New documentation obligations for economic operators in the packaging supply chain.
From 12 August 2026, the manufacturer will be required to draw up the declaration of conformity pursuant to Article 39 and Annex VIII of Regulation (EU) 2025/40. The document certifies that packaging placed on the market complies with the requirements set out in Articles 5 to 12 of the same Regulation, on the basis of the technical documentation.
For the purposes of drawing up the declaration of conformity:
- the manufacturer (as defined in Article 3, point 1, para. 13 – PPWR), before placing packaging on the market, carries out the conformity assessment procedure pursuant to Article 38 and Annex VII of the PPWR;
- suppliers of packaging or packaging materials (as defined in Article 3, point 1, para. 16 – PPWR) provide the manufacturer with all the information and documentation needed to demonstrate the conformity of the packaging and materials, including the technical documentation required by Annex VII;
- the importer (as defined in Article 3, point 1, para. 17 – PPWR), before placing packaging on the market, ensures that the manufacturer has carried out the conformity assessment procedure and drawn up the technical documentation.
In the supply chain there is therefore always only one manufacturer, the party required to draw up the EU declaration of conformity. The other economic operators involved must provide it with all the information needed to prepare the technical documentation and the declaration itself.
Retention of documents
The EU declaration of conformity and the supporting technical documentation must be kept:
- for 5 years from the date of placing on the market, for single-use packaging;
- for 10 years from the date of placing on the market, for reusable packaging.
Declaration of conformity and technical documentation: the link between evidence and attestation
The declaration of conformity must be supported by a structured set of information, data and documentary evidence contained in the technical documentation, which forms the objective basis for the statements made in the declaration.
For this reason, the declaration of conformity and the technical documentation should be seen as parts of a single documentation system: the former summarises the conclusions on conformity, while the latter provides the supporting evidence.
CONAI support for companies
To help companies understand the new documentation obligations relating to the declaration of conformity, CONAI has prepared a new information notice that provides operational details on the declaration, explains the information to be included, the responsibilities laid down by the Regulation and the main deadlines to keep in mind.
The aim is to give companies a practical tool for understanding the new requirements, supporting the proper organisation of information flows along the supply chain and helping them prepare for the full application of the new provisions.
The CONAI information notice on the Declaration of Conformity and the technical documentation required by the PPWR is available at the following link (in Italian): CONAI information notice on the Declaration of Conformity (version of 09/07/2026).
For further information: the dedicated video on the Declaration of Conformity and the section on the New Packaging Regulation (in Italian).
Source: CONAI – News and Press
