Declaration of conformity and technical documentation – what is the difference?
PPWR technical documentation and the EU declaration of conformity are two distinct elements of the same process. Technical documentation contains the evidence, calculations, specifications and assessments showing why a particular packaging complies with the applicable requirements. The EU declaration of conformity, by contrast, is a formal statement by the manufacturer, drawn up only after conformity has been demonstrated. Put simply: Annex VII answers the question, ‘on what basis have we considered the packaging to be compliant?’, while Annex VIII answers, ‘what do we formally declare once the assessment has been completed?’
These documents should not be treated as interchangeable. A one-page declaration does not replace the reports and assessments contained in the technical documentation. Conversely, a folder full of tests does not replace the EU declaration of conformity where the PPWR requires it to be drawn up for a given type of packaging.
Declaration of conformity and PPWR technical documentation – key differences
| Element | Technical documentation | EU declaration of conformity |
|---|---|---|
| Basis | Annex VII | Article 39 and Annex VIII |
| Main function | Shows why the packaging meets the requirements | Formally confirms demonstrated conformity |
| When prepared | Before the final declaration, as part of the conformity assessment | After conformity has been demonstrated |
| Scope | Detailed data, analyses, calculations and evidence | Concise formal document |
| Test reports | May be included in the documentation | There is no need to reproduce full reports |
| Supplier data | May form part of the evidence | Are not automatically annexed |
| Signature | The PPWR does not establish a single form for signing the entire dossier | Annex VIII provides for a signature |
| Responsibility | Provides the technical basis for the assessment | By drawing up the declaration, the manufacturer assumes responsibility for conformity |
| Typical recipient | Manufacturer and competent authorities; access is also provided in accordance with the importer’s role | A document formally confirming conformity, also used in commercial relations |
First technical documentation, then the declaration of conformity
The key difference is the place of both documents in the conformity assessment procedure.
Article 15 of the PPWR requires the manufacturer, before placing packaging on the market, to carry out or have carried out the appropriate conformity assessment procedure and draw up technical documentation.
If this process demonstrates that the relevant requirements are met, the manufacturer draws up the EU declaration of conformity.
The correct process is therefore:
packaging identification → requirements → data → evidence → technical documentation → conformity assessment → EU declaration of conformity.
The declaration should not be drawn up ‘in advance’, with reports supporting its content sought only later.
What is PPWR technical documentation?
Technical documentation is a set of information enabling the conformity of a specific type of packaging with the PPWR requirements to be assessed.
It does not have to mean one large PDF file.
It may be a system of linked documents covering:
- specifications,
- drawings,
- test reports,
- calculations,
- supplier documents,
- assessments of individual requirements,
- information on standards and technical specifications.
The key is that the basis for the assessment can be reconstructed for a specific packaging item.
Annex VII to the PPWR – what should technical documentation include?
Annex VII sets out the internal production control procedure and the scope of technical documentation.
The documentation should enable the conformity of the packaging with the relevant requirements to be assessed and include an adequate analysis and assessment of the risk of non-conformity.
Depending on the packaging, it may include, among other things:
- a general description of the packaging and its intended use,
- the conceptual design,
- manufacturing drawings,
- component diagrams,
- materials of individual parts,
- descriptions needed to understand the design,
- a list of harmonised standards, common specifications or other technical specifications applied,
- a description of the solutions adopted to meet the requirements,
- the results of design calculations,
- the results of tests carried out,
- test reports.
Technical documentation also includes an analysis of the risk of non-conformity
Annex VII does not reduce documentation to a repository of certificates.
The manufacturer should analyse which requirements apply and what risk of failing to meet them exists.
For a specific packaging item, it is therefore worth indicating:
- the PPWR requirement,
- whether it applies,
- from when it applies,
- the risk of non-conformity,
- the assessment method used,
- evidence,
- the result,
- the conclusion on conformity.
Such an analysis should not be squeezed into the declaration of conformity itself.
Test reports and calculations form part of technical documentation
If demonstrating a specific requirement requires a test or calculation, the result should be reflected in the technical documentation.
