Technical Documentation (PPWR)

Technical Documentation is the technical file underlying the Declaration of Conformity (DoC) under the Packaging and Packaging Waste Regulation (PPWR). While the Declaration of Conformity is the manufacturer's formal statement, the technical documentation contains the concrete evidence on which that statement is based.

Typical contents include information on the design and materials used in the packaging, the results of assessments of recyclability and material minimization, test reports, for example on compliance with substance restrictions on per- and polyfluoroalkyl substances (PFAS) and heavy metals for food-contact packaging, and supplier declarations and references to applied standards or test methods.

Technical Documentation is subject to the same retention periods as the DoC: at least five years for single-use packaging and at least ten years for reusable packaging after the last placement on the market. It must be provided to the relevant market surveillance authorities on request, but is not intended for general publication.

Since harmonized standards are not yet available for many PPWR requirements, companies currently often have to demonstrate conformity through their own documented test methods and testing. This requires structured, ongoing data collection from packaging design through to material sourcing, to ensure complete evidence is available in the event of a regulatory inspection.