The PPWR Declaration of Conformity is the document everyone prepares first for PPWR compliance, and with good reason: it is the first thing checked on any packaging, and without it nothing else moves. The verification rarely stops there, though.
When a market surveillance authority wants to go beyond that first check, what they request is the technical documentation:
the design records, material data, and test evidence that prove the declaration is true.
The PPWR calls it technical documentation throughout, though most manufacturers know this kind of dossier as the technical file from CE marking, and the two terms are used interchangeably in practice. A declaration without technical documentation behind it is an empty statement, and the documentation only works if its content maps to the specific requirements the packaging has to meet.
What Does PPWR Technical Documentation Need to Include?
Annex VII, point 2, defines the technical documentation with two layers. The opening paragraph sets what the documentation as a whole has to achieve: making it possible to assess the packaging’s conformity with the applicable requirements, including an adequate analysis and assessment of the risks of non-conformity. Below that, it lists six elements the documentation has to contain wherever applicable, points (a) to (f).
General Description and Intended Use
The first element on the list. It describes what the packaging is and what it is for: the format, the packaged product it serves, and the function it performs. This does not need to be a lengthy narrative. What it needs to do is give an authority reading the documentation enough context to understand the rest of the evidence, since a material declaration or a minimisation justification only makes sense against a clear picture of what the packaging is supposed to do.
Conceptual Design, Manufacturing Drawings, and Materials of Components
One entry on the legal list, covering three kinds of records.
The conceptual design captures the design choices behind the packaging.
The manufacturing drawings document how it is physically produced: dimensions, tolerances, construction.
The materials section lists what each component is made of, component by component: the main body, closures, labels, coatings, inks, and adhesives. That last part carries more weight than it appears to, because substance compliance, recycled content figures, and recyclability assessments all trace back to knowing exactly what materials are in the packaging.
Annex VII also asks for the descriptions and explanations necessary to understand these drawings and the operation of the packaging. For packaging sourced from a converter, most of this already exists on the supplier’s side, and Article 16 obliges suppliers to hand it over. Compiling the documentation does not require redrawing anything, it requires collecting what already exists and keeping it accessible.
Standards and Technical Specifications Applied
The documentation has to list the harmonised standards under Article 36 or common specifications under Article 37 applied, in full or in part, and which parts were applied partially. Since those standards and specifications are still being developed for most PPWR requirements, the entry most manufacturers will actually write in 2026 is the alternative the annex provides for exactly this situation: a description of the solutions adopted to meet the requirements, together with any other technical specifications used for measurement or calculation.
Qualitative Description of the Recyclability, Minimisation, and Reusability Assessments
Point (e) of the list asks for a qualitative description of how the assessments under Articles 6, 10 and 11 were carried out. This is about documenting the method, not just the result: how the packaging was assessed, against what criteria, and by whom. What each of those assessments involves depends on the substantive requirement itself, covered in the next section.
Analysis of the Risks of Non-Conformity
This element comes from the opening paragraph of Annex VII, point 2, rather than from the (a) to (f) list, and it applies to the documentation as a whole. Manufacturers coming from CE marking read “risk assessment” and picture a product safety exercise, evaluating what harm the product could cause. The Annex VII requirement is a different animal. What it asks for is an analysis of the risks of non-conformity: where this packaging could fail to meet the Articles 5 to 12 requirements, and how those points are controlled, particularly so that series production stays conforming over time. A supplier change that could introduce restricted substances, or process variability that could shift a declared recycled content figure, is the kind of risk this analysis covers. No safety risk assessment of the packaging is required.
Test Reports
The final element on the list, and arguably the most important content in the whole dossier. Every other section describes the packaging; the test reports are what proves the claims about it. Which tests belong in the documentation depends entirely on the substantive requirements covered in the next section: a heavy metals analysis where Article 5 applies, a compostability certificate where Article 9 does, and so on. There is no fixed testing list that fits every packaging.
The PPWR does not impose a general testing obligation either. What it imposes is compliance with the limits, and testing is how a manufacturer substantiates that compliance where supplier documentation alone does not.
Technical documentation can be perfectly valid with supplier test reports rather than the manufacturer’s own, as long as each report is traceable to the specific component and requirement it covers.
The Declaration of Conformity
The signed Declaration of Conformity is kept together with the technical documentation, and the two travel as one package for the full retention period. Under Module A, the manufacturer draws up the declaration on the basis of that documentation, so
technical documentation without its declaration is incomplete in the same way a declaration without its documentation is unsupported.
What Are the Substantive Requirements According to the PPWR?
