Since the Packaging and Packaging Waste Regulation — Regulation (EU) 2025/40 — began applying in general on 12 August 2026, one search has spiked in our analytics: some variant of "PPWR technical documentation template". And the honest first answer is the one nobody wants: there is no official template. Annex VII tells you what the documentation must contain; it does not hand you a form to fill in.
That turns out to be workable news, not bad news. The technical file is an evidence system, not a sacred document format — and once you know what it has to prove, who has to hold it and how long, building one is project management, not legal mystery. This article covers exactly that, and pairs with our free Annex VII checklist and evidence workbook for the actual assembly work.
What the technical file is — and why it exists
Under the PPWR's conformity provisions — Articles 38 and 39, with Annexes VII and VIII — packaging placed on the market goes through a conformity assessment. That assessment is documented in a technical file following Annex VII, and its conclusion is stated in an EU Declaration of Conformity following Annex VIII. The file is the evidence; the declaration is the signed conclusion that sits on top of it.
The duty to draw up both belongs to the manufacturer, whose obligations Article 15 sets out: conformity, documentation, identification of type, batch or serial, traceability and corrective action. And the manufacturer is defined the same way for the file as for the declaration — the party that manufactures packaging or a packaged product, or has it designed or manufactured under its own name or trademark. If your boxes are custom-printed with your logo, that is you, not your converter, even though the converter made every unit. We walk that operator logic scenario by scenario in who draws up the PPWR declaration of conformity; the short version is that the file follows the brand on the packaging, not the machine that produced it.
What must the file prove? That the responsible manufacturer can show which packaging version was assessed, which PPWR requirements apply to it, which evidence supports the assessment and who approved the conclusion — specific enough that a later supplier or artwork change is visible rather than silently inheriting an old decision.
What Annex VII actually asks for
Stripped to its content requirements, the technical documentation has four load-bearing parts:
- A description of the packaging — identity, drawings or photographs, function and intended use, down to the component level: materials, layers, coatings, adhesives, closures and weights.
- The applicable requirements — which PPWR rules were screened as applying to this packaging: substances, circular design, minimisation, reuse, labelling and any conditional format rules.
- The results of the assessment — what the screening and any tests concluded, with references to the supplier specifications, composition statements, certificates and test reports behind each conclusion.
- The standards or specifications used — listed precisely, with versions and scope, so another competent person can retrace how each conclusion was reached.
Two things follow. First, the file is mostly made of documents you can obtain rather than write: your supplier holds the compositions, weights and test reports; your job is to request them, date them and map them to a packaging ID. Second, not every requirement can be concluded today. Several PPWR obligations carry their own dates between 2028 and 2040, and some depend on delegated or implementing acts that are still pending — the detailed design-for-recycling criteria and the recycled-at-scale methodology among them. A defensible file records those as open points with an owner and a date. It does not convert a pending EU methodology into a positive conclusion.
Our Annex VII checklist breaks this into ten evidence groups with likely owners — from packaging identity through substance and circular-design assessment to traceability and retention — and pairs it with an editable Excel workbook to track requirements, BOM data and supplier requests.
File and declaration: evidence and signed conclusion
The relationship between the two documents decides the working order. The declaration of conformity — one page, eight fields, following the Annex VIII structure — is issued under the sole responsibility of the manufacturer and states a conclusion. The technical file is what makes that conclusion true. Signing a declaration before the evidence file is complete reverses the order, and it is the single most common way a polished PDF becomes an unsupported declaration.
Both documents also share the same scope discipline: one identified packaging — an ID, a version, a description that leads back to the exact specifications assessed — not "all company packaging". If one supplier certificate covers several formats, keep the supplier's scope statement and map each affected packaging ID explicitly. The declaration's additional information field then points at the technical file by reference — which only works if the file exists, is versioned, and matches what was signed.
How long you keep it — and who can ask for it
Retention is stated plainly in the sources: the technical documentation and the declaration of conformity are kept for five years for single-use packaging and ten years for reusable packaging, and produced to authorities on request. The manufacturer's obligations include a documented response to the authority within the required period — so when market surveillance asks, "it is somewhere in our supplier's archive" is not an answer. Retrievable against the packaging ID is the standard the file has to meet.
