Under Regulation (EU) 2025/40 (PPWR), every packaging type needs its own conformity assessment and EU Declaration of Conformity (DoC) before placement, supported by harmonised standards. This paper maps the Annex VIII declaration contents and the EN 13427–13430 standards family so a nickel-metal hydride (NiMH) exporter can build defensible packaging files for every box, tray and film.
Article 39 and Annex VIII set an internal-control route analogous to Module A in the battery regulation: the manufacturer (or the operator placing packaging on the market) compiles technical documentation demonstrating each applicable requirement, performs the assessment, draws up and signs the EU Declaration of Conformity, and affixes the required markings. Unlike the old directive regime, from 12 August 2026 the declaration is a market-access document — importers must verify it exists, authorities may demand it, and marketplaces treat its absence as a blocker. Each packaging type requires its own assessment and declaration; a single umbrella certificate covering "our packaging" is non-conforming.
The European standards family translates the essential requirements into auditable methodology: EN 13427 is the framework standard listing the other standards and the overall requirements for packaging use; EN 13428 covers source reduction — minimising weight, volume and hazardous substances with a documented assessment; EN 13429 covers reusable packaging and the criteria for reuse systems; EN 13430 covers material recycling, demonstrating that the packaging can be recycled at scale. Companion standards address energy recovery (EN 13431), composting (EN 13432), material identification (EN 1043 series) and the heavy-metal determination methods (aligned to the IEC/EN 62321 and CEN test routes). Citing these standards in the DoC creates a presumption of conformity — the strongest legal position available.
A packaging DoC contains at least: a unique identifier for the packaging type and its batch/traceability reference; name and address of the manufacturer and any authorised representative; a sole-responsibility statement; a description of the packaging (materials, levels, dimensions, weight); references to the applicable Union legislation (2025/40, plus REACH where relevant); references to harmonised standards (the EN 13427 family) or other technical specifications applied; identification and number of any conformity-assessment body involved; supplementary technical information; and place, date, name and signature of the authorised signatory. Keep it available for ten years and translate it into the language required by each destination member state.
Behind every DoC sits a technical file: packaging specification drawings and material composition; supplier material declarations; heavy-metal test reports (Pb/Cd/Hg/CrVI summed ≤100 mg/kg); the EN 13428 source-reduction assessment showing weight/volume minimisation reasoning; the EN 13430 recyclability assessment against design-for-recycling criteria; REACH SVHC screening and SCIP reference where triggered; the Article 15(5) traceability code specification; and production-control records ensuring series consistency. The matrix above illustrates that every evidence type repeats at each of the three packaging levels — primary, secondary and tertiary — because each declaration stands alone even when the documents share a common folder.
Efficient programs build a packaging family matrix rather than 30 isolated files: group packaging by material and process family (corrugated cartons, PET blisters, PE films, paper labels), hold one master technical file per family with test reports and assessments, then issue per-type declarations referencing the family file plus the specific drawings and batch codes. A material or supplier change updates the family file and re-issues affected declarations; the change log demonstrates continuous conformity. This mirrors the battery technical-file discipline and lets one compliance manager maintain hundreds of SKUs.
Weijiang Power provides PPWR Declarations of Conformity per packaging type for every NiMH shipment, backed by EN 13427/13428/13430 assessments, IEC 62321 heavy-metal reports, source-reduction and recyclability files and batch traceability records. Send your packaging list and we will return a family matrix with a separate declaration for each primary, secondary and tertiary packaging type, ready for your importer's 12 August 2026 file.
