How long should you retain the PPWR declaration and documentation?

How long should technical documentation and the PPWR declaration be retained?

Article 15 of the PPWR provides for two basic retention periods depending on the nature of the packaging.

This is the basic rule worth incorporating into the PPWR document retention procedure.

However, this table should not be treated as automatic permission to delete all files five years after the first declaration was created. For products that remain on the market for a long time, subsequent instances of placing packaging on the market and the history of individual versions must also be taken into account.

From when should the 5 or 10 years for retaining PPWR documentation be counted?

For the manufacturer’s technical documentation and declaration, the reference point is the placing of the packaging on the market, not the date the PDF file was created, the date the test was carried out or the date the contract with the supplier was signed.

This distinction is very important.

Documentation may be prepared in June, the declaration signed in July, and the first packaging covered by that assessment placed on the market only in September.

Therefore, a retention system should not be built solely around the field:

“document creation date”.

The system should also record the period during which a given packaging version was actually placed on the market.

What does “placing on the market” mean under the PPWR?

Placing on the market means the first making available of packaging on the Union market.

The PPWR distinguishes the first placing of packaging on the market from its subsequent making available by further operators in the chain.

This is relevant when calculating retention periods, as a new five-year period should not automatically be counted each time the same unit is resold by a wholesaler or retailer.

On the other hand, in serial production, subsequent units of a given type may be placed on the market over a long period. Therefore, a practical archiving system should take account of the applicability history of a specific version, rather than only the date when the project was first launched.

What exactly should a PPWR manufacturer retain?

The obligation does not apply solely to the final declaration of conformity. The manufacturer should also retain the technical documentation forming the basis for demonstrating conformity.

In practice, for a specific packaging type, the archive may include:

• the EU declaration of conformity,
• a description and identification of the packaging type,
• the technical specification,
• drawings and design documentation,
• information on material composition,
• documents relating to components,
• test reports,
• calculations and assessment results,
• information on the standards and specifications applied,
• documents received from suppliers,
• assessments relating to the applicable PPWR requirements,
• a history of changes affecting conformity.

Not all of these documents need to be provided in the same form for every packaging item. The scope should correspond to the specific type and the requirements applicable to it.

Annex VII to the PPWR – what should not be separated from the technical documentation?

Annex VII describes the conformity assessment procedure and the scope of technical documentation.

From an archiving perspective, the most important point is the ability to reconstruct the entire assessment process.

After several years, the company should be able to answer:

• which packaging item the report concerned,
• which material version was used at the time,
• which requirement was assessed,
• which method was used,
• what the result was,
• who approved the assessment,
• which declaration was drawn up on that basis.

A folder containing several dozen PDF reports without links to the packaging type and version does not provide such traceability.

Do old versions of declarations of conformity need to be retained?

Yes – if an older declaration concerned packaging that has already been placed on the market and is still within the required retention period, it should not be deleted merely because a new version has been prepared.

Let us imagine:

• packaging version V1 applies in 2026–2028,
• from March 2028, the company changes the material and moves to V2,
• a new assessment was carried out and a new declaration issued for V2.

The V1 documentation may still be required to demonstrate the conformity of packaging placed on the market earlier.

Replacing the V1 declaration with the V2 document does not mean that the history of the earlier variant ceases to exist.

Is a PPWR declaration „valid for 5 years”?

The retention period should not be interpreted in this way.

Five or ten years is a documentation retention obligation, not a guaranteed period during which the declaration remains unchanged.

The declaration may need to be updated much sooner if, for example, there is a change to:

• the packaging material,
• the design,
• the coating,
• a label relevant to the assessment,
• the closure,
• the supplier and material properties,
• the standard or specification forming the basis of the assessment,
• a PPWR requirement applicable to the packaging.

There may therefore be a declaration that needs to be replaced after a few months, while its old version must still be archived for the required period.

How long must an importer retain the PPWR declaration of conformity?

The importer has its own obligation concerning a copy of the EU declaration of conformity.

Article 18 provides for the importer to keep a copy of the declaration for the relevant period:

• 5 years for single-use packaging,
• 10 years for reusable packaging.

The importer should also ensure that the technical documentation can be made available to the competent authorities.

This is an important distinction: the importer does not have to be the entity that originally drew up all the technical documentation if it is not the manufacturer. However, it must organise the process so that the authority does not hear:

“The documents are with the manufacturer in China and we do not know whether they can be obtained.”

Must the importer hold the full technical documentation?

PPWR distinguishes between keeping a copy of the declaration and ensuring the availability of the technical documentation.

It is therefore advisable to distinguish the following in the import procedure:

From a risk management perspective, the importer may of course decide to keep a larger part of the documentation in its own system, even if certain materials formally remain with the manufacturer.

Can an authorised representative keep PPWR documentation?

Article 17 allows the manufacturer to appoint an authorised representative by written mandate.

