PPWR technical documentation – Annex VII checklist

PPWR Annex VII – what must technical documentation contain?

Annex VII describes the conformity assessment procedure based on internal production control.

The section on technical documentation itself sets out six basic groups of information designated by letters (a) to (f), as well as an obligation to analyse and assess the risk of non-compliance.

Internal production control – what is Annex VII based on?

The procedure provided for in Annex VII is based on internal production control.

This means that the relevant manufacturer:

• draws up technical documentation,
• assesses compliance with the applicable requirements,
• takes measures to ensure that the production process complies with the documentation,
• after demonstrating compliance, draws up the EU declaration of conformity.

For ordinary packaging, the PPWR does not establish a general model under which an external “PPWR certificate” must be obtained before each declaration.

The burden of demonstrating compliance therefore rests primarily on the quality of your own technical dossier.

PPWR technical documentation – complete dossier structure

In practice, a well-structured dossier may be more extensive than the literal six points of Annex VII, as the relationships between documents must also be retained.

The practical structure should include:

1. identification of the packaging type,
2. definition of its intended purpose,
3. identification of the relevant manufacturer,
4. the current design version,
5. drawings and design data,
6. a list of components and materials,
7. supplier specifications,
8. a PPWR requirements matrix,
9. an analysis of the risk of non-compliance,
10. applied standards and specifications,
11. assessments required for the relevant regulatory stage,
12. test reports,
13. calculation results and functional test results,
14. production conformity control,
15. change history,
16. the related EU declaration of conformity.

Analysis and assessment of the risk of non-compliance – a mandatory element of Annex VII

One of the most frequently overlooked elements is the analysis and assessment of the risk of non-compliance.

A complete set of drawings, specifications and reports alone does not yet demonstrate whether the company has consciously identified the requirements and risks.

A practical matrix may look like this:

The analysis does not need to be a complex scoring system. However, it must make it possible to trace why a given requirement was deemed applicable or not and what evidence was used.

Point (a) – general description of the packaging and its intended purpose

The first element should make it possible to understand what the documentation actually covers.

In practice, it is worth recording:

• the internal packaging type code,
• the technical name,
• the type of packaging,
• the function,
• the intended purpose,
• whether it is single-use or reusable,
• whether it is intended for food contact, where relevant,
• the product or product category for which it is used,
• the packaging version.

Example:

“Corrugated cardboard transport box, code BX-017-V3, intended for the single-use dispatch of cosmetic products in the e-commerce channel.”

Such a description is much more useful than simply:

“box”.

Point (b) – design, drawings and materials of constituent parts

The second set of data describes the packaging construction.

Depending on the type, the following may be needed:

• technical drawings,
• die-cut patterns,
• layer diagrams,
• dimensions,
• mass of components,
• list of components,
• material of each component,
• coatings and barriers,
• labels,
• adhesives,
• closures,
• inks or other elements relevant to the assessment.

For multi-material packaging, it is particularly important to link material information to the actual construction.

Packaging bill of materials – a practical BOM for PPWR

Good practice is to create a controlled list of components.

Such a BOM later makes it possible to quickly determine which declarations and assessments require review when one material changes.

Point (c) – explanations required to understand the design and operation

Drawings alone do not always explain the function of the packaging.

Annex VII therefore provides for descriptions and explanations required to understand the relevant drawings, diagrams and the operation or use of the packaging.

These may include, for example:

• a description of how the carton is assembled,
• a description of how the closure operates,
• the function of the barrier layer,
• the function of the protective element,
• a description of the filling method,
• a description of the reuse system,
• conditions for correct use.

The explanation should be as detailed as required to understand the conformity assessment – the aim is not to create instructions for use for every simple envelope.

Point (d) – harmonised standards and common specifications

Annex VII requires the identification of harmonised standards, common specifications or other relevant technical specifications used in the assessment.

If a standard has been applied in part, the documentation should identify the relevant parts.

For each item, it is worth recording:

• document number,
• version or year,
• scope of application,
• the PPWR requirement to which it relates,
• whether it has been applied in full or in part.

There is no benefit in creating a long list of standards solely to make the documentation appear more professional.

What should you do if there is no relevant harmonised standard for a requirement?

The absence of a standard does not automatically exempt you from the obligation to demonstrate conformity.

