How to prepare PPWR documentation for an inspection?

What should the authority be able to reconstruct from PPWR documentation?

Good documentation makes it possible to answer several basic questions without guessing or reconstructing the history after the fact.

A PPWR inspection does not end with presenting the declaration of conformity

The EU declaration of conformity is the outcome of a process, not the full body of evidence.

If the document states that the packaging meets the relevant PPWR requirements, the company should be able to demonstrate the basis for that conclusion.

Therefore, the logical sequence should be as follows:

requirement → assessment method → evidence → result → technical documentation → declaration.

Reversing this sequence creates a typical problem: the declaration is signed, but during an inspection no one can find the document supporting one of the statements it contains.

PPWR inspection package – which documents should be ready?

There is no single identical “inspection file” for all packaging. The scope depends on the type of packaging and the applicable requirements.

However, a typical package should provide access at least to the following groups of data:

1. Start with clear packaging identification

The best laboratory report has little value if the company cannot demonstrate which packaging it concerned.

The inspection package should include data allowing one type and variant to be clearly distinguished from another.

It is worth retaining, among other things:

• an internal packaging code,
• the supplier’s product code,
• the trade name,
• the version or revision,
• dimensions,
• mass,
• intended use,
• a drawing or photograph,
• the date on which use of a given version began,
• the date on which its use ended.

In a company with several similar bottles, a statement that “the report concerns our 500 ml PET bottle” may be insufficient if there are three different preforms, two types of closure and several labels.

2. Establish the company’s role before presenting the documentation

The scope of documents and responsibilities depends on the company’s role.

The manufacturer is primarily responsible for drawing up the technical documentation, carrying out the appropriate conformity assessment and the EU declaration of conformity.

The importer has its own verification obligations and must ensure that the relevant documentation can be made available.

The distributor acts with due care and should not make packaging further available if it has reason to consider it non-compliant.

If an importer or distributor meets the conditions set out in Article 21, it may become subject to the obligations of the manufacturer.

During an inspection, a situation in which a company first presents a declaration as its own and then claims that another entity bears responsibility is highly problematic.

3. Technical documentation in accordance with Annex VII to the Regulation (EU) 2025/40 on packaging and packaging waste

Annex VII is the primary reference point when preparing packaging technical documentation.

The documentation should be prepared in a way that enables assessment of the packaging’s conformity with the relevant requirements.

In practice, it includes, among other things:

• a general description of the packaging and its intended use,
• the conceptual design and appropriate drawings,
• information on the materials of constituent parts,
• descriptions necessary for understanding the design and operation of the packaging,
• a list of relevant standards and specifications,
• a description of the solutions applied to meet the requirements, where the relevant standards have not been applied,
• relevant assessments concerning the requirements of Regulation (EU) 2025/40 on packaging and packaging waste,
• reports on the tests carried out.

The scope should correspond to the current legal framework. A requirement that will apply only in the future should not be presented as if it already required a final assessment under a methodology not yet in force.

4. Do not omit the analysis and assessment of the risk of non-compliance

Annex VII is not merely a checklist of technical documents. The documentation must include an analysis and assessment of the risk of non-compliance.

In practice, it is worth indicating:

• which requirements apply,
• what risk of non-fulfilment exists,
• what data are available,
• where additional testing or verification is needed,
• how the identified risk has been reduced.

Risk analysis is particularly useful when determining the scope of testing. Not every packaging item requires an identical set of tests, but the company should be able to justify why a particular item of evidence was sufficient.

5. Build a “PPWR requirement → evidence” matrix

One of the best tools for control is a simple requirements matrix.

Instead of storing a stack of independent files, the company indicates for each requirement:

• whether it applies,
• from when it applies,
• how it was assessed,
• which document constitutes the evidence,
• what the result is,
• who approved the assessment.

6. The material specification must correspond to the variant actually used

The specification is one of the key documents during an inspection.

The problem arises when a company has a technically correct document, but one relating to a different version of the material.

Check:

• material code,
• supplier name,
• revision number,
• effective date,
• composition,
• layers,
• mass or grammage,
• additional components.

If the supplier has changed the specification, the old version should remain in the archive for the period during which it was used.

7. Drawings and design documentation should show the assessed type

Annex VII provides for appropriate design information.

Depending on the packaging, this may include:

• technical drawings,
• die-cuts,
• layer diagrams,
• component lists,
• dimensions,
• component masses,
• method of joining,
• type of closure.

Design documentation does not have to mean disclosing every piece of information constituting the manufacturer’s know-how. However, it must make it possible to understand the design to the extent needed for conformity assessment.

8. Record which standards and specifications formed the basis for the assessment

Providing only the number of a standard without information on what it was applied to is of limited use during an inspection.

For each reference, it is worth recording:

• the number of the standard or specification,
• the version or date,
• the scope of application,
• which PPWR requirement it supports,
• whether it was applied in full or in part.

If no harmonised standard or common specification has been applied, the documentation should describe the solution used to demonstrate compliance with the requirement.

9. A test report must be traceable to the packaging

During an inspection, a folder labelled “tests” is not enough. You need to demonstrate why a specific report confirms a property of a specific packaging type.

