Short answer: Annex VII requires more than a folder of supplier certificates. The technical documentation must identify the packaging, describe its design and manufacture, show how applicable PPWR requirements were assessed and contain the evidence needed to understand the conformity conclusion.
File identity and scope
- Unique packaging-type or model identifier and current version.
- Intended use, variants and packaging level.
- Responsible manufacturer and relevant economic operators.
- Images, drawings or descriptions sufficient to identify the packaging.
- Components, materials, weights and supplier references.
Applicable-requirements matrix
List the requirements in Articles 5 to 12 and record whether each is applicable, not yet applicable or not applicable to the packaging. State the reason. A generic statement that the packaging “complies with PPWR” does not show what was assessed.
Evidence and assessment
- Specifications and controlled supplier data.
- Test reports, calculations and assessment methods.
- Substance information, including the relevant Article 5 position.
- Standards or common technical specifications used.
- Assumptions, limitations and unresolved gaps.
- A conclusion for every applicable requirement.
Declaration and document control
The EU Declaration of Conformity is the signed output of the conformity assessment; it is not a substitute for the underlying technical documentation. Match the packaging identifier, manufacturer, legislation and referenced standards across both documents. Record approval, version, change triggers and the retention end date.
Final review questions
- Can a reviewer identify the exact physical packaging covered?
- Can every conclusion be traced to evidence?
- Does the evidence match the current material and supplier version?
- Are non-applicable requirements explained?
- Does the declaration agree with the finished technical file?
- Can the file be retrieved for an authority without rebuilding it?