PPWR Packaging Layers and the EU Declaration of Conformity
A carton with a plastic window and an aluminium seal is not one packaging item — it's three materials, and the Packaging and Packaging Waste Regulation treats them as three. Getting PPWR right starts with declaring each layer on its own, and ends with a single EU Declaration of Conformity generated from that data, in every language you sell into, archived for years.
Why layers, not "packaging"
PPWR (Regulation EU 2025/40) is built around the physical make-up of a pack. Recyclability, recycled-content targets and substance limits all apply per material, not to some average of the whole. A pouch that is 80% PE film and 20% aluminium can't claim a single recyclability grade — each component is assessed and reported separately, and the weakest layer often drives the outcome.
So the first job is a proper composition breakdown: list every layer, its material, its mass share and its function. Once that structure exists, the rest of PPWR compliance falls out of it.
Article 12: declare each layer separately
Under the layer-level approach the PPWR expects, each packaging component carries its own record:
| Per layer | What you declare |
|---|---|
| Material | Polymer or substrate (PE, PET, paper, aluminium, glass…) and mass share |
| Recyclability grade | Design-for-recycling class A / B / C — below C is restricted from the market |
| Recycled content | Post-consumer recycled share, against the plastic recycled-content targets |
| Art. 5 substances | Heavy metals (Pb+Cd+Hg+Cr VI ≤ 100 mg/kg) and PFAS limits for food-contact packaging |
| EPR registration | Producer-responsibility scheme registration, per member state |
Recyclability grades A / B / C
PPWR grades design-for-recycling performance on a scale where A is best. From 2030, packaging graded below a set threshold cannot be placed on the market, and higher grades attract lower EPR fees under eco-modulation. Recording the grade per layer is what makes both the market check and the fee calculation possible.
A passport stores this as a structured, checkable record rather than a marketing claim — the same "actual numbers, not a self-declared badge" approach we take with the wider set of PPWR producer obligations. Which of these marks stay printed on the pack and which move behind a QR is a separate design decision, covered in our packaging labelling guide and in what must stay on the pack vs what can move to the QR.
Article 5: substance limits per layer
Article 5 restricts what can be in the packaging. Two families matter most:
- Heavy metals — the sum of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg
- PFAS — food-contact packaging faces strict limits on individual and total per- and polyfluoroalkyl substances
Because these are assessed at the material level, the layer breakdown is exactly the structure an auditor needs: they can see the aluminium seal, the ink layer and the film each carry their own compliant values.
The EU Declaration of Conformity: Art. 38 / 39, Annex VIII
All of the above is the evidence. The EU Declaration of Conformity is the single document that ties it together and states, on the producer's responsibility, that the packaging meets PPWR. Under Articles 38 and 39, after the conformity assessment the producer draws up this declaration following the model in Annex VIII. It names the packaging, the producer, the assessment carried out, and confirms compliance.
The declaration is short — but it must be right, kept current, and available. That's precisely where deriving it from structured layer data pays off: change a material or a recycled-content figure, and the declaration regenerates rather than being hand-edited.
Every EU language, archived for years
Two practical requirements trip people up:
- Language — the declaration has to be provided in a language easily understood by the authorities of the member state where the packaging is placed on the market. Sell across the EU and you need it in effectively any of the 24 official languages, on demand.
- Retention — the declaration and its supporting technical documentation must be kept for 5 years for single-use packaging and 10 years for reusable packaging, after the last unit is placed on the market.
dpp.gs generates the Declaration of Conformity straight from the layer data as both machine-readable JSON and a printable HTML document, renders it in every EU language, and links it from the QR code — so it's one tap away on the shelf and one export away for an authority, not buried in an email thread. The retention clock and assessment date travel with it.
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Per-layer materials, A/B/C recyclability, recycled content, Art. 5 limits and EPR — with an EU Declaration of Conformity in every EU language.
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