Examples may include:
- a report on the content of specified substances,
- PFAS analysis,
- a calculation of recycled content,
- an assessment of recyclability, where the relevant methodology applies,
- a mechanical test supporting minimisation,
- an assessment of reusable packaging.
There is no need to copy dozens of pages from each report into the declaration. The declaration refers to the outcome of the entire process.
Supplier documents are input to technical documentation
Article 16 requires suppliers of packaging and packaging materials to provide the manufacturer with the information and documentation needed to demonstrate conformity.
These may include, among other things:
- material specifications,
- composition information,
- data on layers and components,
- test reports,
- recycled content data,
- information on substances,
- drawings,
- other technical evidence.
A supplier document should not be automatically copied into the declaration of conformity. First, it must be assessed what it demonstrates and which requirement it relates to.
What is an EU declaration of conformity under the PPWR?
An EU declaration of conformity is the manufacturer’s formal statement that compliance with the relevant PPWR requirements has been demonstrated.
Article 39 provides that the declaration must state that compliance with the requirements set out in, or pursuant to, Articles 5–12 has been demonstrated.
The document structure is set out in Annex VIII.
The declaration is therefore neither a test report nor a description of the entire design process.
It is the final formal confirmation of the assessment outcome.
Annex VIII to the PPWR – what must the declaration of conformity contain?
Annex VIII provides for a harmonised structure for the EU declaration of conformity.
The document should include, among other things:
- the declaration number,
- packaging identification enabling its traceability,
- the manufacturer’s name and address,
- a statement of the manufacturer’s sole responsibility,
- the subject matter of the declaration,
- references to the relevant legal acts,
- references to the relevant standards or other specifications, where applicable,
- additional information, where required,
- details of the signatory,
- place and date,
- signature.
This is precisely why the declaration is much shorter than the technical documentation.
What does not need to be copied into the PPWR declaration of conformity?
The declaration is not intended to be a copy of the entire technical documentation.
As a rule, there is no need to include the full content of:
- laboratory reports,
- technical drawings,
- full material formulations,
- complete supplier specifications,
- detailed calculations,
- the full risk analysis,
- the history of all design trials.
This information should be available in the documentation supporting the declaration.
Is the declaration of conformity alone sufficient for the PPWR?
Not for the manufacturer responsible for demonstrating compliance.
Article 15 and Annex VII require technical documentation to be drawn up as part of the assessment process.
A declaration without documentation would in practice amount to the statement:
“the packaging complies”
without material allowing the question to be answered:
“how is this known?”.
During an inspection, it may therefore be necessary to provide the technical material underlying the declaration.
Does technical documentation alone replace the EU declaration of conformity?
No.
The documentation may demonstrate compliance perfectly, but after the procedure has been successfully completed, the PPWR requires an EU declaration of conformity to be drawn up.
You may therefore have:
- all test results,
- a full specification,
- correct calculations,
- a sound risk analysis,
and still not have the final formal document required by Article 39.
Who draws up the technical documentation and who the PPWR declaration?
The relevant manufacturer is responsible for both elements of the process.
This does not mean that they must generate all data themselves.
The process may involve:
- material suppliers,
- component manufacturers,
- laboratories,
- designers,
- the quality department,
- R&D,
- external experts.
Ultimately, however, it is the manufacturer who assesses the entire packaging type and draws up the declaration after demonstrating conformity.
Are the technical documentation and declaration signed in the same way?
They should not be treated as two identical forms.
Annex VIII provides for the formal signature of a person acting on behalf of the manufacturer on the declaration of conformity.
Technical documentation may, however, consist of many separate elements:
- approved specifications,
- reports signed by the laboratory,
- internal assessments,
- drawings with their own approval process,
- supplier documents.
The company should control their versions and approvals, but the PPWR does not create a single signature form for the entire dossier analogous to Annex VIII.
What should be provided to the customer: the declaration or the full technical documentation?
The PPWR does not establish a general rule that, with every sale, the manufacturer must automatically provide every business partner with the full technical documentation under Annex VII.
The documentation must primarily enable conformity to be demonstrated and be available as part of obligations towards the competent authorities and relevant supply chain actors where required by the rules.
