The Pro-K Industry Association, together with its member companies in the Storage and Transport Systems Division, has published a sample template for an EU Declaration of Conformity in accordance with the new EU Packaging and Packaging Waste Regulation (PPWR). The template helps companies comply with the PPWR’s extensive new documentation and verification requirements.

This statement is intended for manufacturers, producers, and distributors of reusable and transport packaging made of plastic and specifically addresses future requirements regarding recyclability, the use of recycled materials, reusability, material restrictions, and technical documentation. The draft is continuously reviewed by experts as part of the association’s work and adapted to regulatory developments.

With the PPWR, the European Union is introducing a comprehensive conformity regime for packaging for the first time. Starting August 12, 2026, companies will be required to maintain technical documentation and a formal EU declaration of conformity for numerous types of packaging. However, many specific requirements will not be defined until secondary European legislation is enacted. This is precisely where the industry currently sees a significant need for action.

A circular economy requires legal certainty

From Pro-K’s perspective, there is a risk that effective reusable plastic systems—such as pallets, crates, containers, or bottle crates—will be unnecessarily burdened by unclear or impractical regulations. “Manufacturers of reusable plastic containers are not laggards in this transformation—they are its pioneers,” emphasizes Jürgen Schultz, spokesperson for the Storage and Transport Systems Division at Pro-K. These systems already meet the core objectives of the PPWR today: high circulation rates, long service life, closed-loop material cycles, and a significant reduction in packaging waste. For years, numerous systems have been based on established return, pooling, and recycling structures.

At the same time, companies still lack key guidelines—such as those defining post-consumer recycled materials, calculating recycled content rates, verifying recyclability, or addressing material loops. “What is needed now are clear and practical guidelines from European secondary legislation. Companies need planning certainty, not regulatory chaos,” Schultz emphasizes. The industry is therefore calling on the German federal government and EU institutions to establish proportionate requirements for conformity assessment, documentation obligations, and labeling, so that proven reusable and circular systems are strengthened rather than burdened by additional bureaucracy.