PPWR technical documentation under Annex VII: outline and example

The declaration of conformity is one page. The technical documentation behind it is the file with which you demonstrate that the packaging meets the requirements of Regulation (EU) 2025/40, and which market surveillance wants to see within ten days on request. This page shows what belongs in it, what the required risk analysis looks like and how a completed file for a folding box is structured.

In brief

• Mandatory since 12 August 2026 for every packaging placed on the market; it is the basis of the declaration of conformity (Article 38, Annex VII).
• Six minimum contents under Annex VII point 2, plus an analysis and assessment of the risks of non-conformity.
• Retention five years from placing on the market, ten years for reusable packaging (Article 15(3)); the same periods for importers (Article 18(7)).
• Presentation on request within ten days, electronically and on request in paper form (Article 15(10)).
• In Germany an administrative offence if not handed over, not correctly or not in time; fines up to EUR 100,000 or EUR 200,000 (Section 66 VerpackDG).

What Annex VII requires

Module A, internal production control, is the only procedure in the Regulation. The manufacturer draws up the technical documentation, ensures that manufacturing and monitoring guarantee conformity, and issues the declaration of conformity (Annex VII points 2 to 4). The documentation must make it possible to assess conformity and contains, where relevant:

Added to this is the analysis of the risks of non-conformity: which component could breach a limit, how likely is that, and which evidence is appropriate? Article 5(6) expressly requires that compliance with the heavy metal and PFAS limits be demonstrated in the documentation. A test report per batch is not prescribed; in 2026 manufacturers mostly rely on supplier declarations per component and add test reports where there is a risk, for example for printing inks, recycled material or food contact. The applicable limits are in the article on PFAS and heavy metals.

The outline (Word)

The template follows Annex VII point 2(a) to (f) and adds the risk analysis: cover sheet with manufacturer, packaging unit, associated declaration of conformity, version and end of retention; change history; applicable requirements as a checklist (as at September 2026, with the later requirements for information); risk analysis per component; the six minimum contents; assessment of the substance requirements under Article 5 (heavy metals, PFAS for food contact, minimisation); standards and specifications; list of annexes; release. One documentation per packaging type.

• Download: technical documentation outline under Annex VII, Module A, with risk analysis and tables (DOCX)

Example: completed technical documentation (fictitious)

The example belongs to declaration of conformity no. KE-2026-0417 from the article on the declaration of conformity. Manufacturer, suppliers, measured and test values are invented; the example shows the structure, not real results.

What to do after drawing it up

The documentation is a living file. If material, supplier, printing ink or a standard changes, the manufacturer checks whether a reassessment is needed (Article 15(4)) and keeps the declaration of conformity up to date (Article 39(2)). Documentation and declaration are retained for five years from placing on the market, ten years for reusable packaging; importers must be able to access them themselves. On reasoned request of an authority all documents must be presented within ten days, in a language the authority easily understands; Germany accepts German or English for the signed declaration (Section 62 VerpackDG). What a check can lead to is in the article on fines and enforcement.

How Polygon One helps

Polygon One keeps the components, material data, supplier declarations and test reports per packaging unit together, from which the declaration of conformity and the technical documentation are built, with version and retention period. When an authority asks, the file is available as one export. How the PPWR software works.

Frequently asked questions

Do I need separate technical documentation for every packaging?

One per packaging type. Variants of the same packaging, for example several sizes with the same material and product, can be combined if the evidence covers all of them (Commission FAQ XV, question 10).

Are supplier declarations enough as evidence?

For low-risk components, yes. Where there is a risk, for example with printing inks, recycled material or food contact, a test report is the appropriate evidence in the sense of the risk analysis under Annex VII.

Does the documentation have to accompany the packaging?

No. It stays with the manufacturer and is presented to the authority on request.

What applies to importers?

They must ensure that the assessment and the documentation exist and keep them available for the same period (Article 18(7)); it is not enough that the supplier has them.

Sources and status: Regulation (EU) 2025/40 (OJ L, 22.1.2025), Articles 5, 15, 18, 38 and 39, Annexes VII and VIII. Commission FAQ on the PPWR, 2nd edition (August 2026), section XV. German Packaging Law Implementation Act (VerpackDG), Sections 62 and 66. As at 13 October 2026. This article is not legal advice.