One more party will ask before any authority does: the importer. Under Article 18, an importer must verify — before placing packaging from a third country on the market — that the manufacturer has carried out the conformity work and that the declaration, documentation, labelling and identification exist. If you sell into the EU through an importer, expect the question; if you are the importer commissioning packaging under your own brand, the own-name-or-trademark rule usually makes the file yours to build in the first place.
Build order for an e-commerce SMB
For a small team starting from nothing, the file goes together in five passes:
- 1. Freeze the object. Name one packaging version: internal ID, drawing or photograph, intended use, markets and your operator role. Everything downstream hangs on this identifier.
- 2. Map the components. Build the bill of materials: every material, weight, supplier and function — including tape, inks, labels, coatings and closures, the parts most BOMs forget.
- 3. Route the requirements. Screen what applies: substances, circular design, minimisation, reuse, labelling and conditional format rules. Record why each requirement applies or does not.
- 4. Close the evidence gaps. Request supplier proof, testing, calculations or internal approvals — and keep open points with owners and dates rather than optimistic blanks.
- 5. Approve, version, retain. Record the assessment conclusion, sign the declaration only when the file supports it, and define the change triggers — material, supplier, artwork or market — that reopen the assessment.
A numbered folder structure — identity, BOM, supplier specifications, test reports, assessments, declaration, change log — is enough infrastructure, provided a stable packaging identifier appears in every filename or record. A database or product record works just as well; the test is whether links, versions and retention are controlled, not what software holds them.
What usually makes a file difficult to defend
The same gaps recur across the files we see, and they are worth checking against yours:
- A material name without a component weight or a supplier document version.
- A supplier statement that does not identify the packaging or components it covers.
- A recyclability conclusion that ignores labels, adhesives, barriers or closures.
- An environmental claim without retained substantiation and artwork scope.
- A signed declaration with no mapped assessment or approval trail behind it.
- No trigger for reassessment after a material, supplier, artwork or market change.
Note what is not on that list: formatting. Nobody fails on fonts. Files fail on traceability — the chain from conclusion back to dated evidence for one identified packaging version.
FAQ
Is there an official Annex VII template?
No. Annex VII defines what the documentation must contain — the packaging description, the applicable requirements, the assessment results and the standards or specifications used — but the structure is yours to choose. A structured folder, database or product record works if versions and retention are controlled; our checklist and editable workbook stand in for the form that does not exist.
Technical documentation vs declaration of conformity?
The file is the evidence; the declaration is the signed conclusion issued on top of it, under the sole responsibility of the manufacturer. Build the file first, sign last — the reverse order is how unsupported declarations happen.
Who must keep the file — the brand or the supplier?
The manufacturer — and for packaging carrying your name, logo or trademark, the PPWR's own-brand rule makes that you, even though your supplier made the units and supplies much of the evidence. For generic, unbranded packaging, the converter is the manufacturer and the file is theirs; your job is to be able to obtain or reference it.
What if evidence is missing?
Record it as an open point with an owner and a date, request the supplier proof or testing that closes it, and hold the signature until the file supports the conclusion. Pending EU methodologies stay pending in the file — they are never silently converted into a positive conclusion.
Bottom line
The Annex VII technical file is the evidence behind every Annex VIII declaration: a description of one identified packaging version, the requirements screened as applicable, the assessment results with their supporting documents, and the standards used — drawn up and kept by the manufacturer for five years for single-use packaging, ten for reusable, retrievable when an authority or an importer asks. There is no official template, and you do not need one. You need a packaging ID, a bill of materials, dated supplier evidence and an honest list of open points.
Get the free Annex VII checklist and evidence workbook →
When the file is ready, the Annex VIII declaration template structures the signed conclusion — and if you are still working out whether the manufacturer role, or the separate EPR "producer" role, lands on your company at all, settle that first: the file follows the role.
Related reading: Who draws up the PPWR declaration of conformity? · Are you a "producer" under the PPWR? · PPWR guide for SMEs