Creating EU Declarations of Conformity: What Can Be Automated—and What Cannot

One declaration, five data sources

An EU declaration of conformity is a single document once it is finished. Before it can be reviewed and signed, however, the information often comes from several sources: product master data, an order, a technical data sheet, supplier documents, messages and ERP exports.

The problem is rarely typing data into a template. The difficult part is the preparation: Which variant belongs to which order? Which value is current? Is a required field missing? Do two documents contradict each other? Can every statement be traced back to a source?

This is where automation can help. Not as an automatic legal approval, but as a traceable path from scattered information to a reviewable draft.

PPWR: what changes from 12 August 2026

Regulation (EU) 2025/40 on packaging and packaging waste—the Packaging and Packaging Waste Regulation, or PPWR—generally applies from 12 August 2026.

That date does not mean that every rule applies immediately in the same way to every package. The concrete relevance depends, among other things, on the scope, the type of packaging, the company’s role and the supply chain. Some requirements also apply at later dates or are clarified by supplementary acts.

For packaging covered by the relevant obligations, Article 15(2) refers to the conformity assessment under Article 38 and the technical documentation in Annex VII. Once conformity has been demonstrated, the EU declaration of conformity must be drawn up under Article 39. Annex VIII sets out its structure.

The technical documentation includes, among other things, a description of the product, relevant designs and materials, applied standards or specifications, a description of the assessment and test reports. The documentation and declaration must be kept for the required period—generally five years for single-use packaging and ten years for reusable packaging.

These are obligations of the responsible economic operator. They are not a reason to assign the same declaration or the same responsibility to every package automatically.

Responsibility is not visible in a file name

Different roles can be involved in a supply chain: manufacturer, importer, supplier, distributor or a company placing packaging on the market under specific conditions. The applicable obligations depend on the specific situation.

For a European SME working with suppliers in Italy, Germany or other EU countries, questions such as these may matter:

• In what role does the company make the packaging or packaged product available?
• What type and function of packaging are actually involved?
• Which data comes from the supplier and which from the company itself?
• Which documents and assessments are relevant to this case?
• Who has been appointed as responsible for assessment, approval and signature?

A digital workflow can make these questions visible and connect the information. It cannot answer them automatically as legal advice.

What can be automated when preparing a declaration of conformity

A robust process starts with one defined document type and an approved template. Software can then take over several recurring steps.

1. Bring data together from existing sources

PDFs, messages, forms, product master data and ERP exports are assigned to the correct order or variant. The solution can extract, for example, product names, dimensions, materials, quantities, versions and supplier information—if those details are present in the sources.

2. Structure required fields and sources

Instead of generating free text immediately, the information is collected in a schema. Each field can be traced to the document or system it came from. This creates an audit trail: the person reviewing the draft does not have to start searching through five different archives again.

3. Flag missing data and contradictions

A good workflow makes uncertainty visible. It can flag a missing material, two different dimensions or a variant that cannot be assigned with confidence. It does not replace the missing value with a plausible guess.

Units and version numbers can also be checked. These checks are not a conformity assessment, but they reduce transcription errors and show where technical clarification is needed.

4. Create a draft from an approved template

Once the data is structured and open points are visible, an approved template can be populated. The rule-set version, template version and source links remain documented. The result is not just a PDF, but a traceable intermediate state.

What should not be delegated

The most important boundary is simple: an automatically generated text is not a confirmed declaration of conformity.

Alpino AI should therefore not claim to issue a legally valid declaration on its own. The workflow does not replace:

• the legal classification of a product or package,
• the decision on which legal basis, standard or specification applies,
• confirmation of technical facts that are not documented,
• the conformity assessment itself,
• technical approval or
• the responsible person’s signature.

The right positioning is this: Alpino AI prepares the documentation in a structured way and makes open points reviewable. The responsible economic operator assesses, completes, approves and signs it.

A realistic pilot for a European SME

A pilot should not start with a general “compliance agent”. It is more useful to choose one document type, one approved template and a clearly defined rule set.

A possible approach:

1. Choose one recurring document type.
2. Define required fields, sources and technical checks together.
3. Assemble 10–20 historical or new cases as a test corpus.
4. Map extraction, contradiction checks, drafting, approval and PDF archiving.
5. Compare preparation time, clarification requests, missing data and corrections before and after the pilot.

This is particularly relevant for printing and packaging businesses, technical manufacturing, machine and plant engineering, component manufacturers and companies with many supplier and material documents. The common factor is not the industry label; it is a recurring process with scattered data and a clearly identified responsible person.

Conclusion: prepare, review, approve

Creating EU declarations of conformity means more than filling in a template. Quality depends on whether the information is complete, consistent, current and traceable to its sources.

Automation can speed up exactly this preparation: data is collected, required fields are structured, uncertainties are flagged and a draft is created. Legal classification, technical assessment, approval and signature remain with the responsible economic operator.

If you want to assess whether this process fits your company, book a 30-minute initial conversation. We start with one concrete documentation workflow and a clearly defined pilot scope.

Sources and regulatory status

The legal notes refer to the research status of 12 August 2026 and do not replace individual legal or technical advice.

• Regulation (EU) 2025/40 on EUR-Lex – in particular Articles 15, 38 and 39 and Annexes VII and VIII
• European Commission: New EU rules on packaging enter into application on 12 August 2026
• European Commission: Guidance C/2026/3702
• German Environment Agency: New rules for packaging
• ZSVR: What changes from 12 August 2026
• MASE: PPWR self-assessment