Annex VII then provides for a description of the solutions applied to meet the relevant requirements.

The documentation may therefore identify:

• another appropriate technical specification,
• an industry method,
• a test method,
• a design calculation,
• an internal validation procedure,
• a combination of several items of evidence.

However, it must be demonstrated why the given solution genuinely enables the relevant PPWR requirement to be assessed.

Point (e) – qualitative description of assessments under Articles 6, 10 and 11 of the PPWR

Annex VII lists a qualitative description of assessments carried out pursuant to Articles 6, 10 and 11.

They correspond to the following areas:

• Article 6 – packaging recyclability,
• Article 10 – packaging minimisation,
• Article 11 – requirements for reusable packaging.

However, the correct timing approach is important.

Documentation should reflect the requirements applicable to the specific packaging at the relevant time.

In 2026, a company should not pretend that it has carried out a final assessment based on criteria that the Commission has not yet introduced or that, under the PPWR, will apply later.

How should recyclability under Article 6 be documented?

Article 6 provides for the gradual implementation of recyclability criteria, including design for recycling and subsequent recycling at scale.

Before the relevant final methodology applies, it is nevertheless worth collecting the design data needed for the subsequent assessment.

This may include:

• main material,
• proportions of individual materials,
• type of label,
• adhesive,
• closure,
• coatings,
• colourants,
• elements that may affect sorting or recycling.

Once the relevant criteria and methods become applicable, this part of the dossier should be updated with the result of the appropriate assessment.

How should minimisation under Article 10 be documented?

The minimisation assessment should show why the packaging weight and volume are justified by its functionality.

The following may be needed:

• packaging weight,
• dimensions,
• analysis of alternative options,
• required strength,
• compression or drop tests,
• barrier requirements,
• product safety,
• logistical conditions,
• other relevant functionality criteria.

The PPWR does not establish a single rule that every package must be reduced by a specified percentage.

The documentation must demonstrate the justification for the selected design in accordance with the requirements applicable at the relevant stage.

How should reusable packaging under Article 11 be documented?

If packaging is declared reusable, the documentation should support the assessment of the characteristics enabling its successive rotations.

Relevant factors may include:

• design intended for multiple use,
• mechanical strength,
• emptiability,
• cleaning or preparation for reuse,
• safety of successive cycles,
• a system enabling actual reuse.

If the packaging is single-use, the absence of applicability of the relevant Article 11 requirements simply needs to be correctly determined, rather than creating an artificial reuse assessment.

Point (f) – test reports

Test reports form part of the documentation where they have been used as evidence in the assessment procedure.

These may include, for example:

• tests concerning restricted substances,
• PFAS analyses,
• material testing,
• strength tests,
• leak-tightness tests,
• barrier testing,
• other tests needed to demonstrate a specific property.

Each report should be traceable to:

material → version → requirement → assessed packaging.

Does every PPWR dossier have to contain a full package of laboratory tests?

There is no single universal set of laboratory tests mandatory for all packaging.

The scope of evidence depends on:

• the material,
• the intended use,
• the applicable requirements,
• available supplier data,
• risk analysis,
• the relevant methods and standards.

If a requirement can be reliably demonstrated by appropriate material documentation or calculation, an arbitrary additional test does not automatically increase conformity.

On the other hand, where the available information does not allow a significant gap to be closed, testing may be essential evidence.

Heavy metals, PFAS and other substances – where should evidence be kept?

Evidence concerning Article 5 should form part of the technical basis for the assessment.

Depending on the packaging, it may include:

• raw material specifications,
• data on lead, cadmium, mercury and hexavalent chromium,
• laboratory reports,
• data on the composition of coatings, inks and adhesives,
• for food packaging – material needed to assess PFAS restrictions.

There is no need to copy all results into the EU declaration of conformity. The technical documentation should contain the detailed evidential basis.

Supplier documents – an important element, but not the entire dossier

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

This may include:

• material specifications,
• composition,
• layer data,
• test reports,
• data concerning substances,
• information on recycled content,
• drawings or component specifications.

However, this does not mean that every supplier must provide every customer with the complete technical documentation for the final packaging under Annex VII.

The supplier provides the information needed by the manufacturer. The manufacturer uses it to build the dossier for the final type, for which it is responsible.

Annex VII requires not only documents, but also production control

The conformity assessment cannot concern one ideal prototype if serial production later deviates from the approved design.

