PPWR Annex VII technical documentation
The technical documentation is the evidence base for packaging conformity. It must exist, it must be kept available for authorities, and it must actually demonstrate that the packaging meets the requirements that apply to it.
Free PPWR Check60 seconds. Find out whether this packaging should be reviewed.What the file is for
Annex VII of Regulation (EU) 2025/40 describes the technical documentation the manufacturer must draw up for packaging before drawing up the EU Declaration of Conformity. Its purpose is to allow the conformity of the packaging to be assessed — by the manufacturer first, and by market surveillance authorities if they ask.
What it generally has to cover
- General description of the packaging — what it is, what product it packages, its intended use and the format it takes.
- Design and manufacturing information — drawings, schemes, component breakdown, and a description of how it is made.
- Materials and composition — each material and component, weights, coatings, adhesives, inks, labels and closures, plus any substances of concern.
- The applicable requirements — a list of the requirements the packaging is subject to, and any standards or technical specifications applied.
- Assessment against each requirement — the reasoning and calculations showing how the packaging meets them (for example minimisation, recyclability, recycled content where applicable).
- Test and verification evidence — laboratory reports, supplier declarations, material data sheets, and recycled-content evidence supporting the assessment.
Where files usually fail
- Components are missed. Closures, liners, labels, inks and adhesives are part of the packaging and part of the assessment.
- Supplier statements are too vague. "Compliant with applicable legislation" is not evidence of anything specific. Declarations need to name the substance or property and the basis for the statement.
- Nothing is versioned. Packaging changes. A file with no index, version or date cannot be shown to correspond to what is actually on the market.
- The claim outruns the evidence. Recycled-content and recyclability claims in particular need traceable substantiation.
Keeping it available
The technical documentation and the Declaration must be retained and made available to authorities on request for the period set out in the Regulation. Treat the file as a maintained record tied to a packaging specification, not a one-off project deliverable.
Getting it built
Our PPWR Declaration Pack assembles this file and produces a draft Declaration for the manufacturer's signature. If you first need to know what applies and what you are missing, start with the PPWR Documentation Review.
Last reviewed: 11 August 2026. Written and maintained by the PPWRDeclaration.com editorial team. This page is general information about Regulation (EU) 2025/40 and is not legal advice.
Why this matters
What happens if the documentation isn't there
The packaging can be restricted
Packaging without valid technical documentation is treated as non-compliant. Market surveillance authorities can require corrective action, restrict sale, or withdraw it from the market.
Penalties apply per Member State
Each Member State sets its own penalties for non-compliance, and they apply where the packaging is placed on the market — not where your business sits.
Buyers block you first
Retailers, distributors and importers increasingly ask for the Declaration and supporting evidence before onboarding. No file usually means no listing.
Late evidence costs more
Supplier declarations and lab testing have long lead times. Discovering a gap close to a deadline forces rushed testing or packaging redesign.