In the first part of our two-part series, we unpacked the declaration of conformity (DoC). Today, we turn our attention to technical documentation. 

According to the Packaging and Packaging Waste Regulation (PPWR), packaging not only has to meet requirements before it can be placed on the EU market, but it must also show proof. This means that each packaging must prove that it’s PPWR compliant by being supported with:

• PPWR Article 39 and Annex VIII - EU Declaration of Conformity

• Annex VII - Technical documentation 

• PPWR Article 38 and Annex VII - Conformity assessment procedure

What is PPWR technical documentation?

PPWR Technical documentation is a set of information that describes a unit of packaging and demonstrates that it complies with the regulation. It must be complete, clear, and made available on request. For each packaging type, manufacturers and importers are required to collect information such as the materials used, the structure and components of the packaging (including layers, coatings, and inks), and details on any restricted substances.

While the Declaration of Conformity acts as the official formal proof that confirms a  packaging is PPWR compliant. The technical documentation represents the documented evidence that supports the DoC by acting as detailed proof that the DoC does in fact align with the EU’s packaging regulations.

If the underlying documentation for the Declaration of Conformity is incomplete, the declaration cannot be issued with confidence. This directly compromises their ability to demonstrate compliance, exposing the business to major regulatory risks. 

Who creates the PPWR technical documentation file?

The manufacturer draws up the technical documentation file. Under the standard conformity assessment procedure (Module A - Internal Production Control), manufacturers assess compliance themselves and retain full responsibility for that assessment. In most cases, involvement from an external notified body is not required.

The burden of this file changes under specific economic operator roles. For instance, importers act as the compliance gatekeepers for third-country goods. Before placing imported packaging on the EU market, importers must verify that the foreign manufacturer has successfully carried out the conformity assessment and drawn up the required technical file. Importers do not author the document, but they must keep a copy of the Declaration of Conformity and ensure the full technical file can be pulled and delivered to national market surveillance authorities within 10 days of a request.

Is a technical file required per SKU?

Not exactly. Manufacturers and importers are required to draw up technical documentation and an EU Declaration of Conformity (DoC) per packaging type, rather than strictly per individual SKU. A single technical file can cover multiple SKUs across different markets provided that the variations between them (such as size or different contained products) do not alter the packaging's compliance with the core PPWR sustainability requirements (Articles 5 to 12). However, if changes in a specific SKU’s format, thickness, or material composition affect its recyclability performance or chemical safety metrics, a separate technical file must be compiled. 

What should be in the PPWR technical documentation (technical file)?

The requirements for technical documentation are set out in Article 38 and Annex VII of the PPWR. Annex VII specifies the information that manufacturers must compile and maintain as evidence that their packaging complies with the regulation's requirements.

The technical documentation forms the foundation of the compliance process and supports the EU Declaration of Conformity (DoC), which serves as the final statement that the packaging meets the applicable PPWR requirements. 

The technical documentation must contain, wherever applicable, at least the following elements:

• a general description of the packaging and its intended use;

• conceptual design, manufacturing drawings and materials of components;

• descriptions and explanations necessary for the understanding of the drawings provided under the previous point and the schemes and operation of the packaging;

• a list of:

  • the harmonised standards, referred to in Article 36, applied in full or in part;

  • the common specifications, referred to in Article 37, applied in full or in part;

  • other relevant technical specifications used for measurement or calculation purposes;

  • in the event of partly applied harmonised standards or common specifications, an indication of the parts which have been applied;

  • in the event of harmonised standards or common specifications not being applied, a description of the solutions adopted to meet the requirements referred to in point 1;

• a qualitative description of how the assessments provided for in Articles 6, 10 and 11 have been carried out; and

• test reports.

The European Commission's final guideline of 30 March 2026 further clarified that manufacturers must be able to provide the complete technical documentation to market surveillance authorities within ten days of a request. 

For organizations managing hundreds or even thousands of packaging variants, meeting this requirement can be extremely challenging without a structured digital system that stores documentation at both the product and bill of material level.

What is the penalty for non-compliance?

1. Loss of Market Access

If you cannot demonstrate compliance by August 2026, you cannot legally place your packaging on the EU market. Non-compliance results in blocked product launches and the mandatory withdrawal of existing stock.

2. Financial Implications

Under Article 68, individual EU Member States are legally required to establish effective, proportionate, and dissuasive penalties within their national frameworks for any infringement of this Regulation. While exact penalty structures are still being determined by individual countries, early national drafts show standard corporate fines can reach up to €200,000 per violation.

