Compliance Documents
EU Declaration of Conformity for
1) Electric Fireplace Product Family — Packaging
2) LFS Freestanding Console — Packaging
1) Electric Fireplace Product Family — Packaging
(Regulation (EU) 2025/40, Article 39 / Annex VIII)
1. Identification of the packaging (Annex VIII)
Unique identification number: PPWR_DOC_LE_LR_Series_21072026-1
Packaging type / description:
This declaration applies to Escea LE-Series and LR-Series holographic electric fireplaces. Packaging consists of a wooden pallet and lid, LDPE plastic bag and PET straps to contain and protect the unit. Loose parts required at the time of product assembly are contained within the product chassis and wrapped in bubble wrap, polyfilm or layflat tubing to protect cosmetic surfaces. The opening of the fireplace is closed for transport and handling by a metal panel screwed to the fireplace chassis.
A table of pallet and lid dimensions for all product sizes is provided in Appendix 1 to this document.
Reference drawing / photo (optional): A drawing of representative packaging is included in Annex 1 to this document
2. Manufacturer identification (Annex VIII)
Manufacturer name / registered trade name or trademark: Escea Fireplace Company
Registered address:
Escea Ltd
P.O. Box 5277
Dunedin 9058
New Zealand
Contact details: info@escea.com
3. EU Authorised Representative for EPR (where applicable)
Name and address of Authorised Representative(s):
Under Review
4. Statement of sole responsibility
This declaration is issued under the sole responsibility of the manufacturer identified in Section 2.
5. Declaration of conformity (Annex VIII)
The packaging identified in Section 1 is declared to be in conformity with the applicable requirements of Regulation (EU) 2025/40 (the Packaging and Packaging Waste Regulation), specifically:
Article 5 — Substances of concern
Escea electric fireplace packaging does not contain any substances of concern. For details, refer to technical data and certifications for component parts in attached technical file.
Article 6 — Design for recycling / recyclability
It is not yet possible to determine the grade as criteria are due only in 2028. Within the bounds of known information, there are no layers, coatings or additives that will prove detrimental to the recyclability or reusability of the product packaging. A table of packaging components is included in Section 7 of this document.
Article 7 — Minimum recycled content
Currently, plastic bags used in Escea electric fireplace packaging do not contain recycled material.
Article 9/10 — Packaging minimisation (weight, volume, empty space)
Escea electric fireplace packaging has been designed to protect the appliance during transport and handling using the minimum material required. Pallets have been sized specifically for each size of fireplace, wooden parts have been reduced to top and bottom only, and a simple plastic bag is used for environmental protection. A steel panel is used to complete the open side of the fireplace during transport and handling in order to provide protection for internal components as well as providing structural support when stacked in a warehouse.
Article 11 / Article 29 — Reusability and reuse targets
There is currently no reuse system in place for Escea electric fireplace packaging.
Article 12 — Labelling
Not yet applicable.
Article 24 — Empty space ratio (transport / grouped / e-commerce packaging)
A method for calculating 50% empty space has yet to be established. Despite this, the packaging has been designed to minimize volume and weight. An interim calculation is located in the Technical Documentation associated with this Declaration.
6. Conformity assessment procedure and standards applied
Conformity assessment module: Module A — internal production control (Annex VII). No notified body involved.
Harmonised standards / technical specifications applied: No standards yet applied
Technical documentation reference: PPWR_TECH_LE_LR_Series_21072026-1.docx
7. Packaging component and material inventory
For traceability and to support the assessments above, the packaging covered by this declaration is composed of the following components:
- Wooden pallet — Transport packaging · Wood · Assessment pending Annex II Table 1 (due 2028)
- Wooden lid — Transport packaging · Wood · Assessment pending Annex II Table 1
- PET strapping — Transport packaging · PET (plastic) · Assessment pending Annex II Table 1
- Plastic bag (product wrap) — Sales packaging · Plastic film · Assessment pending Annex II Table 1
- PET lay-flat tubing / polyfilm — Sales packaging component (protects loose parts, removed at installation) · PET / plastic film · Assessment pending Annex II Table 1
- Bubble wrap — Sales packaging component (protects loose parts, removed at installation) · Plastic film · Assessment pending Annex II Table 1
- Steel panel (front panel, discarded at installation) — Packaging (reclassified — discarded rather than remaining functional) · Steel · Assessment pending Annex II Table 1
- Tape (where used to secure components/packaging) — Minor component of the packaging item(s) it is applied to · No confirmed sub-category yet — treat as attached to substrate for weight reporting; assess separately for D4R
- UN3481 / stack-height labels — Marking, governed by dangerous goods transport law, not PPWR labelling (Art. 12) · N/A — outside PPWR Art. 12 scope
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8. Retention
This declaration and its supporting technical documentation will be retained for 5 years from the date the last unit of this packaging is placed on the market (10 years if any component is classified as reusable packaging) and made available to market surveillance authorities within 10 days of request.
