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EU Packaging and Packaging Waste Regulation (PPWR) 2025/40 introduces technical documentation requirements for packaging. This guide explains how to create technical documentation based on Annex VII.
- Manufacturers must create technical documentation
- Importers must review technical documentation
- Must be kept for 5 to 10 years
- Include artwork, dielines, test reports, and other files
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Who is responsible?
The table below explains what various economic operators must do in relation to technical documentation.
| Entity | Example / Guidelines |
| Manufacturer | 1. Draw up the technical documentation
2. Keep the technical documentation for:
3. Provide the technical documentation to the authorities if requested. |
| Importer | 1. Obtain and review the technical documentation from the manufacturer to ensure that it has been drawn up correctly.
2. Ensure that they have access to the technical documentation for:
3. Provide the technical documentation to the authorities if requested. |
| Distributor | Not mentioned |
Required Information
The table below breaks down the information required in a PPWR DoC, based on Annex VIII.
| PPWR TD Item | Example / Guidelines |
| (a) a general description of the packaging and its intended use; | 1. Model/SKU 2. Dimension/s 3. Material specification 4. Use (i.e., food contact packaging) 5. Description |
| (b) conceptual design, manufacturing drawings and materials of components; | 1. Dielines 2. Artwork files (with label info) 3. Technical drawings 4. Bill of materials 5. Renderings |
| (c) descriptions and explanations necessary for the understanding of the drawings provided under point (b) and the schemes and operation of the packaging; | Explain what the files listed above demonstrate and their purpose |
| (d) a list of:
(i) the harmonised standards, referred to in Article 36, applied in full or in part; (ii) the common specifications, referred to in Article 37, applied in full or in part; (iii) other relevant technical specifications used for measurement or calculation purposes; (iv) in the event of partly applied harmonised standards or common specifications, an indication of the parts which have been applied; (v) 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; |
Harmonised standards
1. Harmonised standards can be used to demonstrate compliance with various aspects of the PPWR. 2. List all harmonised standards that the packing complies with (which should be supported by documentation). Common/technical specifications Applying harmonised standards may not always be necessary (or even possible). But you must still explain which specifications or calculation methods you used to demonstrate compliance with the parts of the PPWR that apply to your packaging. Example: Calculation of the empty space ratio |
| (e) a qualitative description of how the assessments provided for in Articles 6, 10 and 11 have been carried out; and | The mentioned articles are the following:
Article 6 – Recyclable packaging Article 10 – Packaging minimisation Article 11 – Reusable packaging |
| (f) test reports. | List test reports demonstrating compliance with various areas of the PPWR. This could include test reports covering the following:
Note that you can include more than one test report. |
EU PPWR Technical Documentation Template
FAQ
Who is responsible for creating the PPWR technical documentation?
The manufacturer is responsible for creating the technical documentation for packaging. Note that the manufacturer can be defined as:
1. The company manufacturing the packaging or a packaged product
2. The company that has packaging or a packaged product designed or manufactured under its own brand.
Examples:
- Private label companies
- Companies using contract manufacturers
There are also exemptions for microenterprises.
Do we need to create one technical document per packaging?
Not necessarily. While I could not find any statement in the PPWR clarifying whether the technical documentation should be created per design, material or size, the following text provides a clue:
The manufacturer shall draw up a written declaration of conformity for each packaging type and keep it together with the technical documentation at the disposal of the national authorities for 5 years after single-use packaging has been placed on the market, and 10 years after reusable packaging has been placed on the market. The declaration of conformity shall identify the packaging for which it has been drawn up.
The PPWR Declaration of Conformity is drawn up per packaging type, which generally refers to the material of the packaging rather than size, colour, or other variations.
The technical documentation is connected to the Declaration of Conformity, and it is likely that most companies will create technical documentation on a packaging type (material) basis rather than for every single size.
For example, the technical documentation could cover the following:
Packaging type: 250 gsm corrugated paper box
- Colours: Blue, Red, Black
- Size A: 20 x 20 x 85 mm
- Size B: 75 x 75 x 30 mm
- Size C: 165 x 85 x 30 mm
- Size D: 300 x 200 x 100 mm
- Size E: 330 x 200 x 120 mm
What ultimately matters is that the technical documentation demonstrates compliance with the parts of the PPWR that apply to the packaging.
As long as it’s the same “packaging line”, then it’s likely that the artwork files, test reports, and other items in the technical documentation are useful to demonstrate compliance.
That being said, it would likely be impractical to mix many different types of packaging in a single set of technical documentation.
Do we need separate technical documentation for the packaging and the product?
This is not clear when reading the PPWR. That said, you must create a set of technical documentation specifically for the packaging that contains the items listed in Annex VII.
If it were up to me, I would likely keep the PPWR technical documentation as a separate document or an attachment to existing technical documentation.
For how long do I need to keep the PPWR technical documentation?
The technical documentation must be kept for 5 to 10 years by both manufacturers and EU importers:
- Single-use packaging: for 5 years
- Reusable packaging: for 10 years
This counts from the date the packaging was last placed on the market (i.e., sold or shipped). If you last shipped a packaging type in 2027, then the technical documentation must be maintained until 2032 or 2037, depending on if its single-use or reusable
