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EU DoC Flow

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DoC Log

Version	Date	Prepared by (technical work)	Approved by (signatory)	Brief description of change

Disclaimer

The information in this document reflects the author’s best knowledge and experience at the time of writing. It is provided “as is,” without any warranty or representation - express or implied - regarding its accuracy, completeness, or suitability for any purpose. No assurance is given that any statements, projections, or expectations described will occur, and nothing in this document should be understood as a promise or representation of future outcomes.

This document, and any related verbal communications, do not constitute legal advice. Responsibility for ensuring compliance with all applicable laws and regulations remains solely with the recipient. Because legal requirements and interpretations can vary depending on the facts and circumstances, this document is not a substitute for consultation with a qualified legal professional.

To the extent permitted by law, the author will not be liable for any loss or damage arising from the use of, or reliance on, the information in this document, except where such loss or damage results from the author’s gross negligence or intentional misconduct. Any decisions taken by the recipient are made at their own discretion and based on their own independent assessment.

DoC

Table 1

What	Notified body and certificate details (if applicable)*	Additional acts / expected next steps
EU DoC (Declaration of Conformity) No: DoC-PPWR-SP-02-2026	Conformity assessment is internal production control based on Annex VII – no notified body is foreseen for PPWR packaging itself.	Where compliance of packaging with the requirements laid down in or pursuant to Articles 5 to 12 has been demonstrated in accordance with Article 38, the manufacturer shall draw up an EU declaration of conformity in accordance with Article 39.. Manufacturer keeps the DoC and technical documentation for 5 years (single-use packaging) or 10 years (reusable packaging) after placing on the market. This EU DoC is drawn up in, or translated into, the language(s) required by the Member State where the packaging is placed on the market or made available. The EU declaration of conformity shall be continuously updated.
1. No… (unique identification of the packaging)	–	Use a unique internal DoC number and unique packaging identification (e.g. SP-01-2025, material code, drawing number, GTIN list) so that the packaging covered by this DoC can be traced.
2. Name and address of the manufacturer and, where applicable, the manufacturer’s authorised representative	–	The legal entity that is the manufacturer within the meaning of Article 3(1)(13) of Regulation (EU) 2025/40 is responsible for drawing up this EU Declaration of Conformity in accordance with Article 39 and for signing it in line with the Annex VIII model structure. An authorised representative should be included only where applicable, i.e. where appointed by written mandate (Articles 3(1)(19) and 17(1))
3. Statement that the declaration is issued under the sole responsibility of the manufacturer	–	Recommended wording: “This EU Declaration of Conformity is issued under the sole responsibility of the manufacturer identified in point 2.” (consistent with Annex VIII style used in EU product legislation).
4. Object of the declaration (identification of the packaging allowing traceability) – description of the packaging	–	Short functional description + main materials/components (e.g. “sales packaging type SP-01 - 1 L PET bottle with HDPE tethered closure and PP label; traceability via SP-01-2025 and GTIN list”). Here you describe one packaging type; detailed BoM and drawings sit in the technical file.
5. Statement that the object of the declaration is in conformity with the relevant Union harmonisation legislation	–	Must at least reference Regulation (EU) 2025/40 on packaging and packaging waste. If the same DoC also covers other Union acts (e.g. Reg. (EC) 1935/2004 for food contact), list them here.The fulfilment of the requirements laid down in or pursuant to Articles 5 to 12 of Regulation (EU) 2025/40 has been demonstrated
6. References to harmonised standards / common specifications / other technical specifications used	–	Examples: EN 13428 (prevention/minimisation), EN 13430 (recyclability), EN 13429 (reuse), plus internal test methods and supplier specifications. Update when CEN or the Commission publish new PPWR-related standards or common specifications.
7. Where applicable, the notified body … performed … and issued certificate(s)	Normally: “Not applicable - no notified body involved; conformity assessment carried out by internal production control in accordance with Annex VII PPWR.”	Only if another Union act for the same packaging requires a notified body (e.g. certain pressure or dangerous-goods transport packaging), record its name, address, identification number, type of intervention and certificate number/date here.
8. Additional information; signature	–	Place and date of issue; name, role and signature of the signatory; reference to the technical file ID (e.g. TF-SP-01) and where it is stored (DMS / system path).

