EU Declaration of Conformity
The PPWR manufacturer signs it and assumes responsibility for packaging conformity. For Nactarome-filled sales packaging, that will normally be Nactarome.
Articles 15, 38 and 39 · Annexes VII–VIIIEU PPWR 2025/40 + UK packaging EPR · verified 20 July 2026
One packaging flow.
Two different answers.
Find Nactarome’s product-compliance role and the separate EPR producer responsibility across the EU and UK—without mixing up the declarations.
Takes about 2 minutes · evaluates one packaging unit and one transaction at a time · answers are not stored
01
Manufacturer
Owns packaging conformity and the EU Declaration of Conformity.
02
Producer
Owns EPR registration, reporting and financing in a Member State.
03
They may differ
The answer changes by packaging unit, transaction and country.
UKUK is always included.
Great Britain follows the separate UK packaging EPR route. Northern Ireland is recorded and checked separately. UK-to-EU sales also trigger an EU importer and destination-country EPR assessment.
Role finder
Follow the packaging, not the company title.
Run a separate check for the drum, carton, pallet or stretch film when their flows differ.
Single decision path
Eight facts produce two outcomes.
The overview is generated from the same question data used by the interactive role finder.
One guided check. Two legally separate results.
You will receive the likely PPWR product-compliance role, the EU Declaration of Conformity owner and the destination-country EPR conclusion. The UK route is included.
The one rule to remember
“Who makes the declaration?” is not one question.
EPR declaration and fees
The destination-country producer registers, reports packaging quantities and finances waste management. It can be a different company in each Member State.
Articles 3(15), 44 and 45Operational guideline
What PPWR means in daily Nactarome work.
Use this as the common Group baseline. Country reporting procedures remain a separate local verification.
One packaging unit at a time
A filled drum, its outer carton, pallet and stretch film can have different manufacturers and EPR producers. Never approve “the product packaging” as one undefined block.
Sales · grouped · transport
“Primary, secondary and tertiary” may be familiar, but the regulatory record should use the PPWR function-based terminology. E-commerce packaging is a type of transport packaging.
PPWR and food contact
The PPWR EU Declaration of Conformity and the food-contact Declaration of Compliance serve different laws. Keep them linked, but distinguish the responsible issuer and evidence.
UK · always in scope of this Group tool
One Group view, two legal workstreams.
Great Britain follows UK packaging EPR rather than the PPWR. Northern Ireland needs a dedicated check. When the UK entity supplies the EU, separately identify the PPWR manufacturer, the EU-established importer and the destination-country EPR producer.
Who does what
Five roles, five different consequences.
RoleOperational testMain consequenceBasis
Manufacturer
Who manufactures the packaging or packaged product—or has it designed or manufactured under its name or trademark?
Owns conformity assessment, technical documentation and the EU Declaration of Conformity.
Arts. 3(13), 15, 38–39Supplier
Who supplies packaging or packaging material to the manufacturer?
Provides the information and documentation the manufacturer needs to demonstrate conformity.
Arts. 3(16), 16Importer
Which EU-established legal person first places third-country packaging or packaged products on the Union market?
Verifies the manufacturer’s file, adds importer identity and retains or accesses the evidence.
Arts. 3(17), 18Distributor
Who makes packaging available after the manufacturer or importer without changing it or using own branding?
Acts with due care and verifies identity, labelling and EPR registration before supply.
Arts. 3(18), 19EPR producer
Who first makes the packaging available in the Member State where it is expected to become waste?
Registers, reports quantities and finances waste management in that Member State.
Arts. 3(15), 44–45Date map
12 August is a transition point, not one giant deadline.
Now12 Aug 2026
General application
Economic-operator duties become operational. Food-contact packaging placed on the market from this date must meet the PPWR PFAS limits. General recyclability applies using the existing approach pending detailed criteria.
Next12 Feb 2028
Selected compostability rules
Specified beverage bags and soft after-use units must be compostable. Confirm the exact packaging format and any national compostability rules.
