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PPWR roles, objectives and responsibilities at a glance
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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.
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
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.
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.
Other key documents due to become important in the future include:
- Confirmation of compliance with limits for substances of concern (from 12 August 2026): Limits for heavy metals and PFAS must be complied with and this compliance documented. For more information, see PPWR and chemicals.
- Documentation of labelling (from 12 August 2028): Covers material labelling, recycling information, reusability labelling, digital labelling and artwork/print approvals.
- Proof of recycled-content percentage (from 2030): Supplier declarations, certificates, material origin records, calculation of recycled-content percentage and accounting methods
- For Design for Recycling (from 2030): Materials used, material combinations, labels, adhesives, printing inks, additives, barriers, closures and separability of individual components. These particulars form the basis for the later assessment of recyclability.
- For Recycled at Scale (from 2035): Material flows, recycling pathways, available sorting technologies, recycling methods and industry-specific records
Even when the relevant duties do not become binding until a later date, work here should start as soon as possible – also with the aim of identifying gaps. Interzero is ready to assist you!
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!
Checklist: Which documents should companies start to prepare now?
A full set of PPWR documentation includes:
- Technical documentation
- EU declaration of conformity
- Supplier declarations
- Records of compliance with substance limits for packaging
- Change/version history
The following will become relevant over the next few years:
- Material data sheets
- Design for Recycling records
- Documentation of recycled-content percentages
- Labelling documentation
- Packaging specifications
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FAQ on PPWR documentation and evaluation
- Does every packaging item require an EU Declaration of Conformity?
Yes. For all packaging that falls within the scope of the PPWR, the manufacturer must issue an EU Declaration of Conformity (DoC).
- Does each individual packaging format need to be documented separately?
Not necessarily. It is not always required to create separate documentation for every individual size or variant. In certain cases, packaging variants may be grouped together, provided that they can be clearly identified and their conformity can be consistently demonstrated. This must always be assessed on a case-by-case basis.
- Do packaging components also need to be documented?
Yes. Closures, labels, adhesives, barrier coatings, and other packaging components can affect the recyclability of a packaging solution. Therefore, these elements must also be considered within the technical documentation.
- Do existing packaging products also need to be documented?
Yes. If packaging was first placed on the market after 12 August 2026 and falls under the requirements of the PPWR, its conformity must be demonstrated regardless of when the packaging was originally developed.
- What happens if changes are made to a packaging design?
Any changes to materials, structure, or components should be reviewed to determine whether they affect conformity with the applicable requirements. Where necessary, the technical documentation, conformity assessment, and EU Declaration of Conformity must be updated accordingly.
- Who signs the EU Declaration of Conformity?
The EU Declaration of Conformity is signed by the manufacturer or an authorized representative of the company. By signing the declaration, the manufacturer assumes responsibility for the conformity of the packaging.
- Does the PPWR prescribe a specific format for technical documentation?
No. The PPWR does not require a specific documentation format. Companies may maintain their documentation as a digital product dossier, within a quality management system, or through a document management system. The key requirement is that the documentation remains complete, traceable, and up to date.
- How long must documentation be retained?
As a general rule, technical documentation and the EU Declaration of Conformity must be retained for at least five years for single-use packaging and ten years for reusable packaging after the packaging has been placed on the market. Upon request, the relevant documentation must be provided to the competent authorities within ten days. Companies should also verify whether other applicable legislation imposes longer retention periods.
- What are the consequences of missing documentation?
If the required documentation is not available or if the conformity of a packaging item cannot be demonstrated, market surveillance authorities may take enforcement action. Such measures may include requests for corrective action, restrictions on market placement or distribution, and, in serious cases, a prohibition on making the packaging available on the EU market.
- Will companies be required to document recyclability assessments from 2026 onward?
Documentation of recyclability will become mandatory once the European Commission publishes the applicable assessment methodology.
- Does Design for Recycling require a separate document?
No. Design for Recycling is not a standalone document but rather a regulatory requirement whose fulfilment must be demonstrated within the technical documentation. The assessment forms part of the overall conformity assessment of the packaging.
- What are the benefits of preparing documentation processes early?
Companies that establish their documentation processes at an early stage can integrate new requirements gradually and more efficiently. This reduces implementation efforts, improves collaboration with suppliers, and minimizes the risk that packaging products may no longer be placed on the market due to missing compliance evidence.
- What role do harmonized standards play?
Harmonized European standards will help ensure a consistent implementation of PPWR requirements across the market. Applying such standards may facilitate the conformity assessment process. As many standards are still under development, transitional provisions and technical specifications are expected to play an important role during the implementation phase.
- What is the significance of delegated acts?
The PPWR establishes the overarching legal framework. Many technical details will be specified through delegated acts and implementing acts. Companies should closely monitor these regulatory developments and update their documentation accordingly.