In a B2B relationship, however, the business partner may need:
- the EU declaration of conformity,
- the product specification,
- selected material data,
- a report on a specific property,
- information needed for their own technical documentation.
The scope may also result from the commercial agreement.
Therefore, the entire technical dossier should not be automatically sent to every customer, especially if it contains confidential information whose provision is not required by the PPWR in such a relationship.
When does a business partner have stronger grounds to request documentation?
Article 16 is of particular importance.
A supplier of packaging or packaging material must provide the manufacturer with the information and documentation needed to demonstrate conformity.
Therefore, if you sell a component to another entity that will be responsible for assessing the final packaging, it may need much more from you than merely a general statement:
“the product complies with the PPWR”.
It may need specific data that will later be included in its own technical documentation.
The declaration and technical documentation from the importer’s perspective
The importer has a different relationship with both documents than the manufacturer.
Before placing packaging on the market, the importer should verify, among other things, whether the manufacturer has carried out the appropriate conformity assessment procedure and drawn up the technical documentation.
The importer should also retain a copy of the EU declaration of conformity for the appropriate period and ensure that the technical documentation can be made available to the competent authorities.
| Document | Importer’s role |
|---|---|
| EU declaration of conformity | Keeps a copy for the appropriate period |
| Technical documentation | Ensures that it can be made available to the competent authorities |
Therefore, the importer should not limit the process to obtaining a one-page “PPWR certificate” from a factory outside the EU.
How long should PPWR declarations and technical documentation be retained?
PPWR applies the same basic retention period to both documents, depending on the type of packaging.
| Type of packaging | Technical documentation | EU declaration of conformity |
|---|---|---|
| Single-use | 5 years | 5 years |
| Reusable | 10 years | 10 years |
The period should be calculated in accordance with the rules on placing packaging on the market.
A new version of the documentation should not remove the history of an older variant that was previously on the market.
A change to the packaging may require the documentation and declaration to be updated
Technical documentation is not a static archive created once and for all.
If a change may affect compliance, the relevant requirements must be reassessed.
This may include changes to:
- material,
- basis weight,
- barrier layer,
- label,
- adhesive,
- closure,
- supplier,
- recycled content,
- design.
If the assessment result or identification of the packaging covered by the declaration changes, the need to update the declaration of conformity must also be assessed.
Documentation and the declaration should be versioned together
The safest system links:
packaging version → technical documentation version → declaration version.
For example:
| Packaging | Documentation | Declaration | Status |
|---|---|---|---|
| BX-01 V1 | TD-01 rev. 1 | DoC-01 rev. 1 | Archived |
| BX-01 V2 | TD-01 rev. 2 | DoC-01 rev. 2 | Archived |
| BX-01 V3 | TD-01 rev. 3 | DoC-01 rev. 3 | Current |
This makes it possible to determine during an inspection which technical basis corresponded to the declaration applicable at a given time.
Can one report form part of the documentation for several packaging items?
Yes, if its representativeness for all covered variants can be demonstrated.
For example, one material report may be used for many packaging items made to exactly the same specification.
There is no need to copy the report into each dossier if the system can correctly establish the relationship:
report → material → version → packaging items using the material.
Declarations, however, remain linked to the scope of the item for which the manufacturer has actually carried out the assessment.
PPWR declaration and documentation versus SKU – the number of files need not match the number of products
A commercial SKU is not automatically a PPWR documentation unit.
Dozens of products may use the same type of packaging.
On the other hand, one SKU may include several packaging components:
- bottle,
- cap,
- label,
- carton,
- outer carton.
Therefore, the system should distinguish between:
product / SKU → packaging types → versions → documentation → declarations.
What will the authority check: the declaration or the technical documentation?
Both elements may be relevant, but they answer different questions.
The declaration shows the formal outcome of the assessment.
The technical documentation, in turn, makes it possible to verify the basis for that outcome.
Example:
the declaration states that conformity with the relevant requirement concerning substances has been demonstrated.
The authority may then expect material showing:
- which specification was assessed,
- which method was applied,
- which report was used,
- whether the sample corresponded to the current version of the packaging.
