PPWR Technical Documentation and Declaration of Conformity (Part 1): What Regulatory Requirements and Documentation Responsibilities Should Businesses Understand?

For packaging manufacturers, brand owners, importers and purchasing teams, an important question arises: when a customer requests PPWR compliance documentation, what exactly should a business prepare? Is a laboratory test report, an environmental certificate or a supplier declaration sufficient to demonstrate that packaging complies with the regulation?

In practice, these documents serve different purposes. The PPWR establishes specific obligations concerning technical documentation, conformity assessment and the EU Declaration of Conformity. Businesses must therefore establish a documentation system that reflects the actual packaging product and its applicable requirements, rather than simply collecting a range of certificates.

This article examines the regulatory requirements, business responsibilities, technical documentation and conformity declaration under the PPWR, helping packaging businesses and buyers understand the documentation framework they need to consider.

1. What Are PPWR Technical Documentation and the EU Declaration of Conformity?

Two concepts are frequently confused when discussing PPWR compliance.

Technical Documentation

Technical documentation is the set of product-related technical information established by the manufacturer. It explains the packaging design, manufacturing process, material composition, applicable regulatory requirements and the basis of the conformity assessment.

Under Annex VII, the documentation must make it possible to assess the packaging's conformity with the applicable requirements and include an adequate analysis and assessment of the risks of non-conformity.

EU Declaration of Conformity

The EU Declaration of Conformity is a formal document drawn up by the manufacturer after the applicable conformity assessment has demonstrated that the packaging meets the relevant regulatory requirements.

It identifies the packaging and states that compliance with the applicable requirements has been demonstrated. The manufacturer assumes responsibility for the packaging's conformity by drawing up the declaration.

These two documents are related, but they are not interchangeable.

Comparison	Technical Documentation	EU Declaration of Conformity
Purpose	Provides technical evidence supporting the conformity assessment.	Formally declares that the applicable regulatory requirements have been demonstrated.
Main contents	Design, materials, manufacturing information, technical explanations and assessment evidence.	Packaging identification, manufacturer details, applicable legislation and declaration information.
Responsible party	Manufacturer	Manufacturer
Document nature	Technical evidence and assessment documentation	Formal declaration of conformity

Under Article 15, Article 38 and Article 39, manufacturers must carry out the applicable conformity assessment and establish the technical documentation before placing packaging on the market. Once conformity has been demonstrated, the manufacturer must draw up the EU Declaration of Conformity.

In simple terms, technical documentation provides the supporting evidence, while the EU Declaration of Conformity formally confirms the conformity conclusion.

2. What Documentation Responsibilities Does the PPWR Establish for Businesses?

The PPWR does not require every business involved in the packaging supply chain to prepare an identical set of compliance documents. Responsibilities differ according to each economic operator's legal role.

This distinction is particularly important in international packaging procurement, where manufacturers, suppliers, brand owners and importers need to establish a clear process for exchanging product information and supporting documentation.

2.1 Packaging Manufacturers

Under Article 15, manufacturers have primary responsibility for ensuring that packaging complies with the applicable requirements.

Before placing packaging on the market, manufacturers must:

• Ensure that the packaging complies with the applicable requirements under Articles 5–12.
• Carry out the conformity assessment procedure under Article 38 or have it carried out on their behalf.
• Establish the technical documentation required by Annex VII.
• Draw up an EU Declaration of Conformity after compliance has been demonstrated.
• Establish procedures to ensure that series production remains in conformity with the regulation.
• Reassess conformity when changes could affect the packaging's compliance.

Manufacturers must also retain the technical documentation and EU Declaration of Conformity for the following periods:

Packaging Type	Retention Period
Single-use packaging	5 years from the date the packaging is placed on the market
Reusable packaging	10 years from the date the packaging is placed on the market

These retention periods are expressly established under Article 15(3).

Importantly, the legal definition of a manufacturer does not always correspond to the factory that physically produces the packaging.

Under Article 3(1)(13), the manufacturer may be the person or company that has the packaging or packaged product designed or manufactured under its own name or trademark.

The European Commission's 2026 PPWR implementation guidance further explains that the responsible manufacturer depends on the packaging category, branding and the commercial arrangement:

• For sales packaging, the manufacturer will normally be the operator that completes the final processing steps, fills the packaging with its product and places the packaged product on the EU market. This is often the product brand owner.
• For transport packaging, final-form service packaging and primary production packaging, the manufacturer will normally be the packaging manufacturer, unless the packaging is clearly branded with the user's name or trademark.
• Where packaging has no brand name, the relevant factors include who places the order and who determines the packaging design specifications.
• Under Article 21, importers or distributors may also become manufacturers if they place packaging on the market under their own name or trademark, or modify packaging in a way that could affect compliance.

