do I need to have my packaging tested before I use it

Mandatory laboratory testing does not exist, substantiation does

A testing body that tests and certifies the packaging is not mandatory. The PPWR does not require a notified body or external testing as a fixed step before packaging can be placed on the market. What does apply: there must be substantiation that the packaging meets the requirements, and that substantiation must be documented. Anyone who can demonstrate themselves — with documentation, calculations, test results from the supplier or other technical data — that the packaging meets requirements such as recyclability or substance restrictions, fulfils the core of the obligation without necessarily having involved a testing body.

This does not mean testing is never relevant. For some requirements, such as a demonstrated recycling content or a limit on a specific substance, testing is often the only way to provide solid substantiation. Anyone who does not test themselves then relies on the data that is obtained from the packaging supplier . Whether that is sufficient depends on how convincing that data is — a test report is stronger evidence than a verbal assurance, but the regulation does not mandate testing itself as a fixed procedure.

Annex VIII asks for documentation, not a conformity mark

Annex VIII of Regulation (EU) 2025/40 describes the model for the EU Declaration of Conformity and the underlying technical documentation that goes with it. That annex asks for a declaration and evidence demonstrating compliance with the requirements, but does not specify a mandatory role for a testing body or laboratory. What exactly must be included in that declaration and the associated files is detailed on the page on what must be included in a PPWR Declaration of Conformity, and how long those documents must be kept is described on the page on documentation that must be kept with packaging.