EU Declaration of Conformity (Annex VIII)

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Quick path

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Overview

The EU Declaration of Conformity (Annex VIII) is the legally binding document that declares a packaging unit’s conformity with Regulation (EU) 2025/40 (PPWR, Art. 39). It exists per packaging unit — under Master data → Packaging units on the unit’s detail page, in the Declaration of Conformity section. Your role decides the path:

• Manufacturer (and Art. 21 cases: an importer/distributor placing on the market under its own brand or modifying the packaging) — generate the Declaration of Conformity themselves and sign it.
• Importer / authorised representative — collect, verify and retain the Declaration of Conformity issued by the manufacturer (Art. 18(7) / Art. 17(2)). The importer’s retention duty covers not just the Declaration of Conformity but also the Annex VII technical documentation — 5 years for single-use, 10 years for reusable packaging. The same period binds the manufacturer (Art. 15(3)) as well as the importer (Art. 18(7); Commission FAQ X.10). It is not sufficient for the supplier alone to hold these records.
• Distributor — no Declaration of Conformity duty (Art. 19). Collecting one is optional, as due-care evidence; the same upload feature is available for it.
• Supplier — issues no Declaration of Conformity of its own. For these units the card is headed Technical Documentation (Annex VII) and carries the note: “As a supplier you create the technical documentation (Annex VII) for your customers. You do not issue a Declaration of Conformity of your own.”
• Fulfilment service provider — no documentation duty. The card reads “This packaging unit’s role carries no documentation duty.” and offers no action; a document you uploaded yourself stays downloadable.

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What scope one declaration covers

Polygon One keeps the Declaration of Conformity per packaging unit — exactly the granularity the regulation requires:

• One declaration per packaging unit as a whole. For a unit made up of bottle, closure and label, one conformity assessment and one Declaration of Conformity are sufficient for the unit — but the declaration must list the individual components (Commission FAQ XV.5). There is no declaration per component.
• Different sizes may share one declaration where the packaged product is the same and the difference in size does not affect compliance with Art. 5–12 (FAQ XV.10). That is what the family Declaration of Conformity below is for.
• A blanket declaration covering the whole range should not be drafted. Where the packaged products differ, a manufacturer should not draft a single declaration for all packaging placed on the market (FAQ XV.10).

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The status at a glance

In the packaging units overview, a badge shows the state of the Declaration of Conformity per unit:

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Generating (manufacturer and Art. 21 cases)

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Readiness check

Before you can issue, all of the following conditions must be met. If one is not, the card shows the specific reason under “Cannot issue yet — resolve the following first:“:

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Where to enter the manufacturer’s name and address — and why

You maintain the manufacturer’s name and address once, centrally under Settings → PPWR (“Manufacturer legal name” and “Manufacturer address”); the address field offers an address search with suggestions. Every EU Declaration of Conformity must contain the manufacturer’s name and address per Annex VIII — the app carries the stored details into the manufacturer block of every issued declaration, and while they are missing, issuance stays blocked for all units. The same details feed the registration data (Annex IX Part A) of the EPR registration assistant. The issued declaration receives the status Issued and the provenance chip Generated. The PDF is generated from the frozen snapshot at any time via “Download PDF”, and contains the eight numbered points of the Annex VIII sample (unique identification of the packaging, name and address of the manufacturer, statement of responsibility, object, conformity with Union law, applied standards, notified body and the signature).

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Languages of the Declaration of Conformity

The language is mandatory, not optional. Under Art. 39(2) PPWR the EU Declaration of Conformity must be drawn up in, or translated into, the language(s) required by the Member State in which the packaging is placed on the market or made available — so that the market surveillance authority there can verify it on request (Commission FAQ XV.14). Polygon One generates the Declaration of Conformity in 22 official EU languages: Deutsch, English, Français, Español, Italiano, Nederlands, Български, Čeština, Dansk, Ελληνικά, Eesti, Suomi, Hrvatski, Magyar, Lietuvių, Latviešu, Polski, Português, Română, Slovenčina, Slovenščina and Svenska. That covers every EU-27 market — Ireland and Malta through English, which is an official language there too. Which languages a unit needs is derived from its target markets — the unit’s Market member states field (“Select the EU Member States where this packaging is placed on the market.”). Each selected member state contributes its official languages: Belgium contributes Dutch and French, Finland Finnish and Swedish, Luxembourg French and German. With no market recorded, German is used.

