PPWR Technical Documentation: The Annex VII File Explained

PPWR Technical Documentation: The Annex VII File Behind Your Declaration of Conformity

From August 12, 2026, no packaging may be placed on the EU market without a signed Declaration of Conformity — and every DoC is legally worthless without the technical documentation required by Annex VII of Regulation (EU) 2025/40. Most compliance teams have heard of the DoC; far fewer have started building the technical file that has to stand behind it. This article explains what the Annex VII file must contain, who has to compile it, and how to get one done per packaging type before the deadline.

What the Regulation Actually Says

Article 38 PPWR requires a conformity assessment for every packaging type placed on the EU market, following the procedure set out in Annex VII — Module A, internal production control. There is no notified body in the standard case: the manufacturer assesses conformity internally, compiles the technical documentation, and bears full legal responsibility for the result. Article 39 then requires a Declaration of Conformity drawn up to the model in Annex VIII, declaring conformity with the sustainability requirements of Articles 5 to 12 — substances of concern, recyclability, recycled content, bio-based content, compostability, minimisation, and reusability.

Three structural points matter. First, the PPWR deliberately does not use CE marking — recital 109 explains that a CE mark on packaging could be confused with product CE markings. Conformity is demonstrated exclusively through the DoC and the underlying technical file. Second, both documents must be kept for five years after the last single-use unit is placed on the market, and ten yearsfor reusable packaging. Third, the Commission's guidance published on June 5, 2026 makes the operational expectation explicit: the technical documentation must be made available to market surveillance authorities on request within a short deadline — ten days is the reference figure discussed in the guidance context — which rules out reconstructing the file after the letter arrives.

A DoC without a technical file behind it is an empty assertion; a technical file without a signed DoC means no formal statement of conformity was ever made. Enforcement under Article 62 ranges from corrective orders to sales bans, recalls and withdrawal from the market, with national penalty regimes — Germany's VerpackDG is the template — attaching fines to missing or incomplete documentation.

What Goes Into the Annex VII Technical File

Annex VII is short, but each line implies real engineering evidence. For every packaging type, the technical documentation must contain at least:

• A general description of the packaging and its intended use
• Design and manufacturing drawings, including components, parts and layers of the packaging
• The material composition of every component — substrate, coatings, inks, adhesives, closures, labels
• The list of harmonised standards or other technical specifications applied — CEN/TC 261 work such as EN 13430 for material recycling, or the emerging EN 18120-series design-for-recycling standards
• The assessments carried out under Articles 6 (recyclability), 10 (minimisation) and 11 (reusability), including the qualitative minimisation assessment against the performance criteria of Annex IV
• The results of recycled-content calculations under Article 7, once those targets bite in 2030
• Test reports and evidence for Article 5 substances of concern — the 100 mg/kg limit on the sum of lead, cadmium, mercury and hexavalent chromium, and from August 12, 2026 the PFAS thresholds for food-contact packaging

In practice the file is a per-SKU evidence chain. A folding carton with a window patch, a water-based varnish and a hot-melt spine has at least five components whose composition, supplier declarations and test reports all belong in the same file. The August 2026 version of the file centres on Article 5 evidence and the qualitative Article 10 minimisation assessment; the Article 6 recyclability grade and Article 7 recycled-content calculations join the mandatory core as their deadlines arrive in 2030. The file — and the DoC on top of it — must be updated each time.

Why This Is Harder Than It Looks

1. One file per packaging type, not per company

Annex VIII requires unique identification of the packaging covered by each declaration — a blanket "all our packaging complies" statement is explicitly insufficient, and the June 2026 Commission guidance repeats the point. A mid-sized brand owner with 400 SKUs across primary, secondary and transport packaging is looking at hundreds of technical files, each with its own bill of materials, supplier declarations and test evidence. The unit of work is the packaging specification, not the legal entity.

