EU PPWR Conformity Documentation

Start the file at packaging-type level. Annex VII describes internal production control as the conformity assessment procedure and requires technical documentation that makes it possible to assess conformity with the applicable PPWR requirements.

A usable file should identify the packaging, intended use, design and manufacturing information, component materials, applicable PPWR requirements, standards or specifications used, assessment methods, risk analysis, and test reports. Keep the file narrow enough that a reviewer can tell which packaging type the evidence supports.

Manufacturers carry the core PPWR documentation duty: before placing packaging on the market, they must carry out or arrange the conformity assessment procedure and draw up the technical documentation. Once compliance is demonstrated, they must draw up the EU declaration of conformity.

Suppliers should feed the file with information and documentation needed for the manufacturer to demonstrate conformity. Importers do not replace the manufacturer file, but they must check that the conformity assessment was carried out, the technical documentation was drawn up, and the declaration can be kept available for market surveillance authorities.

The EU declaration of conformity is not a marketing claim. It must state that the applicable PPWR requirements in or under Articles 5 to 12 have been demonstrated, follow the model structure in Annex VIII, contain the elements specified in Annex VII, and stay continuously updated.

Use the declaration as the signed summary of the technical file. It should identify the packaging, manufacturer, object of the declaration, Union legislation covered, standards or specifications used, any notified body information where applicable, and signature details.

Treat the technical file as an approval gate for packaging release. The file should connect product engineering records, supplier declarations, standards decisions, test reports, and label or information evidence to the specific PPWR requirements that apply to that packaging.

Where the file relies on harmonised standards, record the standard reference and the parts applied. Where the file does not rely on a harmonised standard or common specification, record the solution used to meet the applicable PPWR requirement and the evidence supporting that solution.

Build retention into the release workflow. PPWR distinguishes between single-use and reusable packaging: manufacturers keep the technical documentation and declaration for 5 years after single-use packaging is placed on the market and 10 years after reusable packaging is placed on the market. Importers have matching access duties for declarations and technical documentation.

Authority-response procedures should be practical. Manufacturers and importers must provide requested conformity information, including technical documentation, in a language that the authority can easily understand. Relevant documents must be made available within 10 days after receipt of the request.