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Downloading

The “Download PDF” button is a split button:

• The left half downloads exactly what the unit needs. With one required language, the language is named in the button, e.g. “Download PDF (Français)”. With several, it reads “Download (3 languages, ZIP)” and delivers every required language in one ZIP archive.
• The right half (chevron, “Choose document language”) opens the full list of all 22 languages. The ones Art. 39(2) requires for this unit are marked required. Where there is more than one, the list also ends with “All required languages (ZIP)”.

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Collect, verify and retain (importer / authorised representative)

As an importer or authorised representative you do not generate the declaration yourself but upload the Declaration of Conformity received from the manufacturer and retain it. Distributor units are not subject to this duty (Art. 19), but they can use the same upload feature optionally as due-care evidence. Via “Upload collected Declaration of Conformity” you choose the file (PDF, PNG or JPEG, max. 10 MB) and optionally record the reference number, issue date and retention basis. Polygon One then checks the document automatically against an Annex VIII checklist; you approve the result so it counts as the unit’s Declaration of Conformity. The automatic check verifies:

• Is a Declaration of Conformity — the artifact is indeed a Declaration of Conformity
• Manufacturer name and address present
• Packaging matches this unit
• Signature present
• Issue date is plausible
• Components of the unit are listed — the declaration names the unit’s components (Commission FAQ XV.5); the names found are shown as “Named in the document: …”

The result counts as Verified only when all checks pass; otherwise Needs review. If AI verification is unavailable, the document is always put to a person for review — there is no silent approval. An approval you grant (Approved by you) is authoritative and is not overwritten automatically.

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When the producer does not deliver: substitute Declaration of Conformity

If, as an importer, you cannot obtain the producer’s Declaration of Conformity despite requesting it, you can issue a substitute declaration yourself as a fallback, to present to the authorities as evidence of your due diligence. Below the “Upload collected DoC” button the card then reads “No Declaration of Conformity from the producer is on file for this unit. You can issue a substitute declaration yourself as a fallback, to present to the authorities.”, with the button “Issue a substitute yourself”. The option appears only when all four conditions hold: the unit’s role is importer (authorised representatives and distributors do not have this path); there is no active Declaration of Conformity at all (even a supplier-uploaded declaration still In review blocks the substitute); all substance checks pass (components, heavy metals, PFAS, manufacturer name and address — only the “only a manufacturer can generate” condition is waived); and no collection attempt still deserves a chance (a submitted, not-yet-reviewed reply, or an open data request whose due date has not passed, blocks the substitute — an open request with no due date does not). “Issue a substitute yourself” first opens a confirmation (“I confirm that the producer’s Declaration of Conformity could not be obtained. … legal responsibility for the Art. 39 Declaration of Conformity remains with the producer.”); you then fill in the same signature dialog as for generation, headed “Issue a substitute Declaration of Conformity (fallback)”. The issued substitute stays permanently marked as one:

• In the overview the unit carries the badge Substitute instead of Issued, with the hint “Substitute Declaration of Conformity issued as a fallback — not the producer’s own document. Legal responsibility for the Art. 39 declaration remains with the producer.”
• On the card it carries the chip Substitute (fallback) and the note “Substitute Declaration of Conformity, issued as a fallback”.

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Family Declaration of Conformity: one declaration for several units

The same packaging in several sizes needs one conformity assessment and one declaration (Annex VII pt. 4; Commission FAQ XV.10). That is what the family Declaration of Conformity is for: a single signed document covering all selected units and naming each of them in the document. Under Master data → Packaging units, tick the units and click “Issue family DoC”. There must be at least two (“Select at least two units. For a single unit, issue the DoC on its detail page.”); the dialog names the upper limit, and select-all-matching is not available here. Polygon One then checks whether the units really do share one conformity assessment — if they do not, you get “These units do not share one conformity assessment”, naming which value differs on which unit. Finally you enter place, the signatory’s name and function, and the signature; these apply to the whole family, and the retention basis is derived from the units here too. These values must be identical across all members: Role · Placed under own brand · Modifies conformity · Micro-enterprise exception (Art. 21) · Packaging type · Target markets · Producer under EPR · Recyclability grade · Source of the recyclability grade · Reusable (Art. 3(6)) · Re-use system (Art. 26) · Bill of materials (components and quantities). What may — and should — differ is the name, internal reference, GTIN and dimensions. That is what makes it a family. In addition, every unit must pass the readiness check; otherwise you get “At least one selected unit does not yet meet the requirements for a Declaration of Conformity. Open that unit to see what is outstanding.”

