Declaration of conformity and technical file
The conformity documentation every packaging placed on the market has had to carry since August 2026.
- What it is
- Conformity assessment, technical documentation and the EU declaration of conformity.
- Who holds it
- The manufacturer. It is not transferred to your EPR representative.
- Retention
- Five years for single-use packaging, ten for reusable
- Fixed fee
- SEK 29,250 per packaging family
Since 12 August 2026, packaging placed on the EU market must have undergone a conformity assessment, be covered by an EU declaration of conformity, and have technical documentation kept on file. There is no grace period for existing stock formats.
This is a separate obligation from extended producer responsibility, and it stays with the manufacturer. Appointing an authorised representative for EPR does not move it. The two are regularly confused, usually by companies who believe that appointing a representative has covered everything.
What we do
- Establish which packaging families need separate documentation
- Review your technical file against what the regulation requires it to contain
- Draft or review the EU declaration of conformity
- Check that identification and contact details carried on the packaging are correct
- Set up a retention structure that will still make sense when an authority asks in 2031
The record you create for a 2026 declaration is the same record an auditor opens years later. Building it properly once is considerably cheaper than reconstructing it under an enforcement deadline.
What the fixed fee covers. One review or first draft per packaging family and one round of comments. Further rounds, revised versions after changes to the packaging or its materials, and additional families are charged on a time basis.