Do I need a declaration of conformity for my shipping box?

## The short answer Whether you need a declaration of conformity for your shipping box depends on who places the packaging on the market and what type of packaging it is exactly. The European Packaging Regulation requires anyone who places packaging on the market to be able to demonstrate that the packaging meets the requirements, and this is done with a declaration of conformity and an underlying technical file as described in Annex VIII of the regulation. A shipping box that you yourself purchase and use to pack orders falls under this in most cases, even if the box itself bears no brand or logo. The point where things often go wrong is the assumption that only product packaging — the box or bottle in which the product itself is sold — counts and that the cardboard outer box that only serves to ship something is left out of the picture. This distinction does exist in the regulation, but it does not align with what people intuitively think. A shipping packaging is a separate category with its own requirements, not a category that is exempted. ## Product packaging and shipping packaging are not synonymous The regulation distinguishes between different levels of packaging: packaging that goes directly around the product, packaging that bundles products, and packaging that serves to transport or ship. A webshop that sells clothing loose in a plastic bag and then puts that bag into a cardboard box for shipping is dealing with two packaging layers that can both fall under the regulation. Both layers can potentially require their own declaration of conformity, with the caveat that the nature of the obligation can differ per layer. This is exactly the detail this topic hinges on: anyone assuming that only the product itself and the direct packaging around it are relevant often leaves the shipping box out of their own file. However, supervisory authorities and certifying parties look at the full packaging chain a company uses, not just the part that the customer sees first. ## When this applies to your situation Whether and how this affects a specific business depends on who in the chain is considered the manufacturer of the packaging, in which country the packaging is placed on the market and whether the box bears its own branding. This is precisely why a general explanation cannot go further here than sketching the distinction: the role you perform — manufacturer, importer or something else — determines whether the obligation lies with you or with a party further down the chain. If you want to check this per packaging type, you can do so [[LINK:/rolwijzer|by working through a few questions and immediately getting an indication]] without needing an account for that. ## What belongs in a declaration of conformity and file A declaration of conformity is not a standalone form but a summary of an underlying technical file. That file typically contains data about the materials used, the way the packaging is reusable or recyclable, and substantiation that there are no unauthorised quantities of heavy metals or certain substances such as PFAS in the packaging. In addition, the name and address of the responsible party must appear on the packaging or in the accompanying documentation. For a shipping box, this means in practice that it is not enough to know who supplies the box; there must also be substantiation for why that box meets the material and design requirements. Drawing up and maintaining such a file is a recurring task, especially when a company changes suppliers or adapts the design of the shipping box. If you prefer not to figure out yourself which template and which substantiation applies to each packaging type, you can have that part [[LINK:/prijzen|set up within the packaging file of the subscription]] instead of reconstructing this from scratch with each shipment. ## What you can check yourself in the meantime Without immediately building a file, it is useful to check for the shipping box you use what material it is made of, whether it bears its own brand and whether the same box is also used in other countries. These three pieces of information determine to a large extent whether the obligation lies with you as the shipper or with the supplier of the box. More background on how this classification is structured in the regulation is neatly compiled in the [[LINK:/kennisbank|knowledge base by topic]], and if you want to know where that information comes from exactly, you can read about it via [[LINK:/hoe-het-werkt|the explanation about the sources used]]. If after reading you still have doubts about whether the shipping box you use falls under your own responsibility, then a legal assessment in borderline cases is something for which the guidelines of the European Commission or a lawyer remain the appropriate point of contact. For an initial, free indication of your situation, the role guide is a logical starting point, and if you prefer to browse the broader topics right away, you will find them compiled in the knowledge base.