Short answer: there is no "PPWR certificate" issued by an authority. What the Regulation asks for is the EU declaration of conformity, and the manufacturer draws it up itself. Behind it sits the technical documentation. No notified body is required.
When a buyer in the EU asks you for a "PPWR certificate", they want one of two things: either the EU declaration of conformity that you issue, or the information and documents they need to prepare their own. Which one depends on your role for that packaging. This article follows the text of Regulation (EU) 2025/40 step by step. The information was read from the sources on 5 October 2026.
Is there a PPWR certificate, and who issues it?
No. PPWR stands for the Packaging and Packaging Waste Regulation. It requires conformity to be shown through "internal production control". Under this procedure the manufacturer carries out the assessment itself and takes sole responsibility (Art. 38, Annex VII). There is no requirement for a certification body in between.
A laboratory gives you test reports and a consultant can help you build the file, but the party that signs the declaration and carries the responsibility is the manufacturer.
Is a company outside the EU the manufacturer or a supplier?
The manufacturer is whoever makes the packaging or the packaged product. If someone else has it designed or made under their own name or trademark, they are the manufacturer (Art. 3(1)(13)). The definition has no requirement to be established in the EU. A supplier is whoever supplies packaging or packaging material to a manufacturer (Art. 3(1)(16)).
- If you are the manufacturer: you carry out the conformity assessment, draw up the technical documentation and issue the EU declaration of conformity (Art. 15). The importer in the EU must ensure that you have done so (Art. 18).
- If you are a supplier: you do not issue a declaration. You give the manufacturer all the information and documents needed to demonstrate conformity, in a language it understands (Art. 16).
According to the information note published by Türkiye's Ministry of Trade on 3 August 2026, a company that makes packaging under its own brand and sells it to the EU can be treated as the manufacturer, and a company selling material to an EU manufacturer as a supplier. The same company can be the manufacturer for one product and a supplier for another. Settle your role per product and per contract.
What goes into the EU declaration of conformity?
The declaration follows the model in Annex VIII (Art. 39). It has eight points:
- The unique identification of the packaging.
- The name and address of the manufacturer and, where applicable, of the authorised representative.
- A statement that the declaration is issued under the sole responsibility of the manufacturer.
- The object of the declaration: a description of the packaging allowing traceability.
- A statement that the packaging conforms to the relevant Union legislation.
- References to the harmonised standards, common specifications or other technical specifications used.
- Where applicable, the notified body and the certificate it issued.
- Additional information.
It ends with the place, date, name, function and signature. A declaration is drawn up in writing for each packaging type (Annex VII, point 4), kept up to date and translated into the language required by the Member State where the packaging is made available (Art. 39).
What is in the technical documentation?
The declaration is not enough on its own; it rests on the technical documentation. Under Annex VII the file contains at least:
- A general description of the packaging and its intended use.
- Design and manufacturing drawings and the materials of the components.
- The descriptions and explanations needed to understand the drawings and how the packaging works.
- A list of the harmonised standards, common specifications or other technical specifications applied.
- A description of the assessments on recyclability, packaging minimisation and reuse.
- Test reports.
The file also includes an analysis of the risk of non-conformity. Declarations from your suppliers are part of the file but do not replace it: the assessment is the manufacturer's.
Which tests are needed?
Two chemical limits have applied since 12 August 2026:
| Topic | Limit | Source |
|---|---|---|
| Heavy metals | The sum of lead, cadmium, mercury and hexavalent chromium may not exceed 100 mg/kg. All packaging. | Art. 5(4) |
| PFAS | Food-contact packaging only. 25 ppb for any single PFAS, 250 ppb for the sum of PFAS, 50 ppm including polymeric PFAS. | Art. 5(5) |
Compliance with these limits is demonstrated in the technical documentation (Art. 5(6)). The Commission's guidance says a sample with total fluorine below 50 mg/kg could be considered compliant; that is guidance, not a provision of the Regulation. The guidance also notes that there is no harmonised EU test method for PFAS. Agree with your laboratory and your buyer which test covers which product.
Are pallets, stretch film and boxes in scope?
The Regulation covers sales packaging, grouped packaging and transport packaging. The Ministry of Trade's note uses pallets, stretch film and boxes as examples. The heavy metal limit applies to all packaging (Art. 5(4)).
Does the declaration travel with every shipment, and how long is it kept?
The manufacturer keeps the technical documentation and the declaration for 5 years after single-use packaging is placed on the market and 10 years for reusable packaging (Art. 15(3)). The importer keeps a copy of the declaration for the same period (Art. 18). Documents are provided within 10 days when an authority asks (Art. 15).
According to the Ministry of Trade's note, the declaration does not have to accompany every shipment and the Regulation has no provision for systematic presentation at customs. Your buyer may still ask for it with each shipment; that is a matter for the contract.
What started on 12 August 2026, and what has not started yet?
| Status | Requirement | Source |
|---|---|---|
| Started | Heavy metal limit, PFAS limit in food-contact packaging, conformity assessment, technical documentation and EU declaration of conformity, manufacturer and importer details on the packaging. | Art. 5, 15, 18, 38, 39 |
| 12 February 2027 | Member States lay down their rules on penalties by this date. The Regulation sets no amounts. | Art. 68 |
| 12 August 2028 or later | Harmonised material label. The date moves to 24 months after the implementing act if that is later. | Art. 12(1) |
| 1 January 2030 or later | Recyclability grades (nothing outside A, B, C) and minimum recycled content in plastic. Both can move later depending on secondary legislation. | Art. 6(3), 7(1) |
Penalty rules being tied to a later date does not postpone the obligations: the requirements have applied since 12 August 2026 (Art. 71).
Where to start
- List the packaging for every product going to the EU: sales, grouped and transport packaging separately.
- Settle your role for each: manufacturer or supplier.
- Ask your suppliers in writing for material and component information.
- Plan the heavy metal test, and the PFAS test for food-contact packaging.
- If you are the manufacturer, prepare the technical documentation and the declaration in the Annex VIII model. If you are a supplier, prepare the document set for your buyer.
- Keep the documents accessible for 5 or 10 years.
The Registamp PPWR module runs these steps from your packaging records: it checks measurements against the limits and prepares the technical documentation and the declaration. See the PPWR module page.
This article is general information, not legal advice. For your own case, refer to the text of the Regulation and, where needed, to a specialist.
Sources
- Regulation (EU) 2025/40 on packaging and packaging waste: eur-lex.europa.eu/eli/reg/2025/40/oj
- European Commission guidance notice, C(2026) 3702 final, 5 June 2026: EUR-Lex
- European Commission, packaging waste page: environment.ec.europa.eu
- Ministry of Trade of Türkiye, PPWR announcement and information note, 3 August 2026 (in Turkish): ticaret.gov.tr