One of the tasks entrusted to the representative may be to keep the EU declaration of conformity and technical documentation at the disposal of market surveillance authorities for the required period.

However, keeping and making documents available should not be confused with the obligation to draw them up in the first place.

Drawing up the technical documentation remains part of the manufacturer’s obligations and cannot simply be “shifted” to the representative as a way of avoiding responsibility.

Article 22 PPWR – 5 and 10 years also apply to traceability

Keeping technical documentation is not the only PPWR retention obligation.

Article 22 requires economic operators to be able, at the request of market surveillance authorities, to identify the relevant actors in the supply chain.

This includes, among other things, being able to determine:

• who supplied the company with the packaging or packaged product concerned,
• to whom the company subsequently supplied such packaging or product.

For identification information, PPWR also applies the following periods:

• 5 years for single-use packaging,
• 10 years for reusable packaging.

However, this is a separate obligation from keeping technical documentation.

Technical documentation and traceability – what should not be confused?

A company may have an excellent laboratory report and still face issues during an inspection if it cannot identify which material variant the report concerned.

Changing supplier is not a reason to delete old documentation

If the previous supplier supplied packaging that was placed on the market, documentation relating to those variants may still be needed.

Example:

• until December 2027, cardboard is supplied by company A,
• from January 2028, the same format is supplied by company B,
• the new material has a slightly different grammage and specification.

In this situation, it is sensible to create a new packaging revision and retain company A’s documents in the historical version, rather than replace them with company B’s documents.

During a subsequent inspection, it may be necessary to demonstrate the conformity of a batch placed on the market while the first supplier was still in place.

Changing the material or design – a new assessment does not erase the old one

If a change may affect conformity, Article 15 requires it to be taken into account in the system for ensuring conformity of production.

In practice, it is therefore worth maintaining documentation according to the following model:

packaging type → version → period of validity → documentation → declaration.

For example:

This means you do not have to guess later which report related to which packaging batch.

How should the retention period be calculated when the same packaging type is sold over several years?

This is one of the practical issues that the phrase “5 years from placing on the market” alone does not resolve.

If the same packaging version is placed on the market not once, but regularly over three years, the company should not set documentation to be automatically deleted five years after the first day of sale.

In practice, a safe management model involves recording for each version:

• the date on which placing on the market began,
• the date on which placing of that version on the market ended,
• the documentation retention deadline.

This ensures that documents relating to units placed on the market later are not deleted too early.

Can PPWR documentation be deleted after sales end?

Not immediately.

The end of sales or the end of production does not automatically end the archiving obligation for packaging that has already been placed on the market.

The documentation should remain available for the required period.

This is particularly important where:

• the product is still held by distributors,
• a complaint or investigation is ongoing,
• an authority is examining an older batch,
• the supplier has ceased trading,
• the company has changed its IT system.

System migration or the end of cooperation with a supplier must not result in the loss of required documentation.

Must PPWR documentation be kept on paper?

PPWR does not require the creation of a warehouse of ring binders as an end in itself.

In practice, documentation may be managed electronically, provided that it remains available, legible, capable of unambiguous attribution and protected against uncontrolled alteration or loss.

A digital system also has several advantages:

• easier version control,
• change history,
• access control,
• quick search by packaging code,
• automatic retention periods,
• backups,
• linking reports to the declaration.

However, a risk arises where files are stored only in employees’ private email inboxes.

How should PPWR files be named so that, after five years, you still know what they relate to?

The name:

“declaration_final_final2.pdf”

is not a good version control system.

A practical file name may include:

packaging code + version + document type + date.

For example:

BX-01_V3_EU-DoC_2029-12-01.pdf

or:

BX-01_V3_TestCompression_LAB123_2029-10-14.pdf

Better still is to store this information as metadata in the system, so that changing a file name does not break the relationships between documents.

What should the version history of a PPWR declaration contain?

For each change, it is worth keeping at least:

• the declaration version number,
• its issue date,
• the packaging type,
• the packaging version,
• the reason for the update,
• the approving person,
• the linked version of the technical documentation,
• the date use commenced,
• the withdrawal date of the previous version.

This makes it possible to demonstrate unambiguously which declaration applied to packaging placed on the market on a given date.

Keeping PPWR documentation only makes sense if it can be found quickly

A market surveillance authority does not necessarily need to be interested in whether a company “has somewhere” the relevant report. What matters is being able to provide the correct material relating to the specified packaging.

PPWR provides for an obligation to cooperate with authorities and to provide the required information and documentation.

In relevant cases, the rules also provide for a short 10-day deadline to provide the required information or documents.

Therefore, when designing the archive, it is worth testing a simple scenario:

“The authority provides code BX-01, a batch from September 2027 and asks for the basis of the declaration. Can we establish the correct version of the documentation within a few minutes?”

What should a document package that can be reconstructed during an inspection look like?

