should therefore carry out a packaging mapping exercise.
The first step is to identify and document the packaging portfolio, determine the relevant packaging levels and components, and then establish how technical documentation and Declarations of Conformity will be linked.
This not only reduces the risk of incomplete declarations. It also prevents companies from having to collect the same packaging information repeatedly for different compliance processes.
The key question is therefore not simply: "Do we need one DoC or several?"
It is: "Can we provide clear, traceable evidence demonstrating why each relevant packaging item is compliant?"
Coming Up in Our Next Article
In our next article, we will take a closer look at:
How 1cc and TechProtect Can Help
This is exactly where 1cc and TechProtect come in.
1cc translates PPWR requirements into clear specifications for conformity assessment and documentation. TechProtect brings packaging information and supporting evidence together in a robust operational structure.
The result: You can provide clear, traceable evidence demonstrating why each relevant packaging item is compliant, without having to gather the same information from different sources for every compliance process.
We assess whether your DoC structure is sufficiently robust, identify specific gaps, and ensure that packaging data, technical evidence and Declarations of Conformity are clearly and consistently aligned.