Later12 Aug 2028 or later
Harmonised sorting label
The material-composition label starts on this date or 24 months after the relevant implementing act enters into force, whichever is later. Transport packaging is generally excluded, except e-commerce packaging.
Design1 Jan 2030 or later
Major design requirements
Detailed design-for-recycling, recycled-content, minimisation, empty-space and reuse requirements begin on their respective dates, often subject to later implementing or delegated acts.
Scale1 Jan 2035 or later
Recycled at scale
The recyclability-at-scale condition applies from 2035 or the later date linked to the implementing methodology.
Minimum evidence deck
What to request and retain for August 2026.
This is a Nactarome internal readiness control. The exact evidence depth remains risk- and packaging-specific.
Identify the packaging
- Supplier and PPWR manufacturer identity
- Packaging type or family and intended use
- Sales, grouped, transport or e-commerce classification
- Material, components and component weights
- Type, batch, serial or equivalent traceability
Obtain conformity inputs
- Article 16 information for Articles 5–11
- Heavy-metals and substances evidence relevant to Article 5
- Available standards, specifications and test reports
- Recyclability evidence under the current approach
- Reusable-packaging evidence where a reuse claim is made
Add food-contact evidence
- Separate food-contact Declaration of Compliance
- Applicable Regulation (EC) 1935/2004 or plastics documentation
- PFAS compliance statement against all Article 5(5) limits
- Test method, scope and analytical basis
- NIAS and migration evidence where applicable
Close the control loop
- Who signs the PPWR EU Declaration of Conformity
- Annex VII technical-document owner
- Annex VIII declaration reference
- Change-notification commitment
- Retention: 5 years single-use or 10 years reusable
EU + UK routes
The EU role is common. The UK remains separate. Both are included.
This operational map was checked on 20 July 2026. Confirm the filing route at the point of declaration because national transitions are moving.
BE
Belgium
EPRiBEL / IRPC; Valipac for industrial and commercial packaging
Official national guidance
The authority confirms a 2026 split: the former responsible company reports through 11 August; the new PPWR producer reports from 12 August. Rigid transport packaging requires special attention.
Nactarome action
Re-map every Belgian industrial flow and obtain producer registration evidence before 12 August.
Open source →FR
France
ADEME / SYDEREP; applicable approved eco-organisation
Official national guidance
ADEME states that the route for all professional packaging is forthcoming; restaurant packaging and transitional reporting remain distinct.
Nactarome action
Confirm the live EPRO scope, approved organisation and reporting route immediately before filing.
Open source →IT
Italy
CONAI or recognised autonomous route
PRO operational guidance
The existing CONAI system governs membership, declarations and environmental contributions while PPWR roles are overlaid.
Nactarome action
Confirm the contracting entity’s CONAI classification, imports and contribution procedure; assess PPWR product compliance separately.
Open source →ES
Spain
MITECO Product Producers Register—packaging section
Official national guidance
Spanish product producers or authorised representatives register and report under Royal Decree 1055/2022. Reconcile the PPWR conclusion with the national record.
Nactarome action
Match the legal entity, RPP number and collective or individual responsibility system to each Spanish flow.
Open source →NL
Netherlands
Verpact / Dutch packaging administration
Official national guidance
Manufacturers and importers can carry packaging EPR duties under the current Dutch system when the applicable conditions and thresholds are met.
Nactarome action
Validate the current threshold, reporting route and PPWR producer transition before the first post-August filing.
Open source →HR
Croatia
FZOEU Register of Producers with Extended Responsibility (RPPO)
Official national guidance
The RPPO records producers, covered products and quantities placed on the market, including packaging obligations.
Nactarome action
Confirm the contracting legal entity’s registration, reporting cadence and packaging data fields in RPPO.
Open source →GR
Greece
EOAN National Producers Register (EMPA) and approved system
Official national guidance
Greek packers, own-account packers, importers and qualifying distance sellers can fall within the current producer framework.
