Regulation (EU) 2025/40 · mandatory since 12 August 2026

Has your importer asked for conformity documents on your packaging?

It is happening more and more, and it is not a whim: the declaration has been mandatory since 12 August 2026 and without it, goods do not ship. We write to the glassworks, the closure maker and the label printer, collect the evidence, compile the technical file and the declaration. You sign and ship.

Check in 60 secondsSee what you get
What you receive · example · EU Declaration of Conformity · Annex VIII
Not sure it applies to you?

Five questions, 60 seconds. We tell you whether you are obligated and what is needed. Free, no sign-up.

Check in 60 seconds
Do you build or modify machinery? From 20 January 2027 your technical file changes too: we handle that as well.See the 2027 Check →
How easy it is

What you do, what we do.

You

  1. List your packaging: bottle, closure, capsule, labels, carton
  2. Name the supplier of each component
  3. Sign

We

  1. Check whether you are actually obligated and which exemption applies
  2. Write to your suppliers in their language, citing the legal duty
  3. Chase them until they answer
  4. Check the evidence against the regulation's limits
  5. Compile the technical file and the declaration, in every market language
  6. Archive everything for 5 years and answer authorities within 10 days
Inside Fascicolo

A register, not a dashboard.

Want to click around? Open the demo, no sign-up →

The register
01 · The register

Every packaging type on one line. A green square for each supplier who has answered. What's missing is obvious at a glance.

The file
02 · The file

Components, suppliers, evidence received, a timeline of every request and reminder. If something's missing, we tell you in one sentence.

03 · The declaration

The ten items of Annex VIII, each conformity line with its evidence reference. Print, sign, archived.

How it works

The document is one page. The work is everything behind it.

Inventory your packaging

Add each type and its components: bottle, closure, capsule, labels, carton. Link each to a supplier. Pick your markets.

We write to your suppliers

An Article 16 request in their language with a secure link. They answer in a form; we chase them.

Technical file and declaration

We assemble Annex VII, check it against the regulation's rules and produce Annex VIII in every market language, ready to sign.

What the regulation actually requires

One declarationper packaging type, not per company
Who signsthe brand owner, not the glassworks
Since12 August 2026, no sell-through period
Retention5 years (10 if reusable)
On requesttechnical file within 10 days
Micro exemption< 10 staff and ≤ €2m, only with same-state suppliers
Food contact · Art. 5

If your packaging touches the product, the limits already apply.

Since 12 August 2026 the substance limits apply too: lead, cadmium, mercury and hexavalent chromium together no higher than 100 mg/kg (Art. 5(4)) and, for food-contact packaging, the PFAS limits (Art. 5(5)). Knowing it is not enough: the evidence has to sit in the technical documentation, and your suppliers hold it.

Wine

Bottle, closure, capsule, seals: anything touching the wine is in scope. Synthetic closures and capsules are where suppliers answer slowest.

Olive oil

Tinplate tin, internal coating, pourer cap: the internal coating statement is the document that matters, and tinplate producers already hold it.

Preserves and honey

Twist-off caps with a seal: the critical component, and almost no supplier sends it unprompted. You have to ask, citing the article.

We send the supplier requests, in their language, citing Art. 16 which obliges them to answer. And we chase until they do.

Add-on for wineries · Reg. (EU) 2021/2117

Wine e-label.

Since December 2023 every wine placed on the EU market must carry an ingredient list and a nutrition declaration. The law allows these to move to an e-label: a QR opening a page with the ingredient list and the nutrition table. The energy value and allergens stay printed on the physical label: the QR lightens the bottle, it doesn't replace it.

The work isn't the QR

It's the data sheet: ingredients in descending order of ingoing weight, additives by functional category plus name or E number, energy calculated with the official coefficients from alcohol, sugars, glycerol and acids. You already have the figures in your certificate of analysis: we turn them into a correct declaration.

A page that respects the law

No advertising, no shop links, no cookies or tracking: the regulation forbids it and our pages don't do it. Only the required information, readable on a phone, in Italian and in your sales languages.