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Versions and superseding

Every issuance or collection creates a new version. The previously active declaration is automatically set to Superseded; its frozen snapshot remains unchanged and stays downloadable.

• Generate new version — as a manufacturer with a passing readiness check.
• Withdraw — sets the active declaration to Withdrawn; a new one can be generated afterwards.
• Out of date — if the unit’s data changes after issuance, the card indicates this with “Declaration of Conformity out of date”. The signed document remains unchanged; issue a new version so it reflects the current data.

For a family declaration the card also names the cause, because it may sit on a different unit:

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When a component change makes declarations out of date

A component often sits in several units, so one change to it can put several Declarations of Conformity out of date at once. Polygon One says so before and after you save:

• Before, a note in the component form directly above Save reads: ”… units hold an issued declaration of conformity. Changing conformity-relevant fields marks it outdated.” It counts only units with an active declaration you issued yourself — a collected one is not counted.
• After, the success message names the state: ”… packaging units now hold an outdated declaration of conformity.” That is a running total: it counts every unit of this component that currently holds an outdated declaration, including the ones that already did.
• The Show outdated button beside it opens the list of all outdated units in your company, not just this component’s.

You can reach the same list at any time via the Declarations of Conformity out of date entry on the PPWR module’s start page.

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What changed since issuance

When you re-issue an out-of-date declaration, the dialog first shows the “What changed since this document was issued” card. It puts the signed document’s frozen snapshot beside today’s data, with the columns Component, Field, Before and Now:

• Components that have since been Removed from, or Newly added to, the bill of materials.
• Changed fields of the Annex VII details: material composition (name, materials, polymer, mass, supplier), heavy metals, PFAS and recycled content.

The card only shows component changes. Changes to the unit itself also make the declaration out of date — name, internal reference, GTIN, packaging type, packaging form, description, recyclability grade, re-use system and, from the second size onward, the size list — but they never appear as a row here. The manufacturer details never make a declaration out of date. Dimensions do not either — but only while the unit carries a single size; from the second size onward the whole size list (reference, name, GTIN and dimensions) is part of what the declaration rests on. When the table stays empty, the card says so explicitly — either “Nothing changed on this unit; the declaration is out of date because of …” (the cause sits on another unit of the family) or “Nothing changed on this unit — the declaration is out of date for another reason.”

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Bulk issuance

For many packaging units at once there is bulk issuance: sign once, issue a separate declaration for every eligible unit. (A shared document covering several units is the family DoC above.) In the packaging units table, select the units and click “Issue DoC”. The button says up front how many of them qualify — “Issue DoC (3 of 8 eligible)”; if none do, it is disabled. In the dialog you enter the place, Additional information (optional), the signatory’s name and function, and the signature for the whole batch (the retention basis is derived per unit) and start with “Issue DoC” again. Issuance runs in the background and progress is shown continuously (“3 of 8 issued, 5 skipped”). Units that fail the readiness check or already have a Declaration of Conformity are skipped with a reason — e.g. “already had a DoC”, “are not manufacturer units (DoC is collected, not issued)”, “are missing the manufacturer’s legal name or address”, “have no component data yet”, “are missing heavy-metals confirmation”, “are missing PFAS confirmation”.

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Re-issuing out-of-date declarations in bulk

If the selected units include out-of-date Declarations of Conformity, a second button appears beside the Issue DoC button (which itself reads ”… of … eligible”): “Re-issue DoC (3 of 8 outdated)”. In one pass it issues a new version for every out-of-date unit — again with one signature for the whole batch:

Sign once and issue a new version for every selected unit whose DoC is out of date. Units with an up-to-date DoC, units that fail the readiness checks and units covered by a family DoC are skipped.

A unit belonging to a family Declaration of Conformity is skipped here — its declaration covers several units and is renewed on the declaration itself, not per unit.