Quick summary: A practical guide to understanding who issues the Declaration of Conformity for transport packaging under PPWR, when responsibility shifts, and how to keep the right documentation audit-ready.
Transport packaging under PPWR — the boxes, wraps and pallets that move your goods rather than present them to shoppers has become one of the most misunderstood corners of the regulation. In plain terms, the Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40) assigns exactly one manufacturer per packaging item, and for standard transport packaging that manufacturer is almost always the company that designed and produced it not the business that fills the box.
That single distinction settles most of the questions teams keep asking: Who prepares the Declaration of Conformity (DoC)? Does every company using a cardboard box need its own DoC? Does adding a shipping label make me the manufacturer? What if the box carries my logo? This guide answers each one against the actual text of the regulation.
The manufacturer defined in Article 3(1)(13) as the party that designs or has packaging made and markets it under its own name or trademark. For standard, unbranded transport packaging (corrugated boxes, stretch wrap, pallets), that is the packaging producer, who issues one DoC under Article 39. Businesses that merely fill the box or add a courier label do not become the manufacturer. Responsibility shifts to you only if you place the packaging under your own brand, commission a custom design, or modify it in a way that affects compliance (the Article 21 “deemed manufacturer” rule) or if you import it from outside the EU.
Transport packaging under PPWR is packaging conceived to facilitate the handling and transport of goods protecting them in transit rather than presenting them at the point of sale. The regulation drops the old primary/secondary/tertiary language in favour of sales, grouped and transport packaging categories.
Typical transport packaging includes:
Because it never reaches the consumer as a sales unit, transport packaging carries lighter consumer-labelling duties than sales packaging. But it is still packaging: the sustainability requirements and the Declaration of Conformity obligation apply, and the responsible operator must remain identifiable.
The general rule is straightforward. If a company manufactures standard, unbranded transport packaging and places it on the market, it is the manufacturer under PPWR and is responsible for:
A crucial clarification from the Commission: the manufacturer is not necessarily the factory that physically produced the packaging. Where a brand owner has packaging made to its specification under its own name, the brand owner is the manufacturer and the converter is only the supplier. Either way, there is one manufacturer per packaging item and that is who issues the DoC for transport packaging under PPWR.
Simplify PPWR Compliance for Manufacturers
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The logic is practical: avoid duplicating compliance work that adds no value. Consider a packaging company that manufactures one million identical corrugated boxes and sells them to 500 customers.
If each of those 500 customers had to prepare its own Declaration of Conformity for the same standard box, the result would be:
PPWR avoids this by placing responsibility with the entity that designed and manufactured the packaging and controls its specification. Downstream users rely on and retain a copy of that single DoC. This is the core reason transport packaging under PPWR rarely requires the box-filler to issue anything of their own.
Six common situations, and where responsibility lands in each:
| Scenario | Manufacturer | Who issues the DoC |
|---|---|---|
| 1. Standard corrugated box (bought off-catalogue) | Packaging company | Packaging company |
| 2. Standard stretch wrap | Film manufacturer | Film manufacturer |
| 3. Standard wooden pallet | Pallet manufacturer | Pallet manufacturer |
| 4. Custom-branded box you design with your logo & spec | You (brand owner) | You |
| 5. Private-label packaging under another company’s trademark | Trademark owner | Trademark owner |
| 6. Transport packaging imported from outside the EU | Non-EU maker (verify) — or you, if own-brand / modified | You verify & retain; you issue if reclassified |
No. Adding a shipping label, courier label, barcode or warehouse sticker to a standard box does not make your company the manufacturer of that transport packaging.
The reason is simple: these additions do not alter the packaging’s design, material or function. You are using the packaging as supplied, not re-engineering it. The manufacturer remains the company that produced the standard box, and its DoC still stands. A logistics label is an operational marking, not an act of manufacture.

Responsibility for transport packaging under PPWR shifts to your business in a defined set of situations:
The unifying principle: it is design control and own-name placement not filling the box or labelling it that makes you the manufacturer.
Understand Your Role Under PPWR Before Compliance Begins
Read our Guide: PPWR Roles and Responsibilities Explained
Whether you issue the DoC or rely on a supplier’s, a compliant file for transport packaging under PPWR should include:
Market surveillance authorities can request technical documentation and expect it produced promptly so the file must be current, complete and retrievable, not scattered across inboxes.
Master Technical Documentation Under PPWR
Read our Guide: Technical Documentation Under PPWR: A Complete Guide
❌ Every company using a shipping box needs its own DoC.
✔️ Generally, the packaging manufacturer prepares the DoC for standard transport packaging; users retain a copy.
❌ Shipping labels count as branding.
✔️ Logistics labels do not change manufacturer responsibilities no design, material or function changes.
❌ Every customer must perform a conformity assessment.
✔️ Not for standard packaging supplied by a compliant manufacturer the assessment sits with the manufacturer.
The real workload in transport packaging under PPWR is not issuing one document it is keeping every DoC, specification and supplier declaration linked to the right packaging and retrievable when an authority asks. That is a data problem.
TraceX’s PPWR packaging data management platform is built to hold that record in one place, helping businesses:
| Spreadsheets & email | [TraceX packaging data management] |
|---|---|
| DoCs scattered across supplier inboxes | Every DoC linked to its packaging SKU |
| No link between batch and technical file | Batch-to-dossier traceability |
| Manual chasing of supplier declarations | Tracked supplier-declaration workflow |
| Slow, stressful response to audit requests | Audit-ready export on demand |
| Unclear who is the responsible manufacturer | Role and responsibility recorded per SKU |
PPWR is deliberately designed to avoid unnecessary duplication of compliance work. For standard transport packaging under PPWR, responsibility sits with the packaging manufacturer because they control the design and production and there is only ever one manufacturer per packaging item. Downstream users do not become manufacturers simply by filling the packaging or adding a shipping label. Responsibility shifts only through own-brand placement, custom design, modification affecting conformity, or importing. Understanding these distinctions and maintaining the right, linked documentation is what turns transport-packaging compliance from a scramble into a routine.
The manufacturer the party that designs or commissions the packaging and markets it under its own name or trademark (Art. 3(1)(13)). For standard transport packaging, that is the packaging producer.
The manufacturer draws up and signs one DoC per packaging item under Article 39, following the Annex VIII model. Downstream users retain a copy rather than issuing their own.
No. Shipping, courier or warehouse labels do not change the packaging’s design, material or function, so they do not transfer manufacturer responsibility.
It can. If you place packaging on the market under your own brand or commission a custom design to your specification, you are treated as the manufacturer under the Article 21 “deemed manufacturer” rule.
A Declaration of Conformity (Annex VIII), technical documentation (Annex VII), packaging specifications, material composition data, batch identification and any supplier declarations retained 5 years (single-use) or 10 years (reusable).
Yes. Importers must verify the manufacturer completed the conformity assessment and DoC, keep a copy on file, and produce technical documentation to authorities on request. Importing under your own brand makes you the manufacturer.
By keeping DoCs, specifications, batch records and supplier declarations linked in a single, audit-ready system rather than scattered files so any packaging item can be evidenced on request.