6. Signature (Annex VIII)
Signed for and on behalf of the manufacturer:
Place of issue: Dunedin, New Zealand
Date of issue: 30/7/26
Name of signatory: Owen Clements
Function: Engineering Manager - Electric
Signature: Owen Clements
2) LFS Freestanding Console Packaging
(Regulation (EU) 2025/40, Article 39 / Annex VIII)
1. Identification of the packaging (Annex VIII)
Unique identification number: PPWR_DOC_LFS_Mk2_Console_21072026-1
Packaging type / description:
This declaration applies to Escea LFS Mk2 Freestanding consoles. Packaging consists of a wooden pallet, wooden frame, and LDPE plastic bag to contain and protect the unit. Loose parts required at the time of product assembly are contained within a cardboard box also contained within the wooden frame and wrapped in bubble wrap, polyfilm or layflat tubing to protect cosmetic surfaces.
A table of packaging dimensions for all product sizes is provided in Appendix 1 to this document.
Reference drawing / photo (optional): A drawing of representative packaging is included in Annex 1 to this document
2. Manufacturer identification (Annex VIII)
Manufacturer name / registered trade name or trademark: Escea Fireplace Company
Registered address:
Escea Ltd
P.O. Box 5277
Dunedin 9058
New Zealand
Contact details: info@escea.com
3. EU Authorised Representative for EPR (where applicable)
Name and address of Authorised Representative(s):
Under Review
4. Statement of sole responsibility
This declaration is issued under the sole responsibility of the manufacturer identified in Section 2.
5. Declaration of conformity (Annex VIII)
The packaging identified in Section 1 is declared to be in conformity with the applicable requirements of Regulation (EU) 2025/40 (the Packaging and Packaging Waste Regulation), specifically:
Article 5 — Substances of concern
Escea freestanding electric fireplace console packaging does not contain any substances of concern. For details, refer to technical data and certifications for component parts in attached technical file.
Article 6 — Design for recycling / recyclability
It is not yet possible to determine the grade as criteria are due only in 2028. Within the bounds of known information, there are no layers, coatings or additives that will prove detrimental to the recyclability or reusability of the product packaging. A table of packaging components is included in Section 7 of this document.
Article 7 — Minimum recycled content
Currently, plastic bags used in Escea electric fireplace packaging do not contain recycled material.
Article 9/10 — Packaging minimisation (weight, volume, empty space)
Escea electric fireplace freestanding console packaging has been designed to protect the appliance during transport and handling using the minimum material required. Pallets have been sized specifically for each size of fireplace console, wooden parts have been reduced to what is required for stacking and handling protections only, and a simple plastic bag is used for environmental protection.
Article 11 / Article 29 — Reusability and reuse targets
There is currently no reuse system in place for Escea electric fireplace packaging.
Article 12 — Labelling
Not yet applicable.
Article 24 — Empty space ratio (transport / grouped / e-commerce packaging)
A method for calculating 50% empty space has yet to be established. Despite this, the packaging has been designed to minimize volume and weight. An interim calculation is located in the Technical Documentation associated with this Declaration.
6. Conformity assessment procedure and standards applied
Conformity assessment module: Module A — internal production control (Annex VII). No notified body involved.
Harmonised standards / technical specifications applied: No standards yet applied
Technical documentation reference: PPWR_TECH_LFS_Mk2_Console_21072026-1.docx
7. Packaging component and material inventory
For traceability and to support the assessments above, the packaging covered by this declaration is composed of the following components:
- Wooden pallet — Transport packaging · Wood · Assessment pending Annex II Table 1 (due 2028). Note: consider a pooled/exchange pallet system re: Art. 29 reuse target.
- Wooden lid — Transport packaging · Wood · Assessment pending Annex II Table 1
- Wood frame — Transport packaging · Wood · Assessment pending Annex II Table 1
- Plastic bag (product wrap) — Sales packaging · Plastic film · Assessment pending Annex II Table 1
- PET lay-flat tubing / polyfilm — Sales packaging component (protects loose parts, removed at installation) · PET / plastic film · Assessment pending Annex II Table 1. Note: not transport packaging — travels with the sales unit to the end user.
- Bubble wrap — Sales packaging component (protects loose parts, removed at installation) · Plastic film · Assessment pending Annex II Table 1. Note: construction (mono- vs multi-material) is the key variable once criteria publish.
- Tape (where used to secure components/packaging) — Minor component of the packaging item(s) it is applied to · No confirmed sub-category yet — treat as attached to substrate for weight reporting; assess separately for D4R. Note: document material/adhesive/pigmentation per application point now, ahead of finalised guidance.
- Stack-height labels — Not PPWR labelling (Art. 12) · N/A — outside PPWR Art. 12 scope. Note: only the ink/adhesive's compatibility with the substrate's recycling stream is a PPWR consideration.
- Paint care labels — Not PPWR labelling (Art. 12) · N/A — outside PPWR Art. 12 scope. Note: only the ink/adhesive's compatibility with the substrate's recycling stream is a PPWR consideration.
8. Retention
This declaration and its supporting technical documentation will be retained for 5 years from the date the last unit of this packaging is placed on the market (10 years if any component is classified as reusable packaging), and made available to market surveillance authorities within 10 days of request.
9. Signature (Annex VIII)
Signed for and on behalf of the manufacturer:
Place of issue: Dunedin, New Zealand
Date of issue: 30/7/26
Name of signatory: Owen Clements
Function: Engineering Manager - Electric
Signature: Owen Clements