Beyond the common baseline, the documentation has to make it possible to assess the packaging against each substantive requirement in Articles 5 to 12 that applies to it. Each article calls for its own type of evidence, and a dossier that is thick with generic spec sheets but never maps evidence to requirements is incomplete no matter how much paper it contains. Labeling under Article 12 still depends on pending implementing acts, so there is little to compile for it today beyond tracking their adoption, and Article 8 on bio-based feedstock imposes no obligation on manufacturers at this stage.
Substances of Concern, Heavy Metals, and PFAS (Article 5)
These limits already apply from August 12, 2026, which makes this the most urgent evidence block in the documentation. For the four restricted heavy metals, and for PFAS where the packaging is food-contact, you need either test results or supplier declarations that are backed by something concrete: a named test method, a lab report, specific figures. A supplier statement that asserts compliance without citing any of those does not hold up as evidence.
Recyclability (Article 6)
The graded recyclability assessment becomes binding from 2030 at the earliest, once the design-for-recycling delegated acts are adopted, so there is no formal grading to document today. What does belong in the documentation already: any exemption the packaging relies on under Article 6(11), with the evidence supporting it, and the justification dossier for packaging claimed as innovative. Referencing the old harmonised standards for recyclability no longer creates a presumption of conformity, so any mention of them works as design context rather than as a conformity claim.
Recycled Content (Article 7)
The recycled content targets apply from 2030 and are calculated as an average per manufacturing plant and year, which shapes what the evidence looks like: documentation from each plant that produces each plastic component, showing the recycled share supplied over the year. A packaging assembled from components made in different plants needs figures from each of them. Plastic parts under 5% of the total packaging unit weight are exempt, and that exemption itself belongs in the documentation, with the weight calculation behind it.
Compostability (Article 9)
From February 2028, the packaging formats subject to mandatory compostability, such as permeable tea and coffee bags, need industrial compostability certification on file. Non-permeable machine-use capsules are outside the EU-wide obligation, but where a member state imposes compostability on its own territory, the evidence requirement follows for sales in that market.
Packaging Minimisation (Article 10)
Minimisation applies from January 1, 2030, and its evidence is the most product-dependent of the whole set: the justification has to show that this packaging is the minimum necessary for this product, which cannot be copied across from another product’s documentation. Design features that increase perceived volume, such as double walls or false bottoms, need a documented functional justification to survive scrutiny. Minimisation is also the one requirement where the old harmonised standard, EN 13428:2004, still carries a presumption of conformity, until the end of 2029.
Reusable Packaging (Article 11)
For packaging placed on the market as reusable, the documentation has to show that the design and the reuse system it circulates in allow the packaging to complete the minimum number of rotations, once the delegated act setting that number is adopted. The evidence here covers both the packaging itself and the system: a well-designed crate in a system with no return logistics does not meet the requirement.
How Do I Protect Confidential Information in My Technical Documentation?
Manufacturing drawings and material compositions are exactly the kind of information companies protect as trade secrets, and the obligation to compile them into a dossier that authorities can request creates an understandable worry. The answer is that the obligation to keep the documentation available does not make its content public. The Commission has confirmed that manufacturers should ensure the confidentiality of commercially sensitive information in accordance with EU and national law, and market surveillance authorities that receive it are bound by those same confidentiality protections. Compiling the documentation means having the evidence ready for a regulator, not disclosing your designs to the market.
How Long Do I Need to Retain PPWR Technical Documentation?
Five years for single-use packaging, ten years for reusable packaging, counted from the moment the packaging is placed on the market. The obligation covers the technical documentation together with the Declaration of Conformity it supports, and it applies to importers as well as manufacturers: an importer bringing packaging into the EU has to keep the same documentation available for the same periods.
Who Compiles the Technical Documentation?
The manufacturer, and this is one obligation that cannot be handed off. A manufacturer can appoint an authorised representative to draft the Declaration of Conformity and to keep the documentation at the disposal of national authorities. Drawing up the technical documentation itself stays with the manufacturer regardless of any mandate.
Suppliers play a defined supporting role. Under Article 16, they are required to provide the manufacturer with all the information and documentation needed to demonstrate conformity, and they cannot refuse to hand it over. What they are not responsible for is assembling it: collecting supplier inputs into a coherent dossier that maps evidence to requirements is the manufacturer’s job, and the legal responsibility for the result cannot be transferred by contract.
Running laboratory tests and contracting EPR representatives country by country sit outside our main business, though both are activities we handle for our clients when a project needs them.
What sits squarely inside our business is putting together complete technical documentation: collecting the evidence, mapping it to the requirements that apply to your packaging, and leaving you with a dossier that holds up when an authority asks for it. Request a quote and tell us where you are in the process.
