PPWR Technical Documentation (Annex VII): Build It Once, Use It Everywhere

PPWR Technical Documentation (Annex VII): Build It Once, Use It Everywhere

The folder that answers every question at once - what Annex VII requires, where the evidence comes from, and how to keep it for 5 or 10 years.

The folder that answers every question at once

Technical documentation (Annex VII) is the evidence base under every Declaration of Conformity: it records what the packaging is, what it is made of, and why it is claimed compliant - and market surveillance can ask for it within 10 days. A DoC without technical documentation is a conclusion without a case file. We have said it to suppliers, to buyers and to ourselves: build the folder once, and it answers PPWR questions, EPR data requests and buyer audits for years.

What Annex VII actually requires

Where the evidence comes from: three layers

Suppliers (carton factory, bag maker, tape maker): test reports and material declarations - the factual source.

The factory (you): assembles supplier evidence per packaging variant, adding your specifications, drawings and weights.

The producer (the signer): reviews and signs the DoC, confirming the evidence supports the conclusion.

The useful insight: you do not need to know how to test packaging; you need to know how to file it. Testing is the supplier's job; filing is yours.

The relationship between the DoC and the technical documentation

Think of them as one evidence package with two jobs:

The technical documentation answers "on what basis is it compliant?"
The DoC answers "who is responsible for that conclusion?"
The importer verifies both exist before placing goods on the market.
Market surveillance can demand the technical documentation within 10 days.

Neither works alone. A file without a signature proves nothing; a signature without a file vouches for nothing.

Retention and response: 5/10 years and 10 days

Retention: five years for single-use packaging, ten years for reusable, from the last placing on the market. Keep the DoC and technical documentation together - they are one case file.
Response: 10 calendar days from a written market surveillance request. That rules out "it is in someone's email". A cloud folder with versioned filenames and controlled access is enough; software is a convenience, discipline is the requirement.
Language: the DoC must be in a language easily understood in the member state. Technical documentation itself has no hard language rule, but attaching English translations is cheap insurance.

How to build it: five steps

List every packaging component per SKU in a register - material type, weight, supplier.

Send each supplier a material declaration template and collect signed copies.

Collect third-party test reports for medium- and high-risk components and check them against five acceptance criteria: accredited lab, matching sample identity, the four metals reported, 100 mg/kg combined limit, traceable report number and date.

Create one folder per packaging variant: declarations, reports, specification, drawings - names with version and date.

Have the signer review, sign the DoC, archive the folder and back it up.

About this series

Written by the team behind a luggage factory in Jiangxi, China, for importers, factories and component suppliers who want the same working knowledge. No promotion, just what we'd tell a friend who asked. Author: CLK Luggage Academy —

Requirement	What it looks like in your files
General description and intended use	Packaging specification sheet (dimensions, purpose)
Design and construction drawings	Box construction diagram, layer structure
Material composition of all components	Supplier material declarations plus your bill of materials
Standards or technical specifications applied	Test standard numbers, internal methods
Qualitative recyclability/minimisation/reusability assessment	Recyclability note for the carton, minimisation rationale
Recycled-content calculations (where relevant)	Recycled-content certificates or declarations
Substance-limit evidence (Article 5)	Heavy-metal test report, PFAS statement

FAQ

Is third-party testing mandatory for every component?

No. Low-risk materials (plain corrugated board from a known mill) can be supported by a material declaration plus occasional testing; plastics, printed materials and recycled content carry more risk and deserve real reports. Match the evidence strength to the risk.

When does the 10-day clock start?

From the date of the written market surveillance request. That is why the file must be findable the same day - never rebuilt under pressure.

Can the technical documentation be electronic only?

Yes. Electronic files with versioning and cloud backup are standard practice. The failure mode is not the format; it is files living only on one person's computer.

One folder per variant, or one file for the whole shipment?

Organise by variant: the carton, polybag and tape each have their own evidence, and the technical documentation aggregates them per packaging variant. If one component lacks evidence, that variant's file is incomplete.

Who is responsible for the 10-day response?

The economic operator who can produce the files - in practice the producer or importer. When you hand the file pack to a buyer or importer, confirm they know where it is and can produce it.

How does this relate to the packaging register templates?

The register is the index, the declarations and reports are the evidence, and the DoC is the cover page. The methodology is this article; the register is the tool that makes it repeatable.