Technical documentation according to PPWR: What Annex VII requires
Before packaging is placed on the market, its conformity must be assessed and documented. The technical documentation in accordance with Annex VII of the PPWR is the central verification document – without it, there is no effective EU declaration of conformity. This article explains what belongs in it, who creates it and how long it must be kept available.
Your role in the conformity assessment procedure
The PPWR provides for a single conformity assessment procedure for packaging: internal production control based on Module A Article 38, Annex VII PPWR. Hereby, the manufacturer fulfils three obligations – technical documentation, production monitoring, declaration of conformity – and declares on their own responsibility that the packaging meets the requirements of Articles 5 to 12. Annex VII No. 1 PPWR. The procedure: The conformity assessment procedure is carried out and the technical documentation is drawn up prior to placing on the market; the EU declaration of conformity is only issued once conformity has been demonstrated. Art. 15(2) PPWR.
Mandatory content according to Annex VII
The documentation must make it possible to assess the conformity of the packaging and must also contain an adequate analysis and assessment of the risks of non-conformity. It must set out the applicable requirements as well as the design, manufacture and operation of the packaging, insofar as relevant for the assessment. Annex VII No. 2 PPWR. The documentation contains at least the following elements where applicable Annex VII No. 2 lit. a–f PPWR:
- one general description the packaging and its intended use;
- Designs, manufacturing drawings and materials of components;
- Descriptions and explanations to understand the drawings, plans and how it works;
- one List of applied standards and specificationsharmonised standards (Art. 36), common specifications (Art. 37), other technical specifications for measurement or calculation purposes – in the event of partial application, the parts applied, and in the event of non-application, a description of the solutions chosen;
- one qualitative description, how the assessments pursuant to Articles 6, 10 and 11 (recyclability, minimisation, reusability) were carried out;
- Test reports.
Who is creating the documentation?
The creation is the responsibility of the Producers Article 15(2), Annex VII No. 2 PPWR. An authorised representative can take on the duties surrounding the Run take on the documentation on behalf Annex VII No. 5 PPWR - the Creation however, the technical documentation is expressly not one of the tasks that can be delegated to the authorised representative Art. 17(2), second subparagraph, PPWR. Importers must ensure before placing on the market that the manufacturer has carried out the procedure and drawn up the documentation Art. 18(2)(a) PPWR.
Retention and presentation obligations
Manufacturers keep technical documentation and the declaration of conformity: five years upon placing single-use packaging on the market, ten years with reusable packaging Article 15(3) PPWR. Importers shall keep a copy of the declaration of conformity and must be able to present the documentation upon request – for the same periods of time Art. 18 para. 7 PPWR. Upon justified request by a national authority, the documents must be submitted within ten days. Art. 18(8) PPWR.
What the documentation serves as proof of
Several PPWR obligations explicitly refer to the technical documentation as the place for verification – such as compliance with substance restrictions including PFAS limits Art. 5(6) PPWR, later the minimum recyclate content Art. 7(6) PPWR and environmental claims regarding packaging characteristics Art. 14 PPWR. Missing, incomplete or incorrect documentation shall be considered a formal non-conformance. Art. 62 para. 1 lit. d PPWR; in Germany, the violation of the obligation to create is subject to a fine from 12 February 2027 Section 66(2)(3), Section 68(17) of the German Packaging Act (VerpackDG).
Frequently Asked Questions
Is there an official template for the technical documentation?
There is no fixed form – Annex VII No. 2 of the PPWR sets out the minimum elements (description, drawings, list of standards, evaluations, test reports) on which the structure should be based.
Can I delegate the technical documentation to an authorised representative?
Keeping and storing yes (Annex VII No. 5 PPWR), drawing up no – it is expressly excluded from the delegation to the authorised representative (Art. 17 para. 2 subpara. 2 PPWR).
How long must the documentation be kept?
Five years from placing on the market for single-use packaging, ten years for reusable packaging (Art. 15(3) PPWR).
From Annex VII to the finished scaffold
PPWR Radar generates the framework for your technical documentation in accordance with Annex VII from your compliance profile – structured, with references and legal status date. This also includes pre-filled drafts of the EU Declaration of Conformity in accordance with Annex VIII.
Start free impact assessment5 questions, no registration – initial assessment of what the PPWR means for your packaging.
This article provides an explanation and overview; it does not constitute legal advice and is no substitute for an assessment of the individual case. Sources: Regulation (EU) 2025/40 (PPWR, OJ L of 22 January 2025), Packaging Law Implementation Act (VerpackDG, Federal Law Gazette 2026 I No. 207). Legal status: 12 August 2026.