Table 2

What	Notified body and certificate details (if applicable)*	Additional acts / expected next steps
Art. 5 Requirements for substances in packaging	–	Legal thresholds (food-contact packaging) apply from 12 Aug 2026 and include: 25 ppb any PFAS (targeted), 250 ppb sum PFAS (targeted), 50 ppm PFAS measured as total fluorine (with additional proof duty if total fluorine exceeds the threshold). Heavy metals sum limit ≤ 100 mg/kg in packaging or packaging components (Article 5(4)) and PFAS limits for food-contact packaging apply from the general application date of PPWR. Commission report on “substances of concern” in packaging is due by 31-Dec-2026 and PFAS provisions are to be reviewed by 12-Aug-2030; update the technical file and DoC if new restrictions are introduced. Compliance with Article 5(4)-(5) shall be demonstrated in the technical documentation drawn up in accordance with Annex VII.
Art. 6 Recyclable packaging	–	From 1-Jan-2030 or 24 months after the design-for-recycling delegated acts enter into force (whichever is later), packaging may only be placed on the market if it achieves recyclability performance grades A, B or C as defined in Annex II. From 2038 only grades A and B remain allowed; lower grades are phased out. Recyclability shall be demonstrated in the technical documentation using the design-forrecycling (D4R) criteria and recyclability performance grading framework established by the delegated acts to be adopted by 1 January 2028 (Article 6(4)) and the implementing acts to be adopted by 1 January 2030 (Article 6(5)). Packaging may not be placed on the market unless it meets the applicable recyclability grade requirements from the relevant dates set out in Article 6(3) (A/B/C from 2030/24 months, and A/B from 2038)
Art. 7 Minimum recycled content in plastic packaging	–	By 31 December 2026, the Commission shall adopt implementing acts establishing the methodology for calculation and verification of recycled content and the format for technical documentation (Article 7(8)). The minimum recycled-content requirements apply by 1 January 2030 or 3 years from the date of entry into force of that implementing act, whichever is later (Article 7(1)). The calculation and verification must comply with the implementing act by 1 January 2029 or 24 months from the date of entry into force of that implementing act, whichever is later (Article 7(11)).
Art. 8 Biobased feedstock in plastic packaging	–	Article 8 sets a Commission review (by 12 February 2028) on biobased plastic packaging and provides that the Commission may, where appropriate, present a legislative proposal to (a) set sustainability requirements, (b) set targets to increase use, (c) potentially introduce a future possibility to meet Article 7(1)–(2) targets using biobased feedstock only in the specific scenario described in Article 8(2)(c), and (d) amend the biobased plastic definition if appropriate.