Therefore, the responsible manufacturer should be identified according to the actual legal and commercial circumstances, rather than simply assuming that the physical production factory is always the manufacturer.

Reference: European Commission PPWR Implementation Guidance, C/2026/3084 – Definition of a Manufacturer.

2.2 Packaging Suppliers

Under Article 16, suppliers of packaging or packaging materials must provide manufacturers with the information and documentation necessary to demonstrate the conformity of the packaging and packaging materials with the PPWR.

Depending on the product and applicable requirements, supporting information may include:

• Raw material specifications and composition information.
• Material information for individual packaging components.
• Applicable laboratory test reports.
• Recycled material content and source information.
• Relevant certificates and supply chain traceability records.
• Other technical information needed for the conformity assessment.

Suppliers must provide the relevant information and documentation in one or more languages that can be easily understood by the manufacturer. The documents may be supplied in paper or electronic form.

These documents help the manufacturer establish the technical documentation and carry out the conformity assessment. However, supplying supporting information does not automatically transfer the manufacturer's full legal responsibilities to the supplier.

2.3 Importers

Under Article 18, importers also have specific verification and documentation responsibilities before placing packaging on the EU market.

Importers must ensure that:

• The manufacturer has carried out the applicable conformity assessment.
• The manufacturer has established the required technical documentation.
• The packaging is labelled in accordance with Article 12.
• The packaging is accompanied by the required documents.
• The manufacturer has fulfilled the relevant identification and contact information requirements.

Importers must also retain a copy of the EU Declaration of Conformity and ensure that the technical documentation can be made available to market surveillance authorities upon request.

The applicable retention periods are 5 years for single-use packaging and 10 years for reusable packaging.

When a national authority makes a reasoned request for the relevant documents, importers must provide the required information within 10 days of receiving the request.

Consequently, importers should not rely solely on a general product declaration from a supplier when verifying PPWR compliance.

3. What Should PPWR Technical Documentation Contain?

This is one of the most important aspects of PPWR documentation management.

Annex VII establishes the conformity assessment procedure under Module A – Internal Production Control.

Under Annex VII, the technical documentation must make it possible to assess the packaging's conformity with the applicable requirements and include an adequate analysis and assessment of the risks of non-conformity.

The documentation must specify the applicable requirements and cover the packaging's design, manufacture and operation, as far as relevant to the assessment.

Where applicable, it must contain the following elements:

Annex VII Requirement	Description
General description and intended use	Basic packaging information and its intended application.
Conceptual design, manufacturing drawings and materials of components	Packaging design, manufacturing drawings and component material information.
Descriptions and explanations	Explanations necessary to understand the drawings, packaging structure and operation.
Standards and technical specifications	A list of applicable harmonised standards, common specifications and other relevant technical specifications used.
Assessment descriptions	A qualitative description of how the assessments under Articles 6, 10 and 11 have been carried out.
Test reports	Test reports supporting the applicable conformity assessment.

Where harmonised standards or common specifications have only been partially applied, the documentation must identify the relevant parts. Where they have not been applied, the manufacturer must describe the solutions adopted to meet the applicable requirements.

It is important to understand that Annex VII does not simply require a collection of separate certificates. It requires technical information that explains the packaging design, manufacturing process and basis for the conformity assessment.

For example:

• For Article 6, the relevant assessment concerns packaging recyclability.
• For Article 10, the assessment concerns packaging minimisation.
• For Article 11, the assessment concerns reusable packaging requirements, where applicable.

These assessment descriptions should reflect the applicable requirements and the actual packaging characteristics.

Technical documentation should therefore be specific to the packaging concerned, rather than relying on a general company profile or environmental certificate as a substitute.

Example: A Custom PE Self-Adhesive Bag for Apparel Packaging

Consider a European apparel brand purchasing customised PE self-adhesive bags from a packaging supplier in China.

Depending on the packaging classification and applicable requirements, the technical information supporting its assessment may include the following:

Part 1: Basic Product Information

• Packaging name and product identification number.
• Intended use, such as apparel packaging.
• Bag dimensions, thickness and structure.
• Material composition and component information.

Part 2: Material and Manufacturing Information

• PE film specifications.
• Information about the adhesive strip and other components.
• Printing ink and relevant material information.
• Manufacturing process and packaging structure descriptions.

