Quick answer: PPWR Annex VII technical file
Every packaging manufacturer must compile a technical file (Annex VII of EU Regulation 2025/40) before signing the Declaration of Conformity. It contains the evidence that your packaging meets PPWR requirements on minimisation, recyclability, recycled content, and labelling. No notified body is required — this is Module A (internal production control). Retention: 5 years for single-use packaging, 10 years for reusable. Market surveillance authorities can demand access within 10 days. Deadline: 12 August 2026.
What Is the PPWR Technical File?
The Packaging and Packaging Waste Regulation (EU) 2025/40 requires two linked compliance documents: a Declaration of Conformity (Annex VIII) signed by the manufacturer, and a technical file (Annex VII) that contains the evidence making that declaration defensible. The DoC is the legal statement. The technical file is the proof behind it.
Annex VII establishes Module A — internal production control — as the conformity assessment procedure for packaging placed on the EU market. Under Module A, manufacturers self-certify compliance without engaging a notified body. The trade-off is that the technical file must be rigorous, complete, and immediately available to market surveillance authorities on request. A DoC without a supporting technical file is not valid.
From 12 August 2026, no packaging may be placed on the EU market without both documents in place. This applies equally to packaging manufactured in the EU and to imported packaging — importers who cannot verify that their supplier has compiled the technical file must prepare it themselves before the goods clear customs. The complete PPWR compliance guide covers the full scope of obligations from that date.
Who Must Prepare It?
The obligation falls on the manufacturer — the economic operator who places packaging on the EU market under their name or trademark. For packaging produced outside the EU, the EU-established importer assumes manufacturer obligations if the non-EU producer has not appointed an Authorised Representative registered in the EU.
Distributors who rebrand packaging or alter its presentation in ways that affect PPWR compliance requirements also become responsible for preparing or verifying the technical file. A retailer sourcing own-brand packaging from a non-EU manufacturer without verifying the technical file's existence is taking on material regulatory exposure — market surveillance authorities have the legal authority to order product withdrawal on the same basis as they would for a manufacturer.
The European Commission's guidance published before the August 2026 application date clarified that the technical documentation must be made fully available to market surveillance authorities within ten days of a request, with no extension possible during active market surveillance investigations.
What the PPWR Technical File Must Contain
Annex VII does not prescribe a fixed document format, but the regulation specifies the substantive elements that must be covered. The technical file must demonstrate conformity with each PPWR obligation applicable to the packaging type in question. In practice, this means assembling evidence across five compliance areas.
| Compliance Area | PPWR Obligation | Evidence Required in Technical File |
|---|---|---|
| Packaging identity | All obligations | Bill of materials, component hierarchy, materials by weight, supplier details, part numbers per SKU |
| Minimisation | Article 4 / Article 10 (empty space cap) | Design justification for each packaging component; evidence that weight and volume are at the minimum necessary to protect product, meet legal requirements, and satisfy consumer expectations |
| Recyclability | Article 6 | Recyclability assessment against harmonised standards or accepted methodology; test reports if standards are available; recyclability performance grade classification |
| Recycled content | Article 7 (plastic packaging) | Recycled content certificates from raw material suppliers; batch-level documentation linking recycled input to specific packaging production runs |
| Labelling and information | Article 12 / Annexes VI, IX | Proof of correct sorting and recyclability labels; evidence of compliance with deposit return scheme markings where applicable |
| Supplier evidence register | All obligations | Signed supplier declarations; test certificates; audit reports; traceability documents referenced in the DoC |
The technical file must describe the packaging type and its intended use, set out the conformity assessment procedure followed (Module A), state the PPWR requirements the packaging has been assessed against, and reference each piece of supporting evidence. A cover document summarising the file structure and cross-referencing evidence to regulatory obligations simplifies market surveillance review and is considered good practice even if not explicitly mandated.
Retention Requirements: How Long Must You Keep It?
The PPWR retention requirements differ by packaging type — a distinction that catches importers of mixed packaging portfolios unprepared when they apply a single retention period across all products.
| Packaging Type | Retention Period | Practical Implication |
|---|---|---|
| Single-use packaging | 5 years from placing on market | Technical file for packaging placed on the market from August 2026 must be retained until at least August 2031 |
| Reusable packaging | 10 years from placing on market | Reusable formats require substantially longer records management and version control as packaging designs evolve |
The retention clock starts from the date the packaging is first placed on the EU market, not the date the technical file is compiled. For companies using continuous production runs, this means implementing a document management system that can link each production batch to the technical file version valid at the time of placement — not just the current version.
Digital document management is strongly advisable. A technical file held in paper or unstructured digital formats becomes an operational liability as PPWR requires packaging producers to update it when packaging specifications change or when new harmonised standards affect the compliance assessment.
Annex VII vs Annex VIII: The Distinction That Matters
The two documents serve different legal functions and are often conflated in early compliance projects. Understanding the distinction avoids critical gaps.