Art. 9 Compostable plastics (components)	–	By way of derogation from Article 6(1), by 12 February 2028, where packaging referred to in Article 3(1), point (1)(f) (i.e. a permeable tea, coffee or other beverage bag, or a soft after-use system single-serve unit used and disposed of together with the product) and sticky labels affixed to fruit and vegetables are placed on the market, they shall be compatible with the standard for composting in industrially controlled conditions in bio-waste treatment facilities and shall be compatible, where required by Member States, with the home-composting standards referred to in Article 9(6). Member States may require, under the conditions in Article 9(2), that additional packaging is compostable (including packaging referred to in Article 3(1), point (1)(g) composed of material other than metal, and very lightweight/lightweight carrier bags, and packaging already required to be compostable nationally before the application date). By 12 February 2028, packaging other than that referred to in Article 9(1) and (2) shall be designed for material recycling in accordance with Article 6 without affecting other waste streams. Compliance with Article 9(1)-(3) shall be demonstrated in the technical information in Annex VII. By 12 February 2026, the Commission shall request European standardisation organisations to prepare or update harmonised standards for compostable packaging and home compostability for the packaging referred to in Article 9(1); once cited, use them in the technical documentation where applicable.
Art. 10 Packaging minimisation	–	Art. 10(2) (from 12-Aug-2026): “Packaging that does not meet the Annex IV performance criteria, or that has features aimed only at increasing perceived volume (e.g., double walls, false bottoms, unnecessary layers), shall not be placed on the market, unless an Article 10(2) exception applies (IPR/GI). Art. 10(1) (by 1-Jan-2030): “By 1 January 2030, packaging weight and volume must be reduced to the minimum necessary to ensure its functionality. Evidence: Compliance with Article 10(1) and 10(2) must be substantiated in the Annex VII technical documentation
Art. 11 Reusable packaging	–	Packaging is considered reusable where it meets the Article 11(1) conditions, packaging placed on the market and presented as reusable must meet the Article 11(1) conditions (designed for multiple re-use/rotations, meets health/safety/hygiene requirements, can be emptied/refilled without loss of function, can be reconditioned in line with Annex VI Part B, allows labelling/traceability information, and meets recyclability requirements under Article 6). The Commission must adopt a delegated act by 12 February 2027 establishing a minimum number of rotations for common reusable formats. Compliance with Article 11(1) must be demonstrated in the Annex VII technical information.
Art. 12 Labelling of packaging	–	Most new labelling duties (material identification symbols, sorting instructions and some digital labelling) must be applied from 12-Aug-2028 or 24 months after the Commission’s implementing acts on labelling take effect, whichever is later. The Commission must also establish, by 1-Jan-2030, a method for providing digital information on substances of concern. Artwork and the technical file for each packaging type must be updated once these acts are in place.
Reference to main Union act	–	Regulation (EU) 2025/40 on packaging and packaging waste – main Union harmonisation legislation referenced in point 5 of the DoC.
Examples of relevant standards (to be checked against OJEU listing)	–	EN 13430 - Packaging - Requirements for packaging recoverable by material recycling; EN 13428 - Packaging - Requirements specific to manufacturing and composition - Prevention by source reduction; EN 13429 - Packaging - Re-use. Use only once updated and cited as harmonised standards under Regulation (EU) 2025/40.