3. Value Chain Liability

Liability flows through the entire supply chain and legal exposure is bound directly to the corporate role an organization occupies. Legally, executing the conformity assessment and assembling the technical file remains the sole obligation of the manufacturer (the brand owner or filler). Importers act as strict gatekeepers for third-country goods and face immediate exposure if they place packaging on the market without verifying that the technical file has been drawn up. Upstream suppliers and converters do not author the final file, but under Article 16, they face direct exposure if they fail to provide the manufacturer with the necessary material testing data and chemical logs required to prove compliance. 

4. Hidden Operational Costs

Beyond fines, businesses face substantial hidden expenses. Necessary compliance testing, such as a single PFAS analysis, can cost tens of thousands of euros, and the R&D required to meet mandatory recyclability standards can add up quickly.

How long does the technical documentation remain valid?

A PPWR technical documentation file remains valid for as long as the packaging design, material composition, and the underlying regulations do not change. It does not have a predefined expiration date.

The PPWR sets different document retention periods based on the packaging type, calculated from the date it was last placed on the market. These timeframes apply to both the Declaration of Conformity and the underlying technical documentation:

• Single-use packaging: 5 years

• Reusable packaging: 10 years

How can companies operationalise DoCs and technical documentation across SKUs and suppliers?

For many companies, the challenge is not creating a Declaration of Conformity or technical file for a single packaging type, it's managing hundreds or even thousands of packaging variants across products, suppliers, and markets.

To keep documentation accurate, accessible, and up to date, companies should focus on five key areas:

1. Organise packaging data at component level

Each packaging component, such as bottles, caps, labels, cartons, and films, should be linked to its material specifications, supplier information, and supporting compliance evidence. This creates a clear connection between packaging data, technical documentation, and the DoC.

2. Define clear update triggers

Changes to packaging can affect compliance. Documentation and DoCs should be reviewed whenever there are changes to:

• Materials

• Suppliers

• Packaging specifications

• Weight or thickness

• Compliance-related claims or labels

3. Standardise supplier evidence collection

The quality of your technical documentation depends on the quality of supplier data. Establish a consistent process for collecting and validating supplier information, including material specifications, declarations, and test reports.

4. Manage market and language requirements

Where packaging is sold in multiple EU markets, companies should maintain:

• A controlled master DoC

• Approved translations where required

• Processes to ensure updates are reflected across all market versions

5. Make documentation easy to retrieve

Companies should be able to quickly locate:

• The correct DoC for a packaging type

• The corresponding technical documentation

• Supporting evidence for compliance assessments

This is particularly important as market surveillance authorities may request documentation at short notice. Without a structured and searchable system, responding efficiently can become increasingly difficult as packaging portfolios grow.

What are the most common pitfalls to avoid with PPWR’s technical documentation?

Under the PPWR, technical documentation is required for every packaging type. This can be problematic with companies dealing with packaging portfolios with a vast array of SKUs, where the following obstacles are prone to occur: 

• Scale: Managing compliance checks, data streams, and legal documentation updates across thousands of multi-market product configurations.

• Data (missing, inconsistent or outdated): Gathering highly granular specifications, keeping them up to date, complete, and structured.

• Lack of internal data management structure: Missing an centralized, automated data setup to dynamically link changing product bills of materials (BOMs) directly to your technical documentation and final Declarations of Conformity.

• Supply Chain Fragmentation: Managing data collection across a highly fractured network of global converters and material providers.

How can Recyda help?

Managing PPWR requirements across an extensive packaging portfolio can quickly become an administrative bottleneck as regulations evolve. Recyda unburdens your teams by providing a centralized, end-to-end software solution built to seamlessly navigate your entire PPWR compliance journey. 

The Recyda PPWR Navigator guides your business from data to documentation:

• Data Importation & Onboarding: Effortlessly centralize your packaging portfolio data into a single, structured source of truth from the very start.

• Article-by-Article Assessments: Automatically determine the exact scope of your obligations and evaluate compliance against article-specific criteria, such as recyclability grading, packaging minimisation, and substances of concern thresholds.

• Supplier Document Management: Streamline the complex process of linking and storing required supplier evidence, material logs, and chemical declarations down to the component layer.

• Automated Regulatory Outputs: Seamlessly compile your final data streams to draw up exhaustive, audit-ready Technical Documentation files alongside legally compliant EU Declarations of Conformity.

Ready to secure your compliance foundation and minimize the corporate risks of missing data? 

Discover how Recyda’s dedicated PPWR Navigator can automate your documentation workflows today.