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Requirement · OPS-01

Carry out the Annex VII conformity assessment, draw up the technical documentation and the EU declaration of conformity, and keep both for 5 years for single-use and 10 years for reusable packaging.

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. 15(2) and (3), 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 self-assessment against Annex VII, per packaging type. as of 2026-08-18
Addressee Manufacturers of packagingAct Regulation (EU) 2025/40, base actArticle Art. 15(2) and (3)Class Businesses

What changes

Every packaging manufacturer selling into the EU. This is the single largest new administrative burden in the act: 94/62/EC had a presumption-of-conformity mechanism but no conformity assessment procedure, no technical documentation file and no EU declaration of conformity for packaging.

The rule

New — no predecessor
Trigger

before placing packaging on the market

Obligation

Carry out the Annex VII conformity assessment, draw up the technical documentation and the EU declaration of conformity, and keep both for 5 years for single-use and 10 years for reusable packaging.

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, Waste and landfill
Applies
From 12 August 2026 (Art. 71)

Burden drivers

D1 · D3 · D5 · D7 — 4 of 7 marks fire on this provision.

No size threshold.

Source text

Verbatim

Before placing packaging on the market, manufacturers shall carry out the conformity assessment procedure referred to in Article 38 or have it carried out on their behalf, and shall draw up the technical documentation referred to in Annex VII.

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