Check in particular:

• sample identification,
• material code,
• manufacturer or supplier,
• test method,
• date,
• result,
• method limits,
• the sample’s conformity with the current version of the packaging.

If you apply one report to several variants, also retain the justification for why the result is representative of all those variants.

10. Supplier documents should form part of a controlled data flow

Article 16 requires suppliers of packaging and packaging materials to provide the manufacturer with the information and documentation needed to demonstrate conformity.

However, it is not enough to obtain a document once and never verify it again.

The procedure should specify:

• which documents are required,
• who verifies them,
• which material they are assigned to,
• how the version number is controlled,
• when the supplier must report a change,
• what is done when a document is no longer current.

Agreements with key suppliers should also regulate cooperation in responding to requests from authorities.

11. The EU declaration of conformity must correspond to the technical documentation

The declaration must not describe a product other than the one covered by the documentation on which it is based.

Before an inspection, check:

• identification of the subject of the declaration,
• manufacturer details,
• legal basis,
• references to the relevant requirements and specifications,
• date of issue,
• the signatory,
• document version.

Detailed reports do not need to be reproduced in the declaration. However, they must be included in the technical documentation and make it possible to substantiate the declaration made.

12. PPWR documentation should also cover control of production conformity

Annex VII bases the procedure on internal production control.

It is therefore not enough to demonstrate that one prototype was compliant. The manufacturer should take measures to ensure that production remains in conformity with the technical documentation and the relevant requirements.

Depending on the process, the following may be relevant:

• incoming material inspection,
• production tolerances,
• weight and dimensional inspection,
• verification of supplier changes,
• formulation control,
• drawing version control,
• handling of non-conforming products.

13. Change history is one of the most important documents during an inspection

The authority may examine packaging placed on the market previously, not only the version currently on the production line.

It is therefore advisable to maintain a change table for each type.

The modification date alone is not sufficient. It is also important to record whether the change affected the previous assessment.

14. The importer must be prepared for an inspection of the foreign manufacturer’s documents

The importer should not build its process on the assumption that documentation can only be obtained from the supplier after receiving a letter from the authority.

Before placing packaging on the market, the importer should verify the relevant elements of the compliance process.

The import system should contain:

• identification of the foreign manufacturer,
• a copy of the EU declaration of conformity,
• confirmation that technical documentation exists,
• an agreed method for its prompt provision,
• documents relating to the current version of the packaging,
• contact details for the responsible person at the supplier.

Article 18 requires the importer to provide the competent authority, upon a reasoned request, with the information and documentation necessary to demonstrate compliance.

15. An inspection may also concern traceability under Article 22

The Regulation (EU) 2025/40 on packaging and packaging waste requires not only technical evidence, but also the ability to reconstruct the relevant relationships in the supply chain.

The company should be able to identify the relevant economic operators:

• from whom it received the packaging or product in packaging,
• to whom it subsequently supplied such packaging or product.

This information is subject to the relevant retention periods provided for in Article 22.

In practice, it is useful to link purchasing and sales data to the packaging code and the period during which a particular version was used.

16. Does the PPWR always allow only 10 days to provide documentation?

“10 days” should not be presented as a single universal rule applying to every operator and every request for documentation.

The PPWR requires manufacturers and importers to provide competent authorities with the information and documentation necessary to demonstrate compliance upon an appropriate request.

However, the specific provision on 10 days from receipt of the request is contained in Article 17, in the list of tasks that may be entrusted to an authorised representative.

This includes making the relevant documents available at the request of the competent national authority within 10 days of receiving such a request.

In operational terms, the company should in any case be prepared to provide documents very quickly. If compiling the package takes several weeks, there is a problem regardless of the formal deadline in a given request.

17. Documentation for the authority must be in an understandable language

Several PPWR provisions on cooperation and documentation require information to be provided in a language or languages easily understood by the relevant entity or authority.

It is therefore not advisable to assume that a 300-page technical report in Chinese will automatically be sufficient during an inspection in the EU.

For imports, it is worth agreeing with the supplier at the contract stage:

• the language in which documents are received,
• who is responsible for translation,
• which parts must be available quickly,
• how consistency between the translated version and the original is maintained.

18. What should you do if documents are missing during an internal review?

A missing document should be treated as a gap to be closed before an external inspection, not as a reason to create a fictitious annex.

The procedure may be as follows:

1. Identify precisely which requirement the gap concerns.
2. Check whether the evidence is actually required.
3. Verify the supplier documentation.
4. Request the missing information under Article 16, where applicable.
5. Check whether other reliable evidence can be used.
6. If testing is needed, commission it for the appropriate sample.
7. Do not finalise a positive assessment without an adequate basis.

A particularly risky situation arises where the declaration has already been signed and the company discovers only later that it lacks evidence for one of the key claims.

19. What should you do if an internal review reveals non-compliance?

The PPWR provides for obligations concerning action in relation to packaging that is not compliant.

The company should not “fix” the problem by removing an unfavourable report from the folder.

