PPWRConformity fileEU

EU PPWR Conformity Documentation

Prepare the technical documentation and EU declaration of conformity that support packaging placed on the EU market.

This guide helps connect packaging evidence, supplier inputs, harmonised standards, declaration language, and retention duties to the PPWR source text.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
Overview

Before placing packaging on the Union market, the PPWR manufacturer must use Annex VII Module A internal production control, draw up technical documentation for the applicable Articles 5 to 12 requirements, and issue an EU declaration covering the applicable Articles 5 to 12 requirements. Article 15(11) exempts custom-made transport packaging for configurable medical devices and medical systems used in industrial and healthcare environments from the conformity assessment, technical documentation, EU declaration, and retention duties in Article 15(2) and (3). Importers must verify the required work and keep the declaration available. The PPWR procedure is manufacturer self-assessment; it does not create a routine notified-body approval or a PPWR CE-marking step.

Section 1

What belongs in the PPWR conformity file?

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. It must also show how production controls keep manufactured packaging aligned with the approved technical documentation. Keep the file narrow enough that a reviewer can tell which packaging type the evidence supports.

  • General description of the packaging and intended use.
  • Conceptual design, manufacturing drawings, and materials of components.
  • Explanations needed to understand the drawings, schemes, and operation of the packaging.
  • List of harmonised standards, common specifications, or other technical specifications applied.
  • Description of the alternative solutions used where standards or common specifications were not applied.
  • Qualitative description of assessments under Articles 6, 10, and 11 where relevant.
  • Test reports and an adequate analysis and assessment of non-conformity risks.
  • Manufacturing controls showing how the production process and monitoring keep the packaging in conformity with the technical file.
Section 2

Who must create and keep the documents?

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 unless Article 15(11) applies. Where Article 15(2) applies and compliance is demonstrated, they must draw up the EU declaration of conformity.

Suppliers must provide the manufacturer with the information and documentation needed to demonstrate conformity, including technical documentation required under or pursuant to Articles 5 to 11. Article 15(12) treats the Union supplier as the manufacturer for Article 15 where a qualifying micro-enterprise has packaging or a packaged product designed or manufactured under its own name or trademark. Importers do not replace the required manufacturer file, but they must check that the required conformity assessment was carried out, the required technical documentation was drawn up, and the declaration can be kept available for market surveillance authorities.

  • Manufacturer: owns the required conformity assessment, technical documentation, and EU declaration of conformity, subject to Articles 15(11) and 15(12).
  • Supplier: provides the information and documentation needed to demonstrate packaging and packaging-material conformity.
  • Importer: checks the manufacturer's conformity work before placing packaging on the market and keeps the declaration available.
  • Authorised representative: may keep the declaration and technical documentation when the written mandate says so, but does not take over the manufacturer's duty to draw up the technical documentation.
Section 3

How should the EU declaration of conformity be prepared?

The EU declaration of conformity is the manufacturer's signed statement, issued under its sole responsibility, that the applicable requirements in or under Articles 5 to 12 have been demonstrated. It must follow Annex VIII, contain the elements specified in Annex VII Module A, stay continuously updated, and use or be translated into the languages required by the Member State where the packaging is placed or made available.

Identify the packaging, manufacturer, object of the declaration, relevant Union legislation, standards or specifications used, and signature details. Complete the notified-body field only where another applicable Union act makes a notified body relevant; Annex VII Module A does not require one for PPWR conformity.

  • Use a unique identification number for the declaration.
  • Identify the packaging in a way that allows traceability.
  • Name the manufacturer and, where applicable, the authorised representative.
  • List the PPWR and any other relevant Union harmonisation legislation with publication references; a single declaration or dossier may cover several Union acts where appropriate.
  • Reference harmonised standards, common specifications, or other technical specifications used.
  • Keep the declaration language aligned with the Member State where the packaging is placed or made available on the market.
  • Name the signatory, place and date of issue, and keep evidence that the signatory is authorised to bind the manufacturer.
Section 4

What evidence should be linked before approval?