*Where applicable, the notified body … (name, address, number) … performed … (description of intervention) … and issued the certificate(s): … (details, including the date of the certificate(s), and, where appropriate, information on the duration and conditions of validity).

Signature

Signed for and on behalf of (company):
Place and date of issue:
Name and function of signatory:
Signature:

Disclaimer

Detailed Assessment

Key fields

Field	Value
Main document for technical documentation
Packaging type / DoC ID (same as in DoC point 1)
Packaging unit (sales / grouped / transport / other)
Short description of packaging (materials, format, volume, use)
Manufacturer - name and full address
Authorised representative (if applicable) - name and full address
Intended use and product category (e.g. beverage, food, non-food, dangerous goods)
List of components (e.g. bottle, closure, label, film, tray, slip sheet, pallet, straps)
References to drawings / BoM / specifications
Other Union acts applied (food-contact, dangerous goods, medical, etc.)
List of standards / technical specifications used (e.g. EN 13428, EN 13429, EN 13430, EN 13432)
Summary of tests, calculations and assessments carried out for Articles 5-12
Risk assessment of non-conformity with PPWR (reference to FMEA / risk log)
Link / ID of the technical file in document management system

Section filter

Checks

Section	Requirement / check	Applies? (Yes/No/NA)	Packaging-level result / data	Component 1	Component 2	Component 3	Component 4	Evidence / reference (test report, supplier DoC, certificate)
General	DoC exists for this packaging type and matches the identification used here (DoC number, version, date)
General	Technical documentation compiled in accordance with Annex VII (internal production control - Module A)
General	All relevant Union acts and standards applied are listed and understood
General	Design, drawings, BoM and specifications for all components are up to date and included in the technical file
General	Risk assessment of non-conformity with Articles 5-12 is available and up to date
Art. 5 Substances of Concern	Sum of lead, cadmium, mercury and hexavalent chromium in each component ≤ 100 mg/kg (0.01 %)
Art. 5 Substances of Concern	Any intentionally added lead, cadmium, mercury or hexavalent chromium?
Art. 5 PFAS scope	Packaging (or part of it) is in contact with food (PFAS requirements applicable)
Art. 5 PFAS scope (a)	For food-contact parts: each individual PFAS concentration below the applicable limit value
Art. 5 PFAS scope (b)	For food-contact parts: sum of PFAS below the applicable limit value
Art. 5 PFAS scope (c)	For food-contact parts: total PFAS (measured via total fluorine) below the applicable limit; if total F above threshold, breakdown between PFAS and non-PFAS documented
Art. 5 Inbound control	Inbound control procedure in place for substances covered by Art. 5 (e.g. supplier approvals, CoA checks, sampling)
Art. 5 Inbound control	Latest inbound control results confirm compliance with Art. 5 limits for all relevant components
Art. 6 Recyclability scope	Packaging placed on the market is subject to Article 6 recyclability requirements unless it falls under a specific exemption/derogation (document the legal basis where applicable)
Art. 6 Exemptions	Packaging falls under any recyclability exemptions (e.g. certain medicinal / medical / infant / dangerous-goods packaging)
Art. 6 Design for recycling	Design-for-recycling assessment carried out for the whole packaging unit in line with criteria of delegated acts and Annex II. Applies from the relevant dates and per criteria/methodology set by the delegated and implementing acts under Article 6
Art. 6 Minimum grade	From the relevant date: packaging reaches at least the minimum recyclability performance grade required. Applies from the relevant dates and per criteria/methodology set by the delegated and implementing acts under Article 6
Art. 6 Recycled at scale	Once “recycled at scale” criteria apply: packaging meets minimum recycling-at-scale thresholds for its category. Applies from the relevant dates and per criteria/methodology set by the delegated and implementing acts under Article 6
Art. 7 Plastic scope	Packaging contains a plastic part (identify each plastic part/component) and determine whether it falls within an Annex II category for minimum recycled-content requirements, or within an Article 7 exemption (if applicable).
Art. 7 Exceptions	Any plastic components fall under exceptions in Art. 7 (e.g. certain medical or infant-food packaging, dangerous-goods transport packaging, etc.)
Art. 7 Category	For in-scope components: category as per Annex II (contact-sensitive PET; other contact-sensitive plastic; single-use plastic beverage bottle; other plastic packaging)
Art. 7 Required % 2030	Required minimum recycled content (%) for 2030 according to Annex II for each component/category
Art. 7 Required % 2040	Required minimum recycled content (%) for 2040 according to Annex II for each component/category
Art. 7 Actual %	Actual recycled content (%) for each plastic component, calculated as average per manufacturing plant, packaging type and format, per year
Art. 7 Compliance	For each plastic component and for the packaging as a whole: required minimum recycled-content percentage met for 2030 (and, when applicable, 2040)
Art. 8 Bio-based scope	Any bio-based plastic used in components (plastic from biomass / organic waste / by-products)
Art. 8 Share Bio-Based	If yes: share of bio-based feedstock in each component (%)