The following should be assessed, among other things:

• the extent of the non-compliance,
• which packaging and batches it concerns,
• whether the packaging has already been placed on the market,
• what corrective action is needed,
• whether further making available needs to be restricted,
• whether communication with the competent authorities is necessary.

The record of corrective action should also be retained as part of the compliance system.

20. Carry out an internal PPWR inspection simulation

The best audit is not asking employees “do we have the documents?”, but identifying a random package and attempting to reconstruct its entire history.

Example scenario:

“Please provide the documentation for carton BX-017 in the version used in November 2027.”

The team should establish:

1. which revision was applicable at that time,
2. who the supplier was,
3. which materials were used,
4. which PPWR requirements applied at that time,
5. how the assessment was carried out,
6. which reports constituted the evidence,
7. which declaration was applicable,
8. whether subsequent changes were not mistakenly assigned to the old version.

If the process works for a randomly selected older package, the company is much better prepared for an actual request from an authority.

21. What might a digital PPWR inspection folder look like?

For a small number of packaging items, a simple folder structure may be sufficient.

Example structure:

BX-017 / V3 / 01_ID / 02_SPECIFICATIONS / 03_DRAWINGS / 04_SUPPLIERS / 05_TESTING / 06_ASSESSMENTS / 07_DECLARATION / 08_CHANGES

With a larger number of packaging items, however, the folder structure begins to cause file duplication.

The same material report may apply to 40 packaging types. Copying it 40 times creates a risk that later only some copies will be updated.

In this case, a relational system is better, where one source document can be linked to multiple packaging items and specific periods of validity.

PPWR documentation for inspection – readiness checklist

1. Does each packaging item have a unique code?
2. Do we know the current and historical versions?
3. Has the manufacturer’s role been correctly determined?
4. Is there technical documentation compliant with Annex VII?
5. Does the documentation include an analysis of the risk of non-compliance?
6. Do we have a matrix of the requirements of Articles 5–12?
7. Does each applicable requirement have evidence?
8. Can reports be linked to the relevant sample?
9. Are supplier specifications up to date?
10. Do we retain previous revisions?
11. Do we know the basis for the standards and specifications applied?
12. Does the declaration of conformity correspond to the documentation?
13. Does production remain under compliance control?
14. Is the change history documented?
15. Can the importer quickly obtain the documentation of a non-EU manufacturer?
16. Is the traceability information under Article 22 available?
17. Are the documents in a language appropriate for the competent authority?
18. Does the company have a procedure for responding to non-compliance?
19. Has a trial inspection been carried out for a randomly selected packaging item?

Most common errors when preparing for a PPWR inspection

• treating the declaration of conformity as the only document required;
• no identification of the packaging version;
• reports relating to variants other than the one currently used;
• no analysis of the risk of non-compliance;
• no matrix of requirements and evidence;
• outdated supplier specifications;
• overwriting old documents with new versions;
• no information about a change of supplier;
• storing evidence exclusively in employees’ email accounts;
• no control of series production against the documentation;
• assuming that documentation from a non-EU supplier can only be obtained after the inspection;
• confusing the role of manufacturer and EPR producer;
• automatically presenting 10 days as the universal deadline for every PPWR request;
• no procedure for corrective action after non-compliance is detected.

How can preparation of PPWR documentation for inspection be automated?

For a few packaging items, organised documentation is sufficient.

For hundreds of types, the problem becomes not the storage of files itself, but the relationships between them.

The system should allow you to enter a packaging code and immediately display the current and historical versions of the documentation, evidence and declarations.

Particularly useful are:

• packaging versioning,
• a central document repository,
• linking documents to PPWR requirements,
• control of supplier dates and versions,
• alerts following a material change,
• approval history,
• documentation completeness status,
• quick export of the inspection package.

How to prepare your company for a PPWR inspection – key conclusions

Readiness for a PPWR inspection is not about having a large number of documents. It is about being able to demonstrate the compliance of a specific packaging item through a consistent and up-to-date chain of evidence.

For each type and version, the company should be able to identify the applicable requirements, how they were assessed, the documents constituting evidence and the declaration drawn up on that basis.

The history of changes is particularly important. An inspection may concern a version used several years earlier, so a new specification should not overwrite the previous one.

The best system test is simple:

select a random packaging item and an earlier date, then try to reconstruct all documentation without the assistance of the people who originally managed the project.

If this is possible, the company is much closer to genuine inspection readiness.

FAQ – PPWR documentation during an inspection

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, technical documentation, cooperation with authorities and measures in cases of non-compliance,
• Article 16 – obligations of suppliers concerning the provision of information and documentation,
• Article 17 – authorised representative, including the obligation to make relevant documents available within 10 days, where such a task is covered by the mandate,
• Article 18 – obligations of importers and the provision of information and documentation to authorities,
• Article 19 – obligations of distributors,
• Article 21 – cases where the obligations of the manufacturer are assumed by an importer or distributor,
• Article 22 – identification of economic operators,
• Article 38 – conformity assessment procedure,
• Article 39 – EU declaration of conformity,
• Annex VII – internal production control and technical documentation,
• Annex VIII – structure of the EU declaration of conformity.