PPWR technical documentation checklist
A technical file should let another competent person identify the packaging, understand how it was assessed and trace every conclusion back to current evidence.
The EU declaration of conformity is the signed conclusion. Annex VII technical documentation is the supporting file. Signing a declaration before the evidence file is complete reverses that order.
What the technical file should prove
The responsible manufacturer should be able to show which packaging version was assessed, which PPWR requirements apply, which evidence supports the assessment and who approved the conclusion. The file should be specific enough that a later supplier or artwork change is visible rather than silently inheriting an old decision.
The detailed checker treats the file as an evidence system, not one large PDF. A structured folder, database or product record can work if the links, versions and retention controls are clear.
Ten evidence groups to assemble
| File section | Minimum useful evidence | Likely owner |
|---|---|---|
| Packaging identity | Name, internal ID, version, photograph or drawing, function and intended use | Packaging / product |
| Components and materials | Component-level materials, layers, coatings, adhesives, closures and weights | Packaging / supplier |
| Design and manufacturing | Drawings, manufacturing description, tolerances and critical design choices | Engineering / supplier |
| Supplier evidence | Dated specifications, composition statements, certificates and test reports | Procurement / quality |
| Substance assessment | Heavy-metal evidence and PFAS evidence where food-contact rules are triggered | Quality / compliance |
| Circular-design assessment | Recyclability, recycled-content and minimisation evidence applicable to the format | Packaging / sustainability |
| Conditional requirements | Empty space, reuse, restricted formats, compostability or DRS evidence where routed | Packaging / operations |
| Labelling and claims | Artwork, market versions, claims substantiation and an update plan for harmonised labels | Brand / legal |
| Conformity conclusion | Applicable requirements, standards or specifications used, open points and approvals | Compliance |
| Traceability and retention | Supplier, operator, markets, linked products, approval history and retention controls | Compliance / quality |
A folder structure people can maintain
01_packaging_identity/ 02_bill_of_materials/ 03_supplier_specifications/ 04_test_reports_and_substances/ 05_recyclability_and_minimisation/ 06_conditional_requirements/ 07_artwork_labels_and_claims/ 08_assessment_and_approvals/ 09_eu_declaration/ 10_change_log/
Use a stable packaging identifier in every filename or record. If one certificate covers several formats, retain the supplier's scope statement and map each affected packaging ID explicitly.
Build the file in five passes
- Freeze the object.Name one packaging version, intended use, markets and operator role.
- Map the components.Record every material, weight, supplier and function, including tape, inks, labels, coatings and closures.
- Route the requirements.Screen substances, circular design, minimisation, reuse, labelling and conditional format rules.
- Close evidence gaps.Request supplier proof, testing, calculations or internal approvals and retain open-point owners and dates.
- Approve and version.Record the assessment conclusion, sign the declaration only when supported, and define change triggers.
What usually makes a file difficult to defend
- A material name without component weight or supplier 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.
- No trigger for reassessment after a material, supplier, artwork or market change.
Where to verify the requirement
Review the manufacturer obligations, conformity-assessment provisions and Annex VII in the official text of Regulation (EU) 2025/40. This checklist organises the work; it does not replace the legal text or determine whether a particular exception applies.
When the file is ready, use the Annex VIII declaration example to structure the signed conclusion.
If supplier evidence is the blocker, use the editable supplier evidence email pack to request composition, weight, substance and circular-design information consistently.