Art. 8 Substitution	Record biobased content (%, evidence) for monitoring. No substitution against Article 7 targets is claimed under current PPWR text. Reassess only if a future legislative amendment following the Article 8 review enters into force
Art. 9 Compostable scope	Any components belong to packaging types that must be compostable (e.g. certain tea/coffee bags, soft single-serve units, sticky labels for fruit/vegetables, very lightweight carrier bags, or packaging required by national law to be compostable)
Art. 9 industrial composting	For components that must be industrially compostable: compliance with relevant composting standard(s) (e.g. EN 13432 or successor)
Art. 9 Systems	In each Member State where packaging is marketed, appropriate bio-waste collection and treatment systems exist so that compostable packaging enters the bio-waste stream
Art. 9 Other components	Components that are not required to be compostable are designed for material recycling and do not impair recyclability of other waste streams
Art. 10 Minimisation: basic design	Packaging weight and volume reduced to the minimum necessary for required functions (product protection, safety, hygiene, consumer information, handling, logistics). Applies by 1 Jan 2030 (Art. 10(1))
Art. 10 No decorative volume	Packaging does not contain components whose main purpose is to increase perceived volume (false bottoms, double walls, unnecessary layers), except where justified by specific legal exemptions. Applies from 12 Aug 2026 (Art. 10(2))
Art. 10 IPR & GI	If design / shape is protected by design right, trademark or geographical indication, check that protection existed before PPWR and record justification
Art. 10 Future method	When harmonised minimisation methodology is available: packaging meets quantitative criteria and is documented accordingly
Art. 11 reuse scope	Packaging is marketed as reusable (according to PPWR definition)
Art. 11 Design for reuse	If reusable: packaging designed and manufactured to withstand multiple trips/rotations without loss of performance, safety or hygiene
Art. 11 Reuse system	Where packaging is marketed as reusable, confirm practical arrangements for return/collection and reconditioning exist (contracts/SOPs), to support consistent compliance with the Article 11(1) performance conditions
Art. 11 Rotations	When minimum numbers of rotations are defined by delegated act: packaging and system designed to meet or exceed required number of rotations
Art. 12 Labelling scope	Packaging falls under any PPWR labelling exemptions (e.g. certain medical / veterinary / medicinal packs where extra labelling is not possible or would compromise safety)
Art. 12 Material ID label	Material identification and sorting information applied as required (physical and/or digital)
Art. 12 Compostable label	For compostable components: correct compostability marking and instructions applied, consistent with waste-collection systems
Art. 12 Recycled content info	Any voluntary recycled-content claims on pack are consistent with Article 7 calculations and do not mislead
Art. 12 Overall labelling	Final check: labelling complies with PPWR and does not conflict with labelling required under other Union acts (food information, CLP, medicinal, medical device, etc.)
Art. 14 Environmental claims: scope	Packaging bears any explicit or implicit environmental claims or labels (e.g. “climate neutral”, “eco-friendly”, “recyclable”, “plastic free”, logos, self-declared labels)
Art. 14 Environmental claims: evidence	For each environmental claim, substantiation is available and kept in the technical file (studies, calculations, LCA, recognised standards); claims are not misleading and are consistent with PPWR and other EU rules
Closing	Reference to EU Declaration of Conformity number and version for this packaging type
Closing	Additional information relevant to technical documentation (e.g. derogations, national authority decisions)
Closing	Responsible person who compiled this technical documentation (name, function, company, contact)
Closing	Date of latest update of this technical documentation sheet
Disclaimer
The information in this document reflects the author’s best knowledge and experience at the time of writing. It is provided “as is,” without any warranty or representation - express or implied - regarding its accuracy, completeness, or suitability for any purpose. No assurance is given that any statements, projections, or expectations described will occur, and nothing in this document should be understood as a promise or representation of future outcomes.
This document, and any related verbal communications, do not constitute legal advice. Responsibility for ensuring compliance with all applicable laws and regulations remains solely with the recipient. Because legal requirements and interpretations can vary depending on the facts and circumstances, this document is not a substitute for consultation with a qualified legal professional.
To the extent permitted by law, the author will not be liable for any loss or damage arising from the use of, or reliance on, the information in this document, except where such loss or damage results from the author’s gross negligence or intentional misconduct. Any decisions taken by the recipient are made at their own discretion and based on their own independent assessment.

EU DoC Flow

DoC Log

DoC

Table 1

Table 2

Signature

Detailed Assessment

Key fields

Checks

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