Do you need to retain separate documentation for each SKU?

Such a rule cannot be derived solely from the number of SKUs.

The key factors are the packaging type and the scope of the conformity assessment.

Several SKUs may use the same packaging type. On the other hand, what appears to be the same carton may exist in several material versions requiring separate traceability.

The retention system should therefore be based on the relationship:

SKU → packaging type → version → documentation → declaration.

This avoids unnecessarily copying the same report into hundreds of SKU folders.

How should PPWR documentation be archived for hundreds of packaging types?

With a small number of documents, a well-organised folder structure can be used.

With hundreds or thousands of variants, however, relationships become the issue.

One report may concern:

• one material,
• several packaging types,
• a specific supplier version,
• a defined period of time.

Copying the same file into 40 folders later creates a problem: which copy is current?

A better model is:

one source document → relationships to multiple packaging types → record of the version and period of validity.

How do you create a PPWR documentation retention policy?

A good procedure should not be limited to the statement “we retain documents for 5 or 10 years”.

It should specify:

1. which documents are subject to archiving,
2. who is responsible for recording them,
3. how the packaging type is identified,
4. how versions are labelled,
5. how the start and end dates of use of a version are recorded,
6. how the retention period is calculated,
7. who may amend documents,
8. who approves a new version,
9. how backups are created,
10. what the procedure for providing documentation to the authority is,
11. when a document may be permanently deleted.

Is it worth retaining documentation longer than the required 5 or 10 years?

Regulation (EU) 2025/40 on packaging and packaging waste specifies the required retention periods, but the company’s internal policy may provide for longer retention where there is a business or legal justification.

Relevant factors may include:

• product lifetime,
• long-term customer contracts,
• complaints procedures,
• other sectoral legislation,
• internal quality rules,
• ongoing inspection proceedings or a dispute.

However, a longer period resulting from company procedure should not be presented as an additional obligation under the PPWR itself.

Most common errors in retaining PPWR documentation

• calculating 5 years from the date the declaration was created rather than from the relevant market event;
• deleting the old version after issuing a new declaration;
• treating 5 years as the declaration’s “validity” period;
• retaining only the final PDF without supporting evidence;
• no information on which packaging version the report concerns;
• overwriting an old file with a new specification;
• no supplier change history;
• no link between documents and the date from which the version applies;
• storing files only in a former employee’s email inbox;
• no copy of the declaration held by the importer;
• confusing technical documentation with the identification information under Article 22;
• no procedure for quickly retrieving documentation during an inspection.

Retaining PPWR documentation – checklist

1. Determine whether the packaging is single-use or reusable.
2. Assign the applicable 5- or 10-year period.
3. Record the date or period during which the relevant version was placed on the market.
4. Retain the EU declaration of conformity.
5. Retain the technical documentation on which it is based.
6. Link reports and supplier data to the specific version.
7. Do not delete old documentation after a product change.
8. Record the end date of use for each revision.
9. Monitor the importer’s obligations concerning copies of the declaration.
10. Retain the data required for traceability under Article 22.
11. Implement backups.
12. Limit the ability to overwrite approved documents.
13. Test whether documentation can be found by code and date.
14. Assign responsibility for the final deletion of documents after the retention period.

When is it worth automating the retention of PPWR documentation?

For a few packaging items, manual archiving is possible.

The problem arises with a larger portfolio, where one type has several versions, several suppliers and many reports applicable during different periods.

The system’s greatest value is then not file storage itself, but the ability to reconstruct the compliance history.

It should be possible to navigate through:

packaging type → version → period of use → supplier → evidence → technical documentation → declaration → retention period.

How long to retain PPWR declarations and documentation – key conclusions

For single-use packaging, the basic retention period for technical documentation and the EU declaration of conformity is 5 years. For reusable packaging – 10 years.

The reference point is the placing of the packaging on the market. Therefore, the archiving system should know not only the document creation date, but also the packaging version and the period of its actual use.

A new declaration does not erase the history of the previous one. A change of supplier, material or design may require a new assessment, but older documents should remain available for the packaging to which they previously related.

In practice, the safest model is:

packaging → version → period of placing on the market → documentation → declaration → archive → retention period.

FAQ – retention of PPWR declarations and documentation

Sources

Legal basis: Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste – EUR-Lex

The article uses, in particular:

• Article 15 – obligations of manufacturers, including retention of technical documentation and EU declarations of conformity,
• Article 17 – authorised representative and the possibility of keeping documents available to authorities,
• Article 18 – obligations of importers, including retention of a copy of the declaration of conformity and ensuring the availability of documentation,
• Article 22 – identification of economic operators and the retention period for supply chain information,
• Article 38 – conformity assessment procedure,
• Article 39 – EU declaration of conformity,
• Annex VII – technical documentation and conformity assessment procedure,
• Annex VIII – structure of the EU declaration of conformity.