The production section requires the manufacturer to take all necessary measures to ensure that the manufacturing process and its monitoring guarantee the conformity of the manufactured packaging with the technical documentation and the relevant requirements.

In practice, this may mean controlling:

• incoming raw materials,
• material codes,
• production tolerances,
• basis weight,
• mass,
• dimensions,
• formulation,
• drawing version,
• supplier changes.

A change in material or design may require reassessment

The technical documentation must correspond to the actual packaging, not its historical version.

Changes requiring particular assessment include:

• new supplier,
• new material,
• change in basis weight,
• change in colourant,
• change in adhesive,
• new label,
• different coating,
• change in recycled content,
• change in closure,
• change in geometry.

Not every change automatically requires the entire set of tests to be repeated.

It is necessary to establish which previous conclusions may be affected by it.

How should PPWR technical documentation be versioned?

The safest model is:

packaging type → revision → validity period → documentation → declaration.

Old documentation should not be overwritten if it relates to packaging previously placed on the market and is still within the required retention period.

PPWR technical documentation and SKU – does every SKU need a separate file?

PPWR does not automatically impose a “one SKU = one dossier” rule.

The unit of assessment is a properly defined packaging type.

Dozens of SKUs may use exactly the same packaging.

At the same time, one SKU may include:

• a bottle,
• a cap,
• a label,
• a carton,
• a transport carton.

Therefore, the data system should support the relationship:

SKU → packaging types → packaging versions → technical documentation.

Who prepares PPWR technical documentation?

The obligation to prepare technical documentation lies with the relevant manufacturer.

In practice, many elements may be prepared by:

• the design department,
• R&D,
• quality,
• laboratories,
• material suppliers,
• external specialists.

However, this does not change the regulatory responsibility of the relevant manufacturer for the completeness and correctness of the process.

Can an authorised representative prepare documentation on behalf of the manufacturer?

Article 17 limits the possibility of transferring this obligation to an authorised representative.

A representative appointed under a written mandate may carry out specified tasks, for example keeping documents available to the authorities and cooperating with them.

However, preparing technical documentation remains one of the manufacturer’s core obligations and cannot simply be transferred to the representative.

This does not mean that advisers or laboratories cannot be used. It means that outsourcing technical work does not remove the manufacturer’s responsibility.

What is the importer’s role in relation to technical documentation?

An importer does not automatically draw up its own Annex VII merely because it imports packaging.

Before placing packaging from a third country on the market, it should nevertheless verify, inter alia, whether the manufacturer has:

• carried out the appropriate conformity assessment procedure,
• drawn up the technical documentation,
• drawn up the appropriate EU declaration of conformity.

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

Therefore, the model:

“the factory in China has documents, but we do not know which ones”

is poor preparation for import.

How long should PPWR technical documentation be retained?

The period depends on the type of packaging.

The period should be assessed in relation to the rules governing the placing of packaging on the market.

The same retention period applies to the relevant EU declaration of conformity retained by the manufacturer.

Does every manufacturer have exactly 10 days to provide the documentation?

This should not be presented as a single universal rule for all PPWR documentation requests.

The manufacturer and importer are required to cooperate with the competent authorities and provide the required information and documentation within the scope of their obligations.

However, the specific provision on 10 days from receipt of the request appears in Article 17 in relation to the relevant task of the authorised representative.

Therefore, the statement:

“PPWR always gives every company exactly 10 days for the entire dossier”

is an excessive simplification.

Example of PPWR technical documentation for a simple carton

For the fictional BX-017 transport carton, the dossier may look as follows:

This is not a form required by the PPWR, but a practical way to map the obligations of Annex VII.

How should you organise the PPWR technical documentation folder?

For a small number of packaging items, a well-designed folder structure may be sufficient:

BX-017 / V3 / IDENTIFICATION / DESIGN / MATERIALS / REQUIREMENTS / RISK / STANDARDS / TESTING / ASSESSMENTS / PRODUCTION / DECLARATION / CHANGES

At a larger scale, however, a relational model is better.

One material report may apply to 50 packaging items. Copying it into 50 folders creates a versioning problem.

A better relationship:

source document → material → version → requirement → all packaging items using the material.

It is worth separating the status “document exists” from the status “document has been verified”

Simply uploading a PDF to a folder does not yet mean that it can be used as evidence.

