Who actually signs the packaging declaration of conformity?
If the brand on the label is yours, you are the manufacturer of the packaging under Regulation (EU) 2025/40 — not the glassworks. What suppliers must give you and what you must sign.
The common mistake
"My bottle supplier handles that." Almost always wrong. Article 3(13) defines the manufacturer as whoever designs or has packaging designed and markets it under their own name or trademark, regardless of who physically makes it. Article 21 confirms it: placing packaging on the market under your brand makes you the manufacturer.
The glassworks answers for the bottle as a component, the cork producer for the closure, the box maker for the carton. The EU declaration of conformity for the finished packaging — glass plus cork plus capsule plus labels plus carton — is signed by the legal representative of the brand owner, and kept for five years (ten if reusable).
What suppliers owe you
Article 16 obliges suppliers to provide the manufacturer with all information and documentation needed to demonstrate conformity: material composition, weights, heavy-metal statements (Pb + Cd + Hg + Cr(VI) ≤ 100 ppm), PFAS evidence for food-contact packaging. Their declarations go into your technical file as evidence. They feed your declaration; they don't replace it.
Since when, with what consequences
The obligation applies from 12 August 2026 with no sell-through for new placements. Penalties are national and being set; the Commission has told authorities to warn first. The faster risk is commercial: distributors (Art. 19) and marketplaces asking suppliers for the document.
Other guides: The PPWR micro-enterprise exemption: when it really appliesArticle 16 supplier request: a ready-to-use template
Data collection and document tooling. Not legal advice. The declaration is signed by the manufacturer's legal representative, who remains responsible for it.