PPWR Technical Documentation under Annex VII

Annex VII is a procedure, not a field list

Anyone looking for the technical documentation is usually looking for a structure to fill in. The regulation delivers something else. The official heading of Annex VII reads “Conformity assessment procedure — Module A — Internal production control”, and Article 38 refers to exactly this procedure for assessing every requirement in Articles 5 to 12.

Module A means self-declaration: no notified body, no third-party certification, no CE marking for the packaging. That sounds like relief and is at the same time the difficulty — the burden of proof sits entirely with the manufacturer.

The annex has five numbered parts, and the technical documentation is only one of them:

This split is more than taxonomy; two common misreadings dissolve with it. First, the much-quoted retention periods do not sit somewhere in the articles but inside Annex VII itself — describing the annex as a mere content list contradicts itself the moment you cite those periods. Second, number 3 requires ongoing production control: if design, standard or specification changes, Art. 15(4) calls for a fresh assessment.

The six elements a) to f)

Number 2 first states a requirement for the whole, then the elements. The requirement for the whole is often skipped over, although it calls for a deliverable of its own:

The manufacturer shall establish the technical documentation. The documentation shall make it possible to assess the conformity of the packaging with the applicable requirements, and shall include an adequate analysis and assessment of the risks of non-conformity.

The elements follow. Below, each shows the wording first, then what it means in procurement.

If you hold a circulating overview of the technical documentation against this list, check d) and f) first. Both are frequently absent, both are mandatory, and both need lead time: standards lists have to be kept with editions, test reports have turnaround times. An overview without these two elements produces documentation that meets precisely the “incomplete” condition in Art. 62(1)(d).

The special role of Article 10(4)

For minimisation, element e) becomes concrete in one place — the only place in the entire regulation that spells out the content of the technical documentation. Art. 10(4) requires three things: an explanation of the specifications, standards and conditions used when assessing the packaging against the performance criteria in Annex IV; the design requirements that prevent further reduction of weight or volume for each of those criteria; and the test results, studies or other relevant sources — explicitly including modelling and simulations — used to assess the minimum volume or weight required.

This is the most usable template the regulation itself offers. If you are unsure how deep the documentation has to go, these three points are the benchmark.

What has to be evidenced now — and what does not

Number 1 limits the procedure to the requirements applicable to the packaging. As of this article, that is less than the list of elements suggests:

The striking entry is recyclability. It sits in element e), but the Commission has provisionally suspended the assessment — set out in its notice of 10 June 2026:

Until the entry into force of the delegated act(s) pursuant to Article 6(4) of the Packaging and Packaging Waste Regulation, manufacturers do not need to perform the conformity assessment procedure in accordance with Article 38 and Annex VII of the Packaging and Packaging Waste Regulation for recyclability.

That delegated act is to be adopted by 1 January 2028, after which 24 months remain for implementation. For practice: if someone offers you a set of criteria today as “the” PPWR recyclability assessment, ask for its date — and structure your own data so it can take a late assessment without overwriting the previous state.

Template, format — and an expiry date

For the EU declaration of conformity a model exists: Annex VIII contains a form with fields 1 to 8 and a signature block. For the technical documentation there is none so far — Annex VII says which content must be covered, not in what form.

“So far” is to be taken literally, and this is what sets this page apart from most overviews: Art. 7(8) obliges the Commission to adopt implementing acts by 31 December 2026 — including the format of the technical documentation referred to in Annex VII. If you are building an internal structure now, build it so the content can later be transferred into a prescribed format: entries captured individually rather than in free-text blocks, evidence held as its own records rather than as attachments inside prose.

In practice you need two separate things that often get conflated: an internal structure in which the documentation is kept and versioned per packaging type, and a request format for suppliers that collects exactly the elements you do not hold yourself. The second is the bottleneck, because it depends on third parties.

Where the data comes from

Four of the six elements cannot be filled without the supplier: drawings and materials of components, the explanations for them, the applied standards and the test reports. That makes the technical documentation primarily a supplier topic — and organisationally a procurement one, because that is where the supplier relationship is held.

The strongest lever here is little known: the supplier's duty to provide information does not arise from the contract but directly from the regulation.

Suppliers shall provide the manufacturer with all information and documentation necessary for the manufacturer to demonstrate the conformity of the packaging and packaging materials with this Regulation, including the technical documentation referred to in Annex VII […], in one or more languages which can be easily understood by the manufacturer.

Three things follow. The duty exists regardless of the supply contract — which does not mean deadlines and update obligations should not be anchored contractually anyway. It explicitly covers the Annex VII records, not just general product data sheets. And the choice of language follows the manufacturer: a test report in a language your team does not read does not satisfy it.

How these records get collected in a structured way instead of accumulating in email attachments is described on the page about PPWR software for documentation and reporting. Packaging manufacturers who have to supply them to their customers will find it under PPWR reporting for producers.

Retention, versioning and the ten-day deadline

Documentation and declaration must be retained for five years for single-use packaging and ten years for reusable packaging, in each case from the day of placing on the market. That is Art. 15(3), in identical wording in Annex VII Nr. 4.

The practically harder requirement sits beside it and is rarely quoted: where a national authority requests the documents, Art. 15(10) requires them within ten days — in electronic form, on request additionally on paper, and in a language easily understood by that authority.

Ten days is not enough to collect data from suppliers. It is only enough to export data you already hold. That is exactly the difference between filing and documentation.

From the two deadlines together follows a third requirement the regulation does not name as a term but presupposes: versioning. If a supplier changes material in year three, it must remain traceable which figures applied to the goods from year one. A folder of overwritten PDFs only knows the current state. What is effectively required is a data set with validity periods — and Art. 15(4) additionally calls for a fresh assessment when design, standard or specification changes.

Manufacturer or producer — two terms, two sets of duties

The regulation uses two terms that sound interchangeable and mean different things in law. Annex VII, Art. 38, Art. 39 and Art. 15 consistently address the manufacturer (German: Erzeuger).

For procurement organisations that means: whoever buys packaging and sells their own products in it is the manufacturer — the documentation duty sits with them, not with the packaging supplier. For transport, service and primary production packaging it is usually the other way round, unless the packaging carries the user's name or trademark.

One exception reverses the outcome and is rarely mentioned: where the trademark holder is a micro-enterprise within the meaning of Recommendation 2003/361/EC and its packaging supplier is established in the same member state, Art. 3(1)(13)(b) makes the supplier the manufacturer — and with it the holder of the documentation duty.

The acceptance test

Whether the documentation holds cannot be read off a project plan. The most reliable self-test is an audit simulation against the clock: pick ten packaging items at random and try to present every applicable element in full for each — with the state that was valid at the time of placing on the market, and within ten days.

The time limit is the actual test. Completeness can be achieved with enough lead time; presentability within ten days cannot. Whatever is missing is the project list. A written version of this test, with best practices for the supplier campaign, is in the PPWR checklist.

A final point of context: under Art. 39(5) the competent authorities shall endeavour to check the accuracy of at least a share of declarations of conformity each year, assessed on a risk basis. The question is therefore not whether checks happen, but how likely it is to be among them.