For supplier documents and test reports, it is worth keeping the following status:

• expected,
• received,
• under verification,
• accepted,
• rejected,
• superseded by a newer version.

Upon acceptance, it is worth recording who verified it and when:

• the scope of the document,
• the product to which it applies,
• the version,
• the method,
• its suitability for the specific requirement.

How should you maintain documentation when further PPWR requirements become applicable later?

This is one of the most important elements of a sound dossier in 2026–2035.

The PPWR is implemented in stages. Therefore, each requirement should be marked with a status:

• applicable,
• not applicable,
• future obligation,
• awaiting a delegated or implementing act,
• under preparation.

This prevents the company from making two opposite mistakes:

• does not leave a future requirement until the last minute;
• does not already declare final fulfilment of a criterion for which the official methodology is not yet applied.

Incomplete technical documentation may itself be a compliance issue

The PPWR also provides for consequences for formal shortcomings in the compliance process.

An issue may arise where:

• the documentation has not been drawn up,
• it cannot be made available,
• it is incomplete,
• it contains incorrect data,
• the declaration does not correspond to the actual documentation.

This does not automatically mean the same penalty in every case. Authorities apply appropriate surveillance and corrective action mechanisms.

However, a lack of documentation should not be treated as a minor formality that can only be completed after receiving an inspection notice.

Most common errors in PPWR technical documentation

• drawing up the declaration of conformity before compiling the file;
• no analysis and assessment of the risk of non-compliance;
• a packaging description so general that it is unclear which variant it concerns;
• no drawing revision;
• no link between materials and components;
• using an outdated supplier specification;
• listing standards that were not actually applied;
• treating all future 2030–2035 requirements as already applicable in their final form;
• no qualitative description of the relevant assessments under Articles 6, 10 and 11;
• a laboratory report without sample identification;
• assuming that every material must have an identical testing package;
• no production conformity control;
• no change procedure;
• overwriting the old file with a new version;
• confusing the manufacturer with the EPR producer;
• assuming that full responsibility can be transferred to an adviser;
• repeating the universal “always 10 days” rule without checking the specific provision and role;
• retaining documentation for only 5 years also for reusable packaging.

PPWR technical documentation – full Annex VII checklist

How can PPWR technical documentation be automated?

For a few packaging types, the dossier can be managed in folders and a spreadsheet.

With a larger number of types, dependencies become a problem.

One material may occur in several dozen designs, and one report may serve as evidence in many assessments.

The most valuable system therefore does not merely store files. It stores relationships between the requirement, evidence, material, packaging type and version.

The data model may look as follows:

supplier → material → specification version → report → PPWR requirement → assessment → packaging type → technical documentation → declaration.

After changing a single material, the system should identify all dossiers and declarations requiring review.

PPWR technical documentation – how to prepare it correctly?

Annex VII does not require one large binder with identical contents for every package. However, it requires documentation sufficient for the conformity assessment and the analysis of the risk of non-compliance.

The core of the dossier consists of six groups of data: description and intended use, design and materials, explanations, standards and specifications, description of the relevant assessments under Articles 6, 10 and 11, and test reports.

This is supplemented by production process control, change management and retention of the documentation history.

The most important thing is to maintain a logical link:

packaging type → version → requirement → risk → evidence → result → technical documentation → EU declaration of conformity.

Such a system not only facilitates issuing the declaration. It also allows you to demonstrate, after several years, why a particular packaging version was considered compliant.

FAQ – PPWR technical documentation and Annex VII

Sources

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

European Commission guidance: Commission Notice C/2026/3084 – Guidelines on Regulation (EU) 2025/40

The article draws in particular on:

• Article 15 – obligations of manufacturers, drawing up and updating documentation, and retention periods,
• Article 16 – information and documentation from suppliers,
• Article 17 – authorised representative and scope of possible authorisation,
• Article 18 – importer’s obligations regarding conformity assessment and documentation,
• Article 35 – testing, measurements, calculations and assessment methods,
• Articles 36–37 – harmonised standards and common specifications,
• Article 38 – conformity assessment procedure,
• Article 39 – EU declaration of conformity,
• Annex VII – conformity assessment procedure, technical documentation and internal production control,
• Annex VIII – model EU declaration of conformity.