Annex VII — the technical file — is the private compliance record. It is held by the manufacturer or importer, is not published, and is made available only to market surveillance authorities on request. It is the internal body of evidence that makes the Declaration of Conformity supportable.
Annex VIII — the Declaration of Conformity — is the public-facing compliance statement. It is signed by the manufacturer, includes required fields (product description, applicable PPWR provisions, signatory details, date and place), and is referenced on or with the packaging. A detailed guide to the PPWR Declaration of Conformity, including Annex VIII fields and how to scale it across SKUs, covers that document specifically.
The practical workflow is: compile the technical file first, then sign the DoC that references it. A DoC signed without an underlying technical file is non-compliant under the regulation even if the packaging itself is physically conformant. Market surveillance authorities who find a DoC without a supporting technical file can treat the packaging as non-compliant regardless of its actual performance.
Building Your PPWR Technical File Before August 2026
With the August 12, 2026 deadline approaching, companies that have not yet started their technical file preparation face a focused but achievable project if they act within the next few weeks.
Step 1: Inventory your packaging portfolio. Identify every packaging format placed on the EU market — primary, secondary, tertiary, and transport packaging. Separate single-use from reusable. Identify which formats contain plastic (recycled content obligations apply). Note which are e-commerce formats (empty space rule under Article 10 / Article 24 applies from January 2030, but minimisation duty from August 2026 — see the PPWR empty space rule guide for details).
Step 2: Collect material data from suppliers. Every technical file depends on supplier-provided data — material composition, recycled content certificates, recyclability test reports. Request this data from packaging suppliers now. Suppliers who cannot provide it by mid-July leave you insufficient time to source alternatives or prepare your own assessments before the deadline.
Step 3: Conduct recyclability assessment. Where harmonised standards exist for your packaging material, follow the applicable standard methodology. Where standards are pending, use the methodology referenced in the latest Commission guidance. Document the assessment, the standard used, and the recyclability grade achieved — this documentation goes directly into the technical file.
Step 4: Compile per-SKU or per-format technical files. A single technical file template applied rigidly across all formats creates gaps where individual packaging types have unique compliance considerations. Group packaging types that share materials, suppliers, and conformity evidence into file clusters, but ensure each file identifies the specific packaging format it covers.
Step 5: Set up version control and retention tracking. Document when each technical file was first prepared, which packaging batches it covers, and what triggers an update (material change, supplier change, new harmonised standard). Implement the 5-year / 10-year retention clock by packaging type.
If you need to generate the associated Declaration of Conformity at scale, the PPWR DoC generator produces Annex VIII-compliant declarations with the required fields pre-populated — reducing the per-SKU effort when working through large packaging portfolios.
Frequently Asked Questions
What is the PPWR technical file (Annex VII)?
The PPWR technical file is the internal compliance record required under Annex VII of EU Regulation 2025/40. It contains documentary evidence that the packaging meets PPWR requirements on minimisation, recyclability, recycled content, and labelling. It underpins the Declaration of Conformity (Annex VIII) which the manufacturer signs. No third-party notified body is required — the procedure is Module A internal production control. The technical file is held by the manufacturer and made available to market surveillance authorities on request within 10 days.
Is the PPWR technical file the same as the Declaration of Conformity?
No. The Declaration of Conformity (Annex VIII) is the public-facing signed statement that the packaging complies with PPWR. The technical file (Annex VII) is the private evidence file held by the manufacturer that makes the declaration supportable. You compile the technical file first, then sign the DoC that references it. A DoC without an underlying technical file is non-compliant even if the packaging itself is physically conformant.
How long must I keep the PPWR technical file?
Retention requirements under PPWR differ by packaging type: 5 years from placing on the market for single-use packaging, and 10 years for reusable packaging. The retention clock starts from the date the packaging is first placed on the EU market, not the date the technical file is created. Companies with mixed portfolios must track retention periods separately by packaging type and implement version control when specifications change.
Does the PPWR technical file need to be audited by a third party?
No. PPWR Annex VII follows Module A — internal production control — which does not require third-party notified body involvement. The manufacturer conducts the conformity assessment internally and holds the technical file. However, the evidence within the file — recyclability test results, recycled content certificates, material declarations — must meet the substantive requirements set out in the regulation and any applicable harmonised standards, and will be scrutinised by market surveillance authorities if the file is requested.
What happens if market surveillance authorities request my technical file and I cannot produce it?
If you cannot produce the technical file within the 10-day window specified in the European Commission's pre-application guidance, market surveillance authorities can treat the packaging as non-compliant regardless of whether the packaging itself meets the physical requirements. They have the authority to prohibit placing the packaging on the market, require its withdrawal from distribution channels, and impose financial penalties under national implementing legislation. The inability to produce documentation is itself treated as a compliance failure, not a procedural irregularity.