Short answer: Manufacturers retain the technical documentation and EU Declaration of Conformity for five years for single-use packaging and ten years for reusable packaging from the date the packaging was placed on the market. Importers must retain a copy of the declaration for the same respective periods.
Manufacturer retention
Article 15(3) sets the five- and ten-year periods. The file should record the first and last relevant placing-on-the-market dates, because a generic creation date does not reliably establish when retention ends.
Importer retention
Article 18 requires importers to keep a copy of the EU Declaration of Conformity at the disposal of market-surveillance authorities and ensure that technical documentation can be made available upon request. The importer does not necessarily hold the entire technical file, but it needs a tested retrieval route.
What should be retained?
- Released technical-documentation version.
- Signed EU Declaration of Conformity.
- Evidence index and controlled supporting records.
- Packaging identity and market dates.
- Approvals and change history.
- Correspondence closing material conformity gaps.
- Importer verification and retrieval records where applicable.
Retention is not the same as keeping an inbox
Documents should remain readable, version-controlled and linked to the packaging type. Define ownership when staff, suppliers or systems change. Test retrieval periodically and preserve the evidence needed to understand why the conformity decision was made.