This is precisely what is included in the technical documentation.
Can one declaration cover PPWR and other EU legislation?
Yes, Article 39 provides for the possibility of a single EU declaration of conformity where packaging is subject to several Union acts requiring such a declaration.
The document should then refer to the relevant Union legislation.
However, this does not automatically mean that one technical documentation will be identical for all regulations.
The company must still hold evidence appropriate to each obligation it declares.
Most common errors: declaration of conformity and technical documentation
- issuing a declaration without technical documentation;
- treating a supplier’s declaration as complete own documentation;
- attempting to include all laboratory reports in the declaration;
- no link between the declaration and a specific packaging version;
- a folder containing tests without information on which requirements they concern;
- overwriting old documentation after a material change;
- no analysis of the risk of non-compliance;
- no version control of the supplier’s specification;
- regarding a “PPWR certificate” as a substitute for both documents;
- automatically sending the full technical dossier to every customer;
- storing declarations and documentation in separate folders without links between them;
- assuming that a new declaration removes the obligation to archive the old version.
PPWR declaration and documentation – checklist
- Identify the correct packaging type.
- Determine its version.
- Identify the manufacturer.
- Determine the applicable requirements.
- Collect data and documents from suppliers.
- Carry out a risk analysis of non-compliance.
- Link each requirement to the relevant evidence.
- Record the standards and specifications applied.
- Keep reports and calculation results.
- Draw up the technical documentation in accordance with Annex VII.
- Carry out the conformity assessment procedure.
- Once conformity has been demonstrated, draw up the declaration in accordance with Annex VIII.
- Sign the declaration on behalf of the relevant manufacturer.
- Link the declaration to the version of the technical documentation.
- Record the period during which the version applies.
- Monitor changes to materials and design.
- Keep historical versions for the required period.
How do you manage declarations and technical documentation for multiple packaging items?
For a few packaging types, the relationship can be maintained manually.
With a larger portfolio, however, the problem is that:
- one supplier document concerns multiple packaging items,
- one report may form the basis for several assessments,
- one material change may affect multiple declarations,
- each type may have several historical versions.
The system should therefore treat the declaration as an outcome linked to a specific version of the documentation, rather than as an independent PDF.
The key relationship is:
material → supplier document → requirement → evidence → technical documentation → packaging type → declaration of conformity.
Declaration of conformity and technical documentation – the key difference
Technical documentation answers the question “why is the packaging compliant?”, while the EU declaration of conformity answers “who formally confirms that conformity has been demonstrated?”.
Documentation under Annex VII contains the technical basis for the assessment: description, materials, standards, calculations, test results and other evidence.
The declaration under Annex VIII is a much shorter formal document drawn up after the assessment has been completed.
One document does not replace the other.
The key process is:
data → evidence → technical documentation → conformity assessment → EU declaration of conformity → change control.
FAQ – PPWR declaration of conformity and technical documentation
What is the difference between a declaration of conformity and PPWR technical documentation?
Technical documentation contains evidence and analyses showing how compliance with the relevant PPWR requirements has been demonstrated. The EU declaration of conformity is a formal statement by the manufacturer, drawn up after the conformity assessment has been successfully completed.
Is the PPWR declaration of conformity alone sufficient?
Not for the manufacturer responsible for demonstrating conformity. The declaration should be based on technical documentation drawn up in accordance with Annex VII.
Do test reports need to be attached to the PPWR declaration?
There is no need to reproduce full laboratory reports in the declaration itself. Reports may form part of the technical documentation that forms the basis for the conformity assessment.
Must the customer receive the full PPWR technical documentation?</h3>
PPWR does not establish a general rule requiring the automatic provision of the full technical documentation set out in Annex VII to every customer. The scope of information provided within the supply chain depends on the roles of the parties, the relevant PPWR obligations and any contractual arrangements. </p> </div>
Who draws up the PPWR technical documentation and declaration of conformity?</h3>
The relevant manufacturer is responsible for the process. Before placing packaging on the market, the manufacturer draws up the technical documentation and carries out the relevant conformity assessment procedure and, once conformity has been demonstrated, draws up the EU declaration of conformity.
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