Addresses that never die

The QR printed on a bottle has to work for the whole life of the product. The pages are ours and stay live; change your label printer and nothing changes. With Custody, the update for each vintage is included.

Setup €190 per winery, up to 10 labels or vintages: values calculated from your certificate of analysis, ingredient list drafted, translations, print-ready QR codes. Updates and hosting included in Custody.See a sample e-label
Pricing · pilot

Less than a consultant. More than a template.

A €49 template doesn't email your glassworks. A €2,000 consultant doesn't scale to three labels.

For scale: €390 is less than one export order held at customs, less than a pallet of glass.

Start
€390
one-off · up to 5 types · +€60 per extra type
  • Inventory and role check
  • Supplier requests, sent and chased
  • Technical files and signable declarations
Producer
€890
one-off · up to 15 types
  • Everything in Start
  • Declarations in every market language
  • Delivery in three weeks from supplier data
  • Wine e-label: +€190 (up to 10 labels/vintages)
Custody
€24
per month
  • 5/10-year archive with versions
  • Updates for the 2028–2030 delegated acts
  • E-label update for every new vintage, permanent QR hosting and translations
  • New declarations at €40
  • Authority requests answered within 10 days
Invoice and bank transfer
Prefer a bank transfer against an invoice? That works: write to us and we send the invoice and IBAN within one working day. The plan activates when the transfer arrives.
Request an invoice

Prices exclude VAT. Laboratory testing, if a supplier can't evidence conformity, is quoted separately and beforehand.

Who is behind this

One person, in Gaiole in Chianti.

My name is Tom Riby. I'm English, I've lived in Chianti for twelve years and I work with local producers. Fascicolo is a new service, started in 2026: not a firm with twenty staff, one person with software tooling and a partner engineer for the machinery side. I say so upfront because it's what I would want to know before handing anyone a legal obligation.

The inventory is free and the demo is public: you pay only after seeing your own register. Full refund if you change your mind before the supplier requests go out. You sign the declaration, as the regulation requires: we prepare the documentation behind it.

Photo
Tom RibyBritish, 12 years in Tuscany, in Italian industryGaiole in Chianti (SI), Italyhello@fascicolo.euWrite to me
Questions

The real objections.

Selling into the EU from: UK · US · Switzerland · Australia · Canada
Guides in English →

My supplier already gives me a declaration.

It covers their component and their liability. If the product carries your brand, the declaration for the finished packaging is yours to sign. Supplier declarations are evidence in your file, not a substitute.

I'm outside the EU.

You are a third-country manufacturer: you need the file, a signed declaration and an EU-established authorised representative holding the documentation. Your EU importer must verify it and keep a copy.

Do I need a lab or a notified body?

The standard route is Module A (internal control). Heavy-metal and PFAS evidence normally comes from your material producers. If it's missing, we tell you what a test costs first.

What if I don't do it?

Packaging without a declaration may not be placed on the market. Penalties are national and being set; the Commission has told authorities to warn first. The immediate risk is commercial: customers and importers asking for documentation.

Is this legal advice?

No. Fascicolo collects data and prepares documents. Your legal representative signs and remains responsible.

Wine e-label: do I need a new QR for every vintage?

No. The QR and the address stay the same; what changes is the page content. If a new vintage has different ingredients or nutrition values we update the page, and the QR already printed keeps pointing to the correct label. With Custody, the update for each vintage is included.

What can the e-label NOT contain?

Nothing commercial: no advertising, offers, shop links or promotional content. The regulation also forbids collecting or tracking data about whoever opens the QR. Our e-label pages carry only the mandatory information, with no cookies and no analytics.

What happens to the e-label if I change supplier?

Nothing: the addresses stay live because they are ours, not a label printer's or an agency's. A page is never switched off; if a product leaves the market the page stays and says so. A QR printed on a bottle sold five years ago must still work, and it does.

Fixed quote in 24 hours

Tell us how many packaging types you have. You get a price, not a call.

Start with the check
PPWR Declaration of Conformity, done for you | Fascicolo