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Requirement · CNF-05

Draw up, continuously update and keep the EU declaration of conformity in the Annex VIII model, translated as the Member State of marketing requires, and assume responsibility for the packaging's compliance by drawing it up.

Manufacturers of packaging must comply, and this is law in force.

Why it matters

This is law in force, not a proposal.

  • It is Art. 39, in the Packaging and Packaging Waste Regulation. as of 2026-08-18
  • The act gives its timing as: From 12 August 2026 (Art. 71). as of 2026-08-18
  • It names 5 industries by name: Plastics converting, Paper and board, Glass, Aluminium and Wood. as of 2026-08-18
  • Compliance is checked by competent authority risk-based checks under Art. 39(5), per packaging type, continuously updated. as of 2026-08-18
Addressee Manufacturers of packagingAct Regulation (EU) 2025/40, base actArticle Art. 39Class Businesses

What changes

All packaging manufacturers. Where packaging or the packaged product falls under several Union acts requiring a declaration, a single combined declaration may be drawn up.

The rule

New — no predecessor
Trigger

packaging placed on the market

Obligation

Draw up, continuously update and keep the EU declaration of conformity in the Annex VIII model, translated as the Member State of marketing requires, and assume responsibility for the packaging's compliance by drawing it up.

Who is affected

Addressee
Manufacturers of packaging
Class
Businesses
Sectors
Names Plastics converting, Paper and board, Glass and ceramics, Aluminium and metals, Wood and wood products · Reaches Food, drink and tobacco, Retail and distribution
Applies
From 12 August 2026 (Art. 71)

Burden drivers

D1 · D5 · D6 — 3 of 7 marks fire on this provision.

No size threshold.

Source text

Verbatim

The EU declaration of conformity shall state that the fulfilment of the requirements laid down in or pursuant to Articles 5 to 12 has been demonstrated.

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