PPWR documentation: Technical documentation, conformity assessment and declaration of conformity

The new duties of documentation introduced by the PPWR (Regulation (EU) 2025/40)must be fulfilled by 12 August 2026 and are therefore among the first measures that companies need to implement.

Manufacturers must be able to prove that their packaging meets the requirements of the PPWR. In certain cases, these duties may be delegated to importers and distributors. For many types of packaging, placement on the market will soon be impossible without the right documentation. Find out here if your company is affected and what your plan of action should be.

Note: This post is for general informational purposes only and is not a substitute for legal advice.

Content:

The importance of documentation
Actors and their duties
Components of the documentation
Digital documentation and assessment
Checklist

Why does documentation play such an important role?

The PPWR pursues the same product-focused approach to conformity as has already been adopted by other pieces of European legislation.

Which means:

Packaging must fulfil the specified legal requirements.
Compliance must be documented and records must be kept.
Authorities can request these records at any time.
Responsibility is born by the respective economic actor – and primarily the manufacturer.

Maintaining a full set of documentation is therefore a key part of packaging management activities, while forming the basis for fulfilling other PPWR duties.

Affected economic operators and their duties

csm_ppwr-unterschiedliche-verpackungen_9b8448967d

The documentation duties from the PPWR affect all economic actors who are responsible for packaging or packaged products that are supplied to or placed on the market in the European Union. The specific responsibilities depend on the operator’s role.

Manufacturers bear primary responsibility under the PPWR. They must complete the conformity assessment for the packaging, create technical documentation and issue an EU declaration of conformity. In addition, manufacturers must ensure compliance with all applicable PPWR requirements and retain all of the necessary documentation on file.

Manufacturers may appoint authorised representatives in writing. These representatives may take on certain tasks, such as keeping the EU declaration of conformity and technical documentation on file, and making this available to the market surveillance authorities. The manufacturer bears the ultimate responsibility for creating the technical documentation and ensuring conformity, however (Article 16, Regulation (EU) 2025/40).

When importing packaging from third countries into the EU, importers must ensure that the manufacturer has created the necessary documentation, that an EU declaration of conformity is available, that the packaging is properly labelled, and that any packaging that is patently non-compliant is not placed on the market.

Distributors are subject to certain duties of care and must not supply any packaging in cases where they know or must assume that the packaging does not conform to the requirements of the PPWR.

Fulfilment service providers are assigned responsibilities under the PPWR in situations where no other responsible economic actor is present within the EU. 

Suppliers’ key role for documentation

In the future, all information and records about packaging and packaging materials will come from the supply chain, and manufacturers will be reliant on the proper provisioning of this information. Professional supplier relationship management will thus become an integral part of PPWR compliance. Important documents are provided by suppliers of virgin materials, packaging producers, printers, recycling companies and certification bodies, for example.

Unsure about your roles and duties? Contact us!

Components of the PPWR documentation

Please note: Many details of these requirements have yet to be clarified by delegated acts and harmonised standards. Routine monitoring of regulatory developments is therefore recommended. Companies that take action early on will lay the groundwork for a legally compliant and future-proof packaging strategy.

Technical documentation

The technical documentation is a core element of the declaration of conformity and serves as evidence that a piece of packaging fulfils the applicable legal requirements (annex VII of Regulation (EU) 2025/40). Technical documentation must be kept up to date and submitted to market surveillance authorities within 10 days of a request. 

Technical documentation comprises the following:

Basic contents: Description of the packaging, including its intended purpose and field of application, material composition, bills of materials, drawings, product specifications, material datasheets, test reports and records of compliance with PPWR requirements
Evidence of compliance with substance restrictions, e.g. material/supplier declarations, test reports, lab analyses and declarations of conformity
Evidence of compliance with packaging minimisation, stating that packaging is not oversized, empty space is avoided, material has been efficiently utilised and designs have been optimised (phased entry into force for requirements)

Conformity assessment

Before placing packaging on the market, a conformity assessment pursuant to Article 38 in conjunction with Annex VII of Regulation (EU) 2025/40 must be completed (Module A: internal production control). This is the systematic proof that a piece of packaging meets all of the applicable requirements from the regulation. The assessment forms the basis for the PPWR declaration of conformity and must be substantiated by the technical documentation.

Requirements that are evaluated by the assessment include the following, for example: minimisation of packaging, restricted substances, recyclability, recycled-content percentage, labelling and reusability (where relevant).

PPWR declaration of conformity (DoC)

In the future, each piece of packaging affected by the PPWR must have an EU declaration of conformity pursuant to Article 39 of Regulation (EU) 2025/40 (specimen in Annex VIII). This document is the manufacturer’s legal assurance that the packaging conforms to all applicable requirements of the PPWR.

The document includes details that identify the packaging and the manufacturer, a declaration of conformity with the PPWR, applicable harmonised norms or technical specifications, a date and a signature.

Digital documentation will become a key to success

Many companies will be turning to digital documentation systems to handle the significant increase in packaging record-keeping. These systems simplify cooperation along the supply chain while also enabling quick access to all of the relevant documents.

Check for Recycling – the packaging compliance tool from Interzero – offers targeted help here. From evaluating recyclability to the conformity assessment and the declaration of conformity, you can use our smart web app to meet all of your PPWR requirements while also enjoying access to the expertise provided by our packaging specialists. 

Manage your entire packaging portfolio from just one interface – check out Check for Recycling today!