PPWR for fashion: the packaging around a garment has a manufacturer, and a declaration.
Regulation (EU) 2025/40 on packaging applies across the Union from 12 August 2026. Before a polybag, a hangtag or a shoe box is placed on the market, its manufacturer assesses its conformity and draws up an EU declaration of conformity. When the packaging is made to your design and carries your name, that manufacturer is your brand: the declaration is yours to sign.
What the regulation asks
Regulation (EU) 2025/40 on packaging and packaging waste repeals Directive 94/62/EC and applies from 12 August 2026. For a fashion brand it reaches the polybag around a shirt, the tissue paper in a box, the mailer bag of an online order and the carton it travels in.
Before packaging is placed on the market, its manufacturer carries out the conformity assessment set by Article 38. In the ordinary case this is internal production control under Annex VII: the manufacturer checks its own packaging, and no notified body, an external inspection body, is involved. The manufacturer then draws up the technical documentation and, where conformity is demonstrated, the EU declaration of conformity of Articles 15 and 39.
The declaration states that the packaging is in conformity with Articles 5 to 12 of the regulation. It follows a fixed model, Annex VIII, and is kept continuously updated. The declaration and the technical documentation are kept for five years after the packaging is placed on the market, and for ten years when the packaging is reusable.
Who the manufacturer is
The answer decides who signs. A fashion brand usually ships two kinds of packaging, and the answer is different for each.
Packaging made to your design and sold under your name. A printed box, a branded hangtag, a dust bag with your logo. Here the brand is the manufacturer, and the declaration is the brand's own.
Packaging bought as it is from a converter's catalogue. A standard polybag, a plain shipping carton. Here the declaration that counts is the converter's, and it is the document to ask for.
The data a declaration needs
Annex VIII sets out what the declaration contains. Most of it is data a brand has to gather before it can sign.
- Identification. A unique identification of the packaging and a number for the declaration.
- The manufacturer. Its name and address, and those of its authorised representative where there is one.
- The object. A description of the packaging that allows it to be traced.
- The standards. The harmonised standards, common specifications or other technical specifications against which conformity is declared.
- The notified body, where one was involved, with its name, address and number.
- The signature. The place and date of issue, and the name and function of the person signing for the manufacturer.
In which language
Under Article 39(2) the declaration is drawn up in, or translated into, the language or languages required by the Member State where the packaging is placed or made available on the market. A brand selling in Italy, France and Germany may need the same declaration in three languages.
What the declaration is not
Packaging is not part of the textile passport. The data the European passport is expected to ask for apparel does not include it, and the declaration of conformity is a separate document with its own rules, its own signatory and its own retention period.
Packaging is recorded once, and the declaration is generated from it.
Stated once for the season
Each item is recorded with its type, material, mass, recyclability and recycled content, from closed lists built on the regulation's own categories. Items are set for a collection and corrected on a single product where it ships differently. Each one says whether you designed it or bought it as it is.
Generated with its gaps in plain sight
For the packaging you design, Tramaproof generates the brand's EU declaration of conformity on the Annex VIII model, in English, Italian, French, German or Spanish according to the markets you declare. A missing value is printed as «To complete», never left blank. Each generation has its own number and is dated by a third-party timestamp.
The converter's declaration, asked for and filed
For packaging bought as it is, Tramaproof sends the converter a request for its own declaration and files the answer beside the brand's. The brand can also upload a declaration it already holds, and the file records who filed it.
Questions about PPWR and fashion packaging
Is a hangtag packaging under the PPWR?
Annex I of the regulation names tags and labels attached to a product among the items that are packaging, together with clothes hangers sold with a clothing item. A hangtag attached to a garment is therefore treated as packaging.
Who signs the declaration for a branded box a supplier produces?
The manufacturer, and for a box made to your design and sold under your name that is the brand. The supplier who produced it still holds the data on material and mass, which is what the brand needs to ask for.
From when is the declaration required?
Regulation (EU) 2025/40 applies from 12 August 2026. From that date the manufacturer carries out the conformity assessment and draws up the declaration before the packaging is placed on the market.
Does packaging appear on the Digital Product Passport?
No. The data expected for the textile passport does not include packaging, and in Tramaproof nothing about packaging reaches a published passport or a product's environmental footprint. The declaration is a document of its own.
In which languages does Tramaproof generate the declaration?
In the languages of the markets declared for the product, among English, Italian, French, German and Spanish, from the same data and under one number. For a market whose language is not among these, the English copy is generated and the screen names the language that is missing.