pro-K Association provides template for declaration of conformity

The template is intended to help companies fulfil their documentation and evidence requirements under the PPWR in a legally compliant and practical manner.


The template, published by the pro-K Industrieverband langlebige Kunststoffprodukte und Mehrwegsysteme (Industry Association for Durable Plastic Products and Reusable Systems) in collaboration with the Specialist Group for Storage and Transport Systems, is aimed at manufacturers, producers and distributors of reusable and transport packaging made of plastic, pro-K states. It is designed to facilitate preparation for the new requirements and takes particular account of future requirements regarding recyclability, the use of recycled materials, reusability, material restrictions and technical documentation. The model declaration of conformity is to be continuously reviewed by experts as part of the association’s work and adapted to regulatory developments, the statement continues. Manufacturers, producers and distributors of reusable and transport packaging made of plastic will be obliged to submit a declaration of conformity in accordance with the EU Packaging Regulation (PPWR) from 12 August 2026. As numerous specific requirements are only to be laid down in secondary European legislation, the industry believes there is currently a significant need for action. Among other things, definitions of post-consumer recycled materials, the calculation of recycled content targets, evidence of recyclability and regulations on circulation cycles are still lacking.
 
As Jürgen Schultz, spokesperson for the Storage and Transport Systems Section at pro-K, explains, existing systems already meet the key objectives of the PPWR today: high circulation rates, long service life, closed material cycles and a significant reduction in packaging waste. “What is needed now are clear and workable guidelines from European secondary legislation, and quickly. Companies need planning certainty rather than regulatory chaos,” emphasises Schultz. The industry is therefore calling on the German government and the EU institutions to introduce proportionate requirements for conformity assessment, documentation obligations and labelling, so that tried-and-tested reusable and circular systems are strengthened rather than burdened by additional bureaucracy.
 
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