PPWR Technical Documentation: What Evidence Must Support Packaging Conformity?
PPWR compliance requires more than collecting supplier certificates. Technical documentation must support conformity for the packaging being assessed and can include specifications, materials, assessments and test reports. This guide explains Annex VII, supplier evidence, conformity assessment and the EU Declaration of Conformity.
PPWR Technical Documentation: What Evidence Must Support Packaging Conformity?
A supplier says its packaging is PPWR compliant.
It sends a material specification, perhaps a test report and possibly a declaration.
Is that enough?
Not necessarily.
Under the EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, conformity must be demonstrated for the packaging concerned. Manufacturers must carry out the applicable conformity assessment, establish technical documentation and, once conformity has been demonstrated, draw up an EU Declaration of Conformity.
This makes one point particularly important for organizations managing packaging compliance:
Evidence is only useful if it can be connected to the packaging for which conformity is being demonstrated.
A collection of supplier documents is not, by itself, a complete conformity record.
In brief
PPWR technical documentation must make it possible to assess whether packaging conforms to the applicable requirements.
Depending on what is relevant, that documentation can include the packaging description and intended use, design and component-material information, technical specifications, required assessments and test reports.
The EU Declaration of Conformity comes after conformity has been demonstrated. It identifies the packaging concerned and formally states that the applicable requirements have been fulfilled.
For companies, this means PPWR documentation should answer three basic questions:
What packaging is being assessed?
Which requirements apply to it?
What evidence demonstrates conformity with those requirements?
Start with the packaging being assessed
Before asking whether the documentation is complete, an organization needs to know exactly which packaging the documentation concerns.
This sounds obvious, but it can become difficult in a real supply chain.
One finished product may use:
a bottle or jar
a closure
a label
a carton
inserts
grouped packaging
transport packaging
Suppliers may use their own part numbers. Procurement may use another set of references. Finished products may have commercial SKUs that do not correspond directly to individual packaging specifications.
PPWR conformity documentation therefore cannot be managed effectively only at supplier level or only at finished-product SKU level.
Annex VII of Regulation (EU) 2025/40 requires the manufacturer to draw up a written declaration of conformity for each packaging type, while Annex VIII requires identification of the packaging that allows traceability.
The practical implication is straightforward:
Before evaluating the evidence, establish precisely which packaging the evidence supports.
That identification may rely on a packaging reference, specification, description, design or another sufficiently traceable identifier, depending on the circumstances.
A supplier folder is not the same as a technical file
Consider a company buying five packaging formats from the same supplier.
The supplier sends:
one general PPWR statement
three material specifications
two test reports
a drawing for one packaging format
The company now possesses documents.
But several questions remain:
Which test report relates to which packaging?
Do the specifications cover the current packaging versions?
Which applicable requirements does each document help demonstrate?
Are there packaging formats for which evidence is still missing?
Has anything changed since the evidence was issued?
These questions illustrate the difference between document collection and demonstrating conformity.
The purpose of Annex VII technical documentation is not merely to prove that documents have been gathered. It is to enable an assessment of whether the packaging complies with the applicable PPWR requirements.
What must PPWR technical documentation contain?
Article 38 of PPWR requires conformity assessment against the requirements laid down in or pursuant to Articles 5 to 12 according to the procedure in Annex VII.
Annex VII establishes Module A, or internal production control.
The manufacturer must establish technical documentation that makes it possible to assess the packaging's conformity with the applicable requirements and includes an adequate analysis and assessment of the risks of non-conformity.
Where applicable, the documentation must contain at least the following.
1. A description of the packaging and its intended use
The technical documentation must include a general description of the packaging and its intended use.
This establishes what is actually being assessed.
For organizations managing hundreds or thousands of packaging references, consistent identification becomes an important part of maintaining reliable compliance records.
2. Design and material information
Annex VII refers to:
conceptual design
manufacturing drawings
materials of components
explanations necessary to understand the drawings, schemes and operation of the packaging
The Regulation therefore reaches beyond a simple description such as “plastic bottle” or “cardboard box.”
The evidence necessary for a particular assessment may depend on the construction and materials of the packaging concerned.
3. Applicable standards and technical specifications
Where relevant, technical documentation must identify:
harmonised standards applied in full or in part
common specifications applied in full or in part
other relevant technical specifications used for measurement or calculation
which parts were used where a standard or specification was applied only partially
Where harmonised standards or common specifications are not applied, the documentation must describe the solutions used to meet the relevant requirements.
This part of the technical file will become increasingly important as standards, specifications and methodologies supporting PPWR develop.
