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 Packaging → 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 / distributor — collect, verify and retain the Declaration of Conformity issued by the manufacturer.
The status at a glance
In the packaging units overview, a badge shows the state of the Declaration of Conformity per unit:| Badge | Meaning |
|---|---|
| Ready | Issuable now as a manufacturer — all checks pass. |
| Blocked | Manufacturer, but the Art. 5 check is not yet satisfied (reasons in the tooltip). |
| In review | A collected declaration exists and is awaiting the Annex VIII check. |
| Issued | A verified, active Declaration of Conformity exists. |
| Collect | Non-manufacturer — the Declaration of Conformity is collected from the manufacturer. |
Generating (manufacturer and Art. 21 cases)
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:“:| Block | Resolution |
|---|---|
| Only a manufacturer (or own-brand importer/distributor) can generate | Check the unit’s role/brand. |
| Add at least one component | Record the component(s). |
| Provide heavy-metals data ≤ 100 mg/kg per component | Record values + basis of claim. |
| Provide a PFAS attestation per food-contact component | Record PFAS evidence. |
| Add the manufacturer’s legal name and address | Enter it under Settings → PPWR. |
Duties that only become outstanding for 2028 (recyclability) and 2030 (recycled content) do not block issuance — Polygon One never marks a future duty as outstanding. Even in the Blocked state, the technical documentation (Annex VII) can still be generated.
Issue and sign
Choose the retention basis
Select Single-use (5-year retention) or Reusable (10-year retention) — this starts the retention period.
Add the signature
Draw the signature directly in the field or upload an image (tabs Draw / Upload). A drawn electronic signature is legally sufficient for an Annex VIII declaration.
Collect, verify and retain (importer / distributor)
As an importer or distributor you do not generate the declaration yourself but upload the Declaration of Conformity received from the manufacturer.Upload the collected declaration
Click “Upload collected Declaration of Conformity” and choose the file (PDF, PNG or JPEG, max. 10 MB). Optionally record the reference number, issue date and retention basis.
Wait for the automatic check
Polygon One checks the document automatically against an Annex VIII checklist.
- Is a Declaration of Conformity — the artifact is indeed a DoC
- Manufacturer name and address present
- Packaging matches this unit
- Signature present
- Issue date is plausible
A collected declaration first lands in the In review state and counts as Issued only after verification. If a supplier has already provided a Declaration of Conformity, you can adopt it directly via “Use as the unit’s Declaration of Conformity” without re-uploading.
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.
Bulk issuance
For many packaging units at once there is bulk issuance: sign once, issue for every eligible unit.
Select units
In the packaging units table, select the units and open “Issue Declarations of Conformity”.
Sign once
Enter the retention basis, place, optional additional information, the signatory’s name and function, and the signature — these apply to the whole batch.
Technical Documentation (Annex VII)
The Annex VII documentation that the Declaration of Conformity relies on.