EU DECLARATION OF CONFORMITY pursuant to Regulation (EU) 2025/40 on packaging and packaging waste (PPWR)

I. Object of the Declaration

This declaration of conformity applies to all transport packaging used by Nykta GmbH for the direct distribution of individually configured personal computers (Built-to-Order) to end customers via its own webshop. The packaging serves exclusively to protect sensitive, high-value electronic equipment during transit and is classified as transport packaging within the meaning of Article 3(2) of the PPWR.

II. Description of the Packaging Components Used

Component 1 – Inner Packaging (Original Chassis Box)

The fully configured PC unit is accompanied by the original packaging of the respective PC chassis manufacturer. This consists of an outer corrugated cardboard box, cushioning elements made of expanded polyethylene (EPE) or expanded polystyrene (EPS), and a protective film around the chassis. A manufacturer's declaration of conformity is available for this packaging and is hereby referenced. The original packaging is not modified.

Component 2 – Two-Component Foam Cushion (Internal Cushioning)

To secure the components installed inside the chassis (motherboard, drives, cooling system) against vibrations and impacts during transport, two-component polyurethane foam cushions (PU foam, reactive foaming process, comparable to Sealed Air Instapak or equivalent) are used. The cushions are individually adapted to the inner geometry of the respective chassis, forming a form-fitting protective enclosure.

Material: Polyurethane (PU), two-component, based on polyol and isocyanate
Supplier: Sealed Air Instapak (Article No. 0188/IQRT-20) or equivalent
Recycled Content: 0%

Component 3 – Outer Box (Outer Packaging)

A corrugated cardboard box is used as outer packaging. The size of the outer box is selected from a defined range of sizes depending on the dimensions of the original chassis box in order to minimize excessive empty space. The box consists of corrugated cardboard based on virgin and recovered paper fibres. The proportion of recovered fibres is approximately 90%.

Component 4 – Bubble Wrap

Between the original box and the outer box, 1–2 layers of bubble wrap are used to fill any remaining clearance in the outer box and provide additional impact protection. The bubble wrap used currently contains 0% recycled material. The transition to films with a recycled content of 50% is being prepared in cooperation with the supplier.

Material: Polyethylene (PE)
Supplier: Storopack AIRmove² bubble-film M (Article No: 532325)

Component 5 – Custom-Cut Cushioning Blocks (Component Securing)

For targeted, highly effective mechanical fixation of particularly heavy and sensitive components inside the chassis (primarily to secure the graphics card and partly the CPU cooler), individually cut blocks made of expanded polyethylene are used for each PC system. This solution represents an eco-efficient and environmentally friendly alternative to full encapsulation using PU foam.

Material: Expanded Polyethylene (EPE)
Supplier: Domestic specialist supplier / factory custom cut
Recycled Content: 30%

Clarification on Eco-Efficient Second Use (Waste Prevention): Nykta GmbH does not operate a formal, closed re-use system within the meaning of Article 3(24) of the PPWR, which would require logistical return loops. However, within the scope of operational waste prevention (in accordance with the waste hierarchy of Directive 2008/98/EC), the company practices an eco-efficient second use of intact transport packaging and auxiliary materials (e.g., corrugated boxes, EPE foams, bubble wrap) originating from B2B goods receipts from component suppliers. These materials undergo a strict internal quality and stability check before being re-used in B2C shipping. It is ensured that they fully meet the protection and safety requirements for the transport of dangerous goods or electronic equipment and do not bear any misleading obsolete markings. This practice serves to directly conserve primary resources and reduce packaging waste generation at source.

III. Conformity Assessment Procedure

Nykta GmbH has carried out the following internal assessment procedure:

3.1 Necessity and Minimisation (Art. 9 PPWR)

The packaging configuration was evaluated based on product characteristics (weight, centre of gravity, vibration sensitivity of installed components). It was determined that multi-level packaging is technically required. The requirements of the chosen shipping service provider for transport packaging were taken into account. Box wall thicknesses, the amount of foam, and the number of bubble wrap layers have been reduced to the minimum technical level necessary.

Through the targeted, combined use of tailored EPE cushioning blocks (Component 5) for heavy internal components such as graphics cards and CPU coolers, the volume of the two-component PU foam (Component 2) used has already been reduced to the absolute minimum. However, the remaining use of the two-component foam cushion is strictly required as a high-performance component for which there is technically no alternative. Due to the individual Built-to-Order configurations of the personal computers, the internal clearances and weight distributions vary with each system. Only the expanding reactive foam process guarantees seamless, form-fitting fixation of the highly sensitive, pluggable electronic components (such as RAM modules and PCIe expansion cards). Dispensing with this component would lead to a disproportionately high transport damage rate. The resulting accumulation of irreparable waste electrical and electronic equipment (WEEE) would directly contradict the Union's overarching resource efficiency and environmental protection objectives. From an overall ecological perspective, protecting the packaged goods to avoid total loss holds legal and technical precedence here.

3.2 Recyclability (Art. 7 and Annex II PPWR)

3.3 Recycled Content (Art. 7 PPWR)

For corrugated cardboard boxes, the use of recycled fibres is standard in the industry and amounts to approximately 90% according to the supplier. The newly introduced custom-cut EPE cushioning blocks have a verified recycled content of 30%. For the PU foam cushions and bubble wrap, the recycled content is currently 0%.

3.4 Substance Restrictions and Hazardous Substances (Art. 5 PPWR)

No packaging is used that knowingly contains heavy metals (lead, cadmium, mercury, hexavalent chromium) exceeding the permissible threshold values or any other substances restricted under the PPWR. Regarding the PU foam: in its cured state, the components used (polyol, isocyanate) are not classified as hazardous substances under the CLP Regulation; a confirmation from the supplier is available. Unobjectionable supplier certificates are also available for the EPE foams used.

3.5 Labelling (Art. 11 PPWR)

The implementation of labelling obligations pursuant to Article 11 of the PPWR (material identification, QR code) is being assessed within the transitional period and will be fully deployed before the prescribed statutory deadline.

IV. Reference to Technical Documentation

The following documents are associated with this declaration and are filed in the internal quality management system:

• Declaration(s) of conformity from the PC chassis manufacturers (Annex 1)
• Supplier proof for PU foam cushions – material specification, recycling, recycled content (Annex 2)
• Supplier proof for bubble wrap – recycling, recycled content (Annex 3)
• Internal packaging assessment / technical justification of the packaging configuration (Annex 4)
• Supplier proof for custom-cut EPE cushioning blocks – material specification, 30% recycled content (Annex 5)

V. Responsible Person

This declaration is issued by and is the sole responsibility of:

Philip Pfab, Managing Director
Nykta GmbH, Miesbacher Str. 34b, 83620 Feldkirchen-Westerham
Email: info@nykta-pc.eu
Tel: +49 (0) 806339408-0

VI. Declaration

We, Nykta GmbH, declare under our sole responsibility that the packaging described above complies, to the best of our knowledge and based on the conformity assessment procedure carried out, with the applicable requirements of Regulation (EU) 2025/40 (PPWR), insofar as these are in force and applicable at the time of this issue. For components where supplier verifications are still pending, we undertake to obtain these promptly and to update this declaration accordingly.