Part 3: Evidence Supporting Applicable Assessments

• Relevant material safety information.
• Heavy metal test reports, where applicable.
• Other test results relevant to applicable regulatory requirements.
• Recyclability assessment information, where applicable.
• Packaging minimisation assessment and supporting evidence.

Part 4: Conformity Documents

• Technical Documentation.
• EU Declaration of Conformity.

This is an illustrative documentation structure, not a universal list of mandatory tests for every PE self-adhesive bag. The actual assessments and evidence required depend on the packaging composition, intended use and applicable PPWR provisions.

There is also an important point for apparel packaging: the European Commission's implementation guidance explains that packaging used to contain, protect, handle, deliver or present garments may fall within the PPWR definition of packaging. However, textile sales packaging benefits from the specific recyclability exemption under Article 6(11)(g). This exemption does not mean that all PPWR requirements are waived.

Reference: European Commission PPWR Implementation Guidance – Packaging Classification and Textile Sales Packaging.

4. How Does an EU Declaration of Conformity Differ from an Ordinary Supplier Declaration?

During packaging procurement, businesses often receive documents such as Supplier Declarations, Material Declarations and Certificates of Compliance.

Although these documents may support product compliance, they are not automatically equivalent to an EU Declaration of Conformity.

Document Type	Main Purpose	Can It Replace the EU DoC?
Supplier Declaration	Provides supplier statements about materials or products.	No
Material Declaration	Describes material composition and relevant properties.	No
Laboratory Test Report	Records test results under specified methods and conditions.	No
Environmental Certificate	Supports claims within the scope of a particular certification.	No
Technical Documentation	Contains technical information and evidence supporting the conformity assessment.	No
EU Declaration of Conformity	Formally declares that the applicable regulatory requirements have been demonstrated.	It is the formal declaration itself.

What Information Should an EU Declaration of Conformity Contain?

According to Article 39 and Annex VIII, the EU Declaration of Conformity must follow the prescribed model structure and contain the relevant information.

The main elements include:

1. Packaging identification: A unique identification number for the packaging.
2. Manufacturer information: The manufacturer's name and address, and where applicable, the authorised representative's details.
3. Responsibility statement: A statement confirming that the declaration is issued under the manufacturer's sole responsibility.
4. Object of the declaration: Identification and description of the packaging that allows traceability.
5. Applicable legislation: References to the relevant Union legislation applied.
6. Technical specifications: References to relevant harmonised standards, common specifications or other technical specifications used.
7. Notified body information: Details of the notified body and its intervention, where applicable.
8. Signature details: Place and date of issue, name, function and signature of the person signing on behalf of the manufacturer.

The declaration must follow the requirements of Annex VIII and be continuously updated. It must be drawn up in, or translated into, one or more languages required by the Member State where the packaging is placed on the market or made available on the market.

Notified body information is included where applicable; it should not be interpreted as a requirement for every packaging product to undergo third-party certification.

Under Article 39(4), by drawing up the EU Declaration of Conformity, the manufacturer assumes responsibility for the packaging's compliance with the PPWR.

Therefore, an EU Declaration of Conformity is not simply an ordinary supplier certificate, nor can it automatically be issued solely because several laboratory reports are available.

5. Key Takeaways: What Documentation Responsibilities Should Businesses Understand?

The PPWR documentation framework is not simply about collecting additional certificates. It requires supply chain participants to provide the information and evidence relevant to their respective legal responsibilities.

Supply Chain Participant	Main Responsibility	Documentation Focus
Packaging Manufacturer	Product conformity and technical documentation	Technical Documentation and EU Declaration of Conformity
Material or Packaging Supplier	Providing necessary material and technical information	Material Specifications, Test Reports and Supplier Information
Importer	Verifying the manufacturer's conformity documentation and relevant product information	DoC verification and access to technical documentation
Brand Owner	Fulfilling the obligations associated with its actual legal role	Product information, supplier documentation and responsibility verification

Businesses should keep three key principles in mind:

• Technical documentation is not simply a product description. It is the technical evidence supporting the packaging conformity assessment.
• Supplier declarations, laboratory test reports and environmental certificates have different purposes and cannot automatically replace an EU Declaration of Conformity.
• The manufacturer remains responsible for the applicable conformity assessment, technical documentation and formal declaration, even when suppliers or other service providers assist with preparing supporting information.

For this reason, packaging procurement should not focus only on whether a supplier can provide certificates. It should also consider whether the supplier can provide accurate, complete and product-specific technical information.