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 / 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.
Declaration of Conformity on the packaging unit detail page
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).
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).
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.
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 — you can also simply type the address free-form.Why these are required:
Every EU Declaration of Conformity must contain the manufacturer’s name and address per Annex VIII — the app automatically carries the stored details into the manufacturer block of every issued declaration. While they are missing, issuance stays blocked for all units (see the readiness check above).
The same details feed the registration data (Annex IX Part A) of the EPR registration assistant — so you only enter them in one place.
1
Start generation
Click “Generate Declaration of Conformity”.
2
Signatory details
Enter the Name of signatory and Function / position, and optionally the place.
3
Choose the retention basis
Select Single-use (5-year retention) or Reusable (10-year retention) — this starts the retention period.
4
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.
Drawing the signature for the Declaration of Conformity
5
Issue the declaration
With “Issue declaration” the EU Declaration of Conformity is signed under the manufacturer’s sole responsibility, the retention period is started, and an immutable data snapshot is frozen.
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”.
The Declaration of Conformity PDF is generated in German and English 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).
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 German and English today and flags units destined for markets that require another language; the app does not perform the translation itself.
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.
1
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.
2
Wait for the automatic check
Polygon One checks the document automatically against an Annex VIII checklist.
Collected Declaration of Conformity with the automatic check
3
Approve
Review the result and approve the document so it counts as the unit’s Declaration of Conformity.
The automatic check verifies:
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
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.
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.
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 many packaging units at once there is bulk issuance: sign once, issue for every eligible unit.
Issuing Declarations of Conformity for several units at once
1
Select units
In the packaging units table, select the units and open “Issue Declarations of Conformity”.
2
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.
3
Issue
Start with “Issue DoC”. Progress is shown continuously (“{done} of {total} issued, {skipped} 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”, “not manufacturer units”, “missing manufacturer’s legal name or address”, “no component data yet”, “missing heavy-metals or PFAS confirmation”. An unverified declaration is never issued.
Technical Documentation (Annex VII)
The Annex VII documentation that the Declaration of Conformity relies on.
