When can two packaging units share the same Declaration of Conformity?

This article explains how to determine whether two packaging units count as the same packaging type under PPWR - and therefore whether they can share a single Declaration of Conformity (DoC), or whether each needs its own.

This is relevant at Step 3 (Add packaging types) and Step 5 (Sign the DoC) of the PPWR compliance workflow in Coolset.

The core rule: one DoC per packaging type

Under PPWR, every packaging type placed on the EU market requires its own Declaration of Conformity. A DoC is issued per packaging type - not per SKU, not per size variant, and not per product line.

Two packaging units are the same type - and can share one DoC - only if they share all three of the following:

1. The same material composition - the same materials in the same configuration

2. The same packaged product - they are used for the same product

3. The same compliance outcome - they pass or fail the same PPWR requirements in the same way

If any one of these three differs, you have a separate packaging type and need a separate DoC.

What counts as a difference?

1. Different material composition → separate DoC

Material composition covers what the packaging is made of and how those materials are combined. If any component changes - the base material, a secondary material, or the proportion of recycled vs. virgin content - you have a different packaging type.

Size alone does not create a new type if everything else is the same. A 500 ml and a 750 ml PET bottle made from the same resin and used for the same product are one packaging type.

Switching from virgin to recycled material does create a new type. PET and rPET have different compliance profiles - including potentially different PFAS and heavy metal results - so they must be assessed and documented separately.

2. Different packaged product → separate DoC

The DoC covers a specific packaging unit used for a specific product. If the same physical packaging is used for two distinct products - for example, the same glass jar used for both jam and honey - those are two separate packaging types, each requiring its own DoC.

3. Different compliance outcome → separate DoC

Even if two packaging units look physically identical and are used for the same product, they need separate DoCs if they produce different compliance outcomes - for example, if one passes the PFAS limit and the other does not, or if a change in formulation affects the heavy metals assessment.

In practice, this situation is less common than differences in material composition. But it can arise when suppliers change production inputs without changing the packaging's outward appearance.

Practical decision guide

Before deciding whether two packaging units can share a DoC, ask:

1. Are the materials identical? Same base materials, same secondary components (e.g. lid type), same recycled/virgin ratio?

2. Is the packaged product the same? If the packaging is used for two different products, each needs its own DoC.

3. Is the compliance outcome the same? Would both units pass (or fail) the same PPWR requirements in the same way?

If the answer to all three is yes → one packaging type, one DoC. If the answer to any is no → separate packaging type, separate DoC.

In Coolset: how this affects your packaging types

When you add packaging types in Coolset (Step 3), each entry you create corresponds to one packaging type - and will eventually require one DoC signature (Step 5).

• If you sell a product in two sizes using the same material and resin, add it once as a single packaging type.

• If you have two versions of a container with different materials (e.g. PET vs. rPET, metal lid vs. plastic lid), add them as separate packaging types.

• If the same packaging is used across multiple SKUs of the same product, add it once - you do not need one entry per SKU.

Getting this right at Step 3 avoids duplicating compliance work later and ensures your DoCs accurately reflect the packaging you place on the market.

What to do next

Once you have mapped your packaging types correctly, the next step is to send supplier requests to collect the technical data - test reports, material specifications, and substance compliance evidence - needed to complete the conformity assessment and sign the DoC.

→ See: How to send a supplier data request → See: What is the Declaration of Conformity?

Frequently asked questions

1. My packaging comes in two sizes. Do I need two DoCs? Not if the two sizes share the same material composition, the same packaged product, and the same compliance outcome. A 500 ml and 750 ml bottle made from the same PET resin, used for the same product, are one packaging type. Size alone does not create a new type.

2. We recently switched from virgin PET to rPET for some of our bottles. Can they share a DoC with the old version? No. PET and rPET are different materials and may have different compliance outcomes - particularly under the PFAS and heavy metals requirements. They must be treated as separate packaging types with separate DoCs.

3. We use the same glass jar for our jam range and our honey range. Is that one DoC or two? Two. The packaged product differs, so these are separate packaging types. Each needs its own DoC.

4. My supplier says they'll issue one DoC to cover all packaging they supply to us. Is that allowed? Only if all of the packaging covered by that DoC is genuinely the same packaging type - same materials, same products, same compliance outcome. If your supplier is grouping different packaging types under one DoC, that is not compliant. Each distinct type needs its own document. Note also that if your brand appears on the packaging, you are the manufacturer under Art. 21 and must issue the DoC yourself, not rely on your supplier.

5. What happens if I get the scoping wrong and combine two separate types into one DoC? The DoC would not accurately represent the packaging it covers, which creates a compliance risk. If authorities request your technical documentation within 10 days and the DoC does not match the actual packaging, you could be found in breach. It's worth taking the time to scope your packaging types carefully before signing.