Treat the technical file as an approval gate for packaging release. Connect engineering records, supplier declarations, standards decisions, test reports, and label or information evidence to the specific PPWR requirements that apply. A legacy standard under Directive 94/62/EC does not automatically give a PPWR presumption of conformity; record whether the standard or common-specification reference covers the PPWR requirement and has the legal status claimed.

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.

  • Recyclability assessment and grading evidence for Article 6 where relevant.
  • Recycled-content calculation and verification evidence for Article 7 where relevant.
  • Minimisation evidence and supporting assumptions for Article 10 where relevant.
  • Reusable packaging and reuse-system confirmations for Article 11 where relevant.
  • Labelling, marking, QR code, or data-carrier evidence for Article 12 where relevant.
  • Substance evidence, including heavy metals and PFAS evidence where the packaging type triggers those checks.
  • Change-control record for packaging design, characteristics, standards, specifications, or manufacturing changes.
Section 5

What retention and authority-response rules should the workflow cover?

Build retention into the release workflow. Where Article 15(3) applies, 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 where those documents are required.

Authority-response procedures should be practical. On a reasoned request, manufacturers and importers must provide the conformity information, including technical documentation, in a language the authority can easily understand. The relevant documents must be available within 10 days after receipt. Distributors provide the relevant information and documents to which they have access, but Article 19 does not assign them the manufacturer's document-retention duty.

  • Retention field: packaging type, market-placement date, single-use or reusable status, and retention end date.
  • Authority-response field: document owner, backup owner, source repository, language owner, and paper-copy route when requested.
  • Re-assessment trigger: changes to packaging design, characteristics, harmonised standards, common technical specifications, or other specifications used for conformity.
  • Formal non-compliance trigger: missing, incorrect, incomplete, or erroneous declaration or technical documentation.
Recommended next step

Turn PPWR conformity work into a maintained evidence file

This PPWR guide helps connect packaging types, supplier evidence, technical documentation, declarations, retention duties, and authority-response workflows before market placement.

Primary sources

References and citations

data.europa.eu6 citations
Referenced sections
  • Official PPWR text used for conformity assessment, technical documentation, declaration, role, retention, and formal non-compliance claims.
  • Article 38 and Annex VII are the binding PPWR source for Module A internal production control, technical documentation, production controls, and the declaration for each packaging type.
  • Articles 15 to 18 set manufacturer, supplier, authorised-representative, and importer duties for conformity assessment, technical documentation, declarations, identification, retention, and authority responses.
Show 3 more
  • Article 39 and Annex VIII define the declaration's purpose, structure, fields, update and language rules, multi-act dossier option, and manufacturer responsibility.
  • Annex VII requires the technical documentation to cover design, manufacture, operation, specifications used, assessment descriptions, and test reports where applicable.
  • Articles 15, 18, 19, and 62 set retention and authority-response duties and identify missing, incomplete, or erroneous conformity documents as formal non-compliance.
"Conformity assessment of packaging as regards the requirements laid down in or pursuant to Articles 5 to 12"
More quoted passages
"The manufacturer shall establish the technical documentation."
"Before placing packaging on the market, manufacturers shall carry out the conformity assessment procedure"
"The EU declaration of conformity shall state that the fulfilment of the requirements"
"shall cover, as far as relevant for the assessment, the design, manufacture and operation of the packaging"
"The relevant documents shall be made available within 10 days"
single-market-economy.ec.europa.eu2 citations
Referenced sections
  • Commission single-market page used only for standards context when teams document standards applied in a PPWR technical file.
  • The Commission single-market page lists harmonised standards under the predecessor packaging directive; use it as standards context, not as a substitute for the PPWR text.
"Summary list of titles and references of harmonised standards"
data.europa.eu
Referenced sections
  • Official non-binding guidance explaining that the manufacturer remains the sole economic operator legally responsible for Articles 5 to 12 conformity even when a laboratory, certification scheme, supplier, or authorised representative supports the assessment or drafting.
"sole economic operator bearing legal responsibility"
environment.ec.europa.eu
Referenced sections
  • European Commission overview page for official PPWR policy context and public implementation framing.
"Packaging & Packaging Waste Regulation"
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