4. Relevant PPWR assessments
Annex VII specifically requires, where applicable, a qualitative description of how assessments under Articles 6, 10 and 11 have been carried out.
These provisions address areas including recyclability, packaging minimisation and reusable packaging.
However, timing matters.
PPWR generally became applicable on 12 August 2026. That does not mean every substantive requirement contained in Articles 5 to 12 became applicable on that date.
Different requirements have different application dates, transitional provisions and, in some cases, dependencies on future technical measures.
For a broader explanation of what applied from 12 August and what comes later, see PPWR Obligations Starting 12 August 2026: What Companies Need to Know.
Organizations therefore need to distinguish between:
requirements that apply now
and
requirements for which future evidence and assessment will be needed.
5. Test reports
Annex VII expressly lists test reports among the elements that technical documentation must contain where applicable.
That matters because certain characteristics cannot necessarily be demonstrated by a supplier statement alone.
Depending on the packaging and the requirement being assessed, supporting evidence may include:
laboratory test reports
material specifications
technical calculations
design information
assessments
other technical evidence
The appropriate evidence depends on what must actually be demonstrated.
Evidence should answer a requirement, not merely exist
This provides a useful way to review supplier documentation.
Instead of asking:
“Do we have documents for this supplier?”
ask:
“Do we have adequate evidence for the applicable requirements for this packaging?”
The difference is significant.
A supplier specification may establish material composition.
A test report may demonstrate a particular measured property.
A technical assessment may address another PPWR requirement.
A Declaration of Conformity serves a different purpose again.
Possessing one of these does not automatically prove everything that needs to be demonstrated.
What is the relationship between technical documentation and conformity assessment?
Technical documentation and conformity assessment are closely connected.
Article 38 requires conformity assessment against requirements laid down in or pursuant to Articles 5 to 12 according to Annex VII.
Annex VII, in turn, requires technical documentation that makes it possible to assess conformity.
The process should therefore not be understood as:
collect documents → write technical file → conformity automatically follows
Instead, the documentation must contain the information necessary to support the conformity assessment.
Where conformity has been demonstrated, the manufacturer then draws up the EU Declaration of Conformity under Article 39.
The Declaration of Conformity is not the evidence file
This is one of the most important distinctions for PPWR implementation.
The technical documentation supports the conformity assessment.
The EU Declaration of Conformity formally states that fulfilment of the applicable requirements has been demonstrated.
The two serve different purposes.
Compliance element | Primary purpose |
|---|---|
Packaging identification | Establish what packaging is being assessed |
Supporting evidence | Provides facts, measurements, specifications and other substantiation |
Technical documentation | Documents the basis on which conformity can be assessed |
Conformity assessment | Determines whether applicable requirements have been fulfilled |
EU Declaration of Conformity | Formally declares demonstrated conformity |
The table is a simplified operational view. The legal requirements themselves are set out principally in Articles 15, 38 and 39 and Annexes VII and VIII of Regulation (EU) 2025/40.
What must the EU Declaration of Conformity identify?
Annex VIII sets out the model structure for the declaration.
It includes, among other elements:
unique identification of the packaging
the manufacturer's name and address
a statement that the declaration is issued under the manufacturer's sole responsibility
identification and description of the packaging allowing traceability
references to relevant Union legislation
relevant harmonised standards, common specifications or other technical specifications
notified-body information where applicable
additional information
place and date of issue
name, function and signature
This reinforces the importance of traceability.
A declaration should not simply say that “our packaging complies with PPWR.” It must identify the packaging for which conformity is being declared.
Suppliers have an explicit information obligation
Article 16 of PPWR creates an important connection between packaging suppliers and manufacturers.
Suppliers of packaging or packaging materials must provide manufacturers with the information and documentation necessary for the manufacturer to demonstrate conformity, including relevant technical documentation required under or pursuant to Articles 5 to 11.
This makes supplier cooperation integral to PPWR implementation.
But organizations should be precise about what they request.
A generic request such as:
“Please provide your PPWR certificate.”
may not identify what is actually needed.
A better supplier request begins with the packaging concerned and asks for the information and evidence needed to demonstrate the requirements applicable to it.
Depending on the circumstances, this could include:
packaging specifications
material information
component information
drawings
applicable technical specifications
test reports
assessments
conformity documentation
information about changes affecting the packaging
What should an organization verify when supplier evidence arrives?
A useful first-level review can ask:
Does the evidence identify the packaging?
Can the organization tell what packaging or specification it covers?
Is it current?
