PPWR Technical Documentation: Building Your Annex VII Evidence Vault
What belongs in the Annex VII file, who has to hold it, and how it backs your Declaration
PPWR technical documentation is the Annex VII file proving a packaging type meets the regulation's design and substance rules. It contains a general description and intended use, design drawings, a full bill of materials, and the assessment evidence for every requirement that applies – today, laboratory results for heavy metals and PFAS. You have had to hold it since 12 August 2026, and you keep it for 5 to 10 years.
Updated 19 August 2026: revised now that the PPWR (Regulation (EU) 2025/40) applies, since 12 August 2026.
The days of relying on vague supplier promises are over. Packaging placed on the EU market now needs this file behind it before it goes on sale, not at some point later.
Key takeaways
- The technical file must be assembled before you place any packaging on the market. That duty has been live since 12 August 2026.
- It requires concrete laboratory evidence for the restricted substances in Article 5: heavy metals, and PFAS in food-contact packaging.
- The file covers the requirements applicable when the packaging goes on the market, so recyclability grades, recycled content and the empty-space ratio join it later in the decade.
- You retain the documentation for five years (single-use) or 10 years (reusable), and it is the mandatory foundation for your EU Declaration of Conformity.
What is PPWR technical documentation?
Under the new Packaging and Packaging Waste Regulation, authorities demand structured proof rather than assumptions. The ppwr technical documentation is a formal file that contains the design, material composition, and chemical testing data for a specific packaging type. It is created following the internal production control procedures outlined in Annex VII of the regulation.
PPWR technical documentation is not just a commercial invoice from your supplier. It is an engineering and compliance dossier. It forces the legally designated manufacturer of the packaging to show that the item meets the requirements of Articles 5 to 12 as far as each of them applies – today, above all the chemical restrictions. If an auditor knocks on your door, this is the exact file they will ask to see.
What exactly must be included in the Annex VII file?
Building this file requires gathering fragmented data from across your supply chain. You cannot just submit a marketing brochure claiming your packaging is green. The law requires specific technical inputs that detail every physical property of the container.
First, you need a general description of the packaging and its intended use. You must document the exact types of ecommerce packaging you use, whether primary, secondary, or tertiary, and explain how the components function together to protect the product.
Second, the Annex VII technical documentation must include design and manufacturing drawings. This means detailing the component structures, the complete bill of materials, and the exact weight of the plastics, paper, and adhesives used. You must also include descriptions and explanations necessary for understanding those drawings.
Third, you must provide laboratory test reports verifying chemical safety. You need concrete proof that the packaging meets the restrictions on substances of concern under Article 5. This includes tests showing that the combined concentration of lead, cadmium, mercury, and hexavalent chromium remains strictly below 100 mg/kg. If the packaging comes into contact with food, you must also include tests proving total fluorine from PFAS sources is below 50 ppm.
Finally, the file has to carry the assessment evidence for each requirement that applies to the packaging at the time you place it on the market. That is a moving target by design. The Article 5 substance limits are in scope today. The recyclability performance grade, the recycled-content percentages and the 50 percent empty-space calculation are not yet applicable requirements, so they join the file as their own dates arrive later in the decade – but the material data they will need is data worth collecting now, because it comes from the same suppliers.
Gathering these lab tests and material breakdowns is tedious when you are trying to scale your store. We build automated data pipelines to simplify this process. Let Gramta organise your compliance files and keep your supplier data secure.
Who is legally responsible for maintaining these records?
The obligation to compile and store this documentation falls heavily on the brand owner or the entity that commissions the packaging under their own trademark. If you fit the legal definition of the manufacturer, the burden of maintaining this evidence vault is entirely yours.
If you are importing finished packaged goods from outside the European Union, the PPWR compliance rules for importers require you to verify that your overseas supplier actually holds this technical documentation, and that the conformity assessment happened, before the goods go on the market. There is a micro-enterprise shift that can move the manufacturer role to your packaging supplier, but only where that supplier is located in the Union. Source from outside the EU and the documentation duty is yours.
How does the technical file relate to the Declaration of Conformity?
The Annex VII technical documentation and the Annex VIII EU Declaration of Conformity (DoC) are legally bound together. You cannot have a valid DoC without the technical file sitting behind it to validate its claims.
Since 12 August 2026, manufacturers have had to draw up an EU Declaration of Conformity and hold the underlying technical documentation, keeping both available to market surveillance authorities for five years (single-use packaging) or 10 years (reusable).
When you sign the DoC, you are legally attesting that the internal production control was carried out and that the technical documentation exists to prove it. If market surveillance authorities ask for your DoC and then demand the technical file to verify your claims, failing to produce it can get your products barred from the market. If your file is not complete, collecting the technical documentation from your suppliers is the gap to close first, because an unbacked declaration is worse than a missing one.
How do you organise your compliance data?
Audit your packaging portfolio. Map out every box, tape, and mailer you use, work out which supplier provides each material, and formally request their chemical testing reports and material composition breakdowns. Treat this data collection as a procurement requirement, not a favour you are asking.
Because you also have to track the requirements still to come on the PPWR deadline timeline, scattered emails and PDF attachments will not hold up. You need one place that records which packaging formats have completed their conformity assessment and which are missing laboratory evidence.
Do not risk market exclusion because of missing supplier data. Get started with Gramta to automate your document collection, securely store your Annex VII files, and ensure your e-commerce business remains fully compliant with the new European packaging laws.
Sources:
Frequently asked questions
- What is PPWR technical documentation?
- It is a mandatory file required by Annex VII of the EU Packaging and Packaging Waste Regulation that contains the design, material, and testing evidence proving your packaging meets all sustainability requirements.
- What needs to be included in the Annex VII technical file?
- A general description of the packaging and its intended use, design and manufacturing drawings, a full bill of materials with component weights, and the assessment evidence for each requirement that applies at the time you place the packaging on the market. Today that means the heavy-metal and PFAS limits in Article 5; the recyclability, recycled-content and empty-space evidence joins the file as those requirements start to apply.
- How long must I keep my PPWR technical documentation?
- Depending on the specific packaging type, you must retain the complete technical documentation for 5 to 10 years and make it available to market surveillance authorities immediately upon request.
- Can I issue a Declaration of Conformity without technical documentation?
- No. The EU Declaration of Conformity is legally invalid unless it is backed by a complete Annex VII technical documentation file that proves the compliance claims.
Reviewed by Daniel Vaknine