2. The file is a living document with a growing scope

A technical file compiled in August 2026 documents conformity with the requirements applicable at that date. On January 1, 2030, the recyclability grades of Annex II become binding — packaging graded D or E is banned — and the first recycled-content targets under Article 7 apply, with mass-balance chain-of-custody evidence behind every percentage claimed. Each of those milestones expands what the file must prove, and every material change — a new adhesive, a lighter grammage, a different masterbatch — triggers a re-assessment and a new DoC version. Without version control, you cannot reconstruct which declaration was valid when a batch shipped, which is precisely what a market surveillance authority will ask.

3. The manufacturer is usually the brand owner — and the evidence sits with suppliers

The June 2026 guidance confirmed that the economic operator who owns the trademark and determines the packaging design is the PPWR manufacturer — not the converter who physically produces the pack. The brand owner signs the DoC, but the deinkability report, the ink migration data and the heavy-metal declarations live at the converter, the ink maker and the board mill. Compiling an Annex VII file is therefore a supplier-data exercise: a structured request per packaging type, confirmation that the supporting evidence exists and is retrievable, and an escalation path for the suppliers who answer with an ISO 9001 certificate instead of component-level data.

4. The ten-day retrieval test

The retention obligation is not a filing formality. When an authority requests the file, it expects the complete documentation — drawings, composition, assessments, test reports — for a specific packaging type, within days. Email folders and shared drives fail this test at portfolio scale: the evidence exists somewhere, but nobody can assemble the file for SKU 2371 by Thursday. Retrieval speed, not existence, is the compliance criterion that will separate clean inspections from corrective orders.

5. Importers and distributors have their own verification duties

Article 18 requires importers to verify — before placing packaging on the market — that the manufacturer carried out the conformity assessment, that the technical documentation exists, and that the DoC accompanies the packaging; the importer keeps a copy of the DoC and must be able to produce the technical file on request. Article 19 obliges distributors to check that the manufacturer and importer met their obligations before making packaging available. And under Article 21, an importer or distributor who sells under its own brand, or modifies packaging in a way that affects conformity, becomes the manufacturer with the full Annex VII burden. Private-label ranges and own-brand imports fall straight into this trap.

Practical Action Plan

• 1. Fix your role per packaging type. Manufacturer, importer or distributor — and check Article 21 reclassification for every own-brand or modified pack. All documentation duties flow from this answer.
• 2. Build the packaging master data first. A technical file is only as good as the bill of materials underneath it: component list, materials, weights, suppliers per SKU. Deduplicate into packaging types — identical constructions can share one file.
• 3. Map Annex VII line by line to evidence you hold. Drawings, composition data, Article 5 test reports, the qualitative Article 10 minimisation assessment, and — ahead of 2030 — an Annex II recyclability grade per construction. A systematic recyclability check across the portfolio shows where the gaps are before an auditor does.
• 4. Send structured supplier requests now. Ask explicitly for component-level composition, heavy-metal and PFAS declarations referencing Regulation (EU) 2025/40, and the test reports behind them. Suppliers first asked in July 2026 will not answer by August.
• 5. Draw up the DoC per packaging type from the file. Use a structured Declaration of Conformity template mapped to the ten mandatory Annex VIII elements, and keep the DoC linked to the file version it rests on.
• 6. Version and retain. Five years for single-use, ten for reusable — per packaging type, with a change log connecting each DoC revision to the material change that triggered it.
• 7. Rehearse the retrieval. Pick three random SKUs and time how long it takes to produce the complete file. If the answer is measured in weeks, the storage model — not the evidence — is the problem to fix before August 12, 2026.

How PPWR Connect Helps

The Annex VII file is where every PPWR obligation converges into one auditable evidence chain per packaging type — and assembling hundreds of them by hand is exactly the workflow that breaks spreadsheets. PPWR Connect gives brand owners, manufacturers and importers the structure a dedicated PPWR compliance software is built for: packaging master data per SKU, component-level composition, supplier evidence intake, automated Annex II recyclability grading, and versioned Declarations of Conformity generated from the same data the technical file rests on — retrievable in minutes, not weeks. Start with the free PPWR assessment to see where your documentation stands against the August 12, 2026 deadline.