Does it relate to the packaging actually being supplied today?
What does it demonstrate?
Is it clear which property, characteristic or requirement the document supports?
Is the evidence sufficiently specific?
A broad statement covering an entire supplier portfolio may not provide the same level of substantiation as packaging-specific technical evidence.
Are there gaps?
Does the organization still lack information needed for an applicable conformity assessment?
These are evidence-management questions, not merely document-management questions.
Importers also need visibility into the conformity evidence
For companies importing packaged products or packaging into the European Union, this issue cannot simply be delegated upstream and forgotten.
Under Article 18 of PPWR, before placing packaging on the market, importers must ensure, among other matters, that the manufacturer has carried out the conformity assessment and drawn up the required technical documentation.
Importers must also keep a copy of the EU Declaration of Conformity and ensure that the technical documentation can be made available to market-surveillance authorities.
Where a national authority requests the relevant information and documentation under Article 18, it must be provided within 10 days of receiving the request.
That makes accessibility important.
“Documentation exists somewhere with the supplier” and “documentation can be reliably produced for the packaging concerned” are not necessarily the same thing.
Packaging changes can trigger a new conformity question
PPWR compliance is also not static.
Article 15 requires manufacturers to take adequate account of changes in:
packaging design
packaging characteristics
harmonised standards
common technical specifications
other technical specifications used to declare or verify conformity
Where the manufacturer finds that conformity could be affected, a reassessment must be carried out.
This has an important practical consequence.
An organization cannot assume that evidence collected once remains valid indefinitely.
If a supplier changes a material, component, design or other relevant characteristic, the organization needs to determine whether the existing conformity basis is still valid.
How long must technical documentation be retained?
Manufacturers must retain the Annex VII technical documentation and EU Declaration of Conformity for:
Single-use packaging: five years from the date the packaging was placed on the market.
Reusable packaging: ten years from the date the packaging was placed on the market.
This creates another traceability challenge.
Organizations may need to preserve the evidence associated with packaging that is no longer the current version.
Simply overwriting an old specification with a new one can make it difficult to demonstrate what supported conformity when an earlier version was placed on the market.
A practical way to begin
Organizations do not need to begin by creating more PDFs.
A more useful starting point is to determine whether they can answer a small set of questions for their packaging:
1. What packaging are we assessing?
Establish a sufficiently precise and traceable identification.
2. Which PPWR requirements apply?
Take account of both the nature of the packaging and the relevant application dates.
3. What evidence do we already have?
Identify specifications, supplier information, tests, assessments and other supporting documentation.
4. What does each piece of evidence actually demonstrate?
Avoid treating every document as generic proof of “PPWR compliance.”
5. What is missing?
Identify the evidence necessary to complete the relevant conformity assessment.
6. Can we retrieve the evidence again?
Make sure that documentation can be associated with the correct packaging when it is needed.
7. Will we know when something changes?
Changes affecting packaging conformity need to be identified and evaluated.
If your organization has not yet established which entity acts as the manufacturer, importer or distributor in a particular scenario, first see PPWR Manufacturer, Importer or Distributor? How to Determine Your Role.
The real challenge is traceable evidence
PPWR technical documentation is sometimes discussed as though the main task were producing a new compliance document.
The operational challenge is broader.
Organizations need to be able to connect the packaging being assessed with the requirements that apply to it and the evidence that supports the conformity determination.
That becomes increasingly difficult when an organization has:
many packaging formats
multiple packaging suppliers
several components per product
changing packaging specifications
supplier documents in different formats
different application dates for PPWR requirements
evidence that needs to remain accessible for years
The result is a shift from simply storing compliance documents toward maintaining traceable evidence of packaging conformity.
And that is the foundation on which a credible EU Declaration of Conformity must ultimately rest.
Learn more
For an overview of the Regulation's current applicability and upcoming obligations, read PPWR Obligations Starting 12 August 2026: What Companies Need to Know.
For a deeper look at how legal responsibilities can differ between manufacturers, importers and distributors, read PPWR Manufacturer, Importer or Distributor? How to Determine Your Role.
PPWR Academy will also address technical documentation, supplier evidence, economic-operator responsibilities and practical implementation during:
Is Your Organization Ready for PPWR? Immediate Obligations, Key Deadlines and Practical Next Steps
1 September 2026
Register for the PPWR Academy webinar here → https://events.ppwracademy.com/webinar/
This article provides general educational information about Regulation (EU) 2025/40 and does not constitute legal advice.
Published by PPWR Academy
Last reviewed: August 2026