Nactarome action
Confirm the contracting legal entity’s EMPA registration and approved packaging system before supply.
Open source →UK
UK
Great Britain: UK packaging EPR. Northern Ireland: dedicated applicability route.
Official UK guidance · separate workstream
Great Britain is outside the PPWR and follows UK packaging EPR. Northern Ireland must be checked separately; neither the GB nor EU answer should be copied automatically.
Nactarome action
Open NI source →
Maintain UK producer assessments, registrations, data reporting and fee or recycling evidence. Record Great Britain and Northern Ireland flows separately.
Open GB source →Open NI source →
Worked examples
How common Nactarome flows land.
These are screening outcomes. The exact contract, branding and destination facts remain decisive.
ScenarioPackagingProduct-compliance roleEPR producer
Nactarome fills a drum or bag with its product
Sales packaging
Nactarome manufacturer
Nactarome usually producer in the domestic Member State
Nactarome buys an unbranded finished pallet domestically
Transport packaging
Pallet maker normally manufacturer
Domestic pallet maker normally producer for the empty pallet
Nactarome imports finished own-brand packed goods
Sales or grouped
Nactarome manufacturer + importer
Importing Nactarome entity normally domestic producer
Nactarome buys EU-branded finished goods and resells unchanged
Sales or grouped
Nactarome distributor
First supplier in the domestic Member State is normally producer
EU entity sells directly to an industrial end user in another Member State
Any packaged product
EU-wide product role remains transaction-specific
Seller is likely producer in the destination; representative required
EU entity supplies a reseller in another Member State
Any packaged product
EU-wide product role remains transaction-specific
Destination reseller normally becomes producer there
Packaging becomes waste outside the EU
Any
Check whether prior EU making-available occurred
No PPWR EPR in a Member State for the exported waste flow
UK entity supplies within Great Britain
Any
UK product-law assessment; no PPWR for a GB-only flow
UK entity assessment under UK packaging EPR
UK entity supplies directly to an EU professional end user
Any
UK manufacturer or supplier; EU importer to identify
UK entity is normally destination producer and appoints an EPR representative
Nactarome control flow
Evidence moves once. Responsibility stays visible.
Describe the flow
Sales and Operations identify legal entity, packaging unit, source, destination and customer use.
Collect the evidence
Procurement obtains the Article 16 supplier pack and change-notification commitment.
Confirm the role
QA and Regulatory determine manufacturer, importer or distributor and own the conformity decision.
Close EPR
Sustainability and Finance confirm country registration, reporting data and fees before supply.
Group open points to close
Confirm the exact Nactarome legal-entity register and all existing EPR numbers.
Define the packaging-family method for EU Declarations of Conformity.
Confirm professional end user versus reseller in cross-border B2B contracts.
Resolve branded transport packaging and reusable asset ownership.
Keep Northern Ireland as a dedicated legal route.
Monitor implementing acts and national register transitions.
Source register
Every conclusion has a visible legal level.
Regulation (EU) 2025/40
Economic-operator definitions, sustainability requirements, conformity and EPR.
Commission Notice C/2026/3702
Manufacturer, producer, importer, PFAS, dates and reuse interpretations.
Commission PPWR FAQ—30 March 2026
Implementation questions complementing the Commission Notice.
Belgian EPRiBEL / IRPC PPWR transition
Belgian role change and split 2026 declaration.
French ADEME EPRO status
Professional-packaging EPR scope and rollout status.
Spanish MITECO packaging register
Existing Spanish producer registration.
Dutch packaging rules
Existing Dutch EPR route.
Croatian RPPO
Existing Croatian register.
Greek EOAN / EMPA
Existing Greek producer register and schemes.
UK packaging EPR
Separate Great Britain and Northern Ireland workstream.
Printable companion
PPWR guideline or case record
Use the browser’s Save as PDF option. The code switches to clean print layouts for the full guideline, the complete logic overview or an individual role-finder result.