PPWR Technical Documentation: What EU Packaging Buyers Should Ask Suppliers For

Your supplier sends you an EN 13432 certificate.

Is that your PPWR technical documentation?

No.

A certificate may support one part of the compliance file. It is not the whole technical file.

For EU packaging buyers, this distinction matters.

Under Regulation (EU) 2025/40, the manufacturer must carry out the applicable conformity assessment and prepare the technical documentation described in Annex VII. The Regulation also creates separate obligations for suppliers and importers.

So when you source packaging from outside the EU, the useful question is not:

“Can you send me your PPWR certificate?”

A better question is:

“Can you provide the product data, test evidence, certification and traceability information needed to support the PPWR requirements that apply to this finished packaging?”

That gives your supplier something specific to answer.

This guide explains what an EU packaging buyer should ask for, how the main documents differ, and how those documents should connect to the actual bag, mailer or packaging specification being purchased.

For the wider regulatory framework, see our PPWR compostable packaging guide.

What Is PPWR Technical Documentation?

PPWR technical documentation is the evidence file used to support the conformity assessment of packaging.

You may also hear terms such as:

• PPWR technical file;
• packaging technical dossier;
• compliance file;
• technical dossier;
• conformity evidence.

These terms are often used informally.

The formal PPWR reference is the technical documentation set out in Annex VII.

It should make it possible to assess whether the packaging meets the PPWR requirements that apply to it.

That means the technical file should answer questions such as:

• What exactly is the packaging?
• What is it made from?
• What is its intended use?
• Which requirements apply?
• Which standards or methods were used?
• What calculations or assessments support compliance?
• What tests were carried out?
• Which finished product does the evidence cover?

The Regulation links technical documentation to the conformity-assessment process and requires manufacturers to maintain that documentation. EUR-Lex

So think of the technical file as an evidence folder.

Not one certificate.

PPWR Technical File vs DoC vs Test Report

This is probably the most useful distinction for a buyer.

These documents are related.

They are not interchangeable.

Document	What it does
PPWR Technical Documentation	Holds the evidence supporting conformity
EU Declaration of Conformity	Formally declares that the packaging meets applicable requirements
Test Report	Provides test evidence for a specific property or requirement
Certificate	Supports a specific certified property or standard
Supplier Declaration	Provides supplier data or a formal statement about material/components
Product Specification	Defines the finished packaging being supplied
Traceability Record	Connects the product, batch and documents

A simple way to remember this is:

The DoC says the packaging complies.
The technical file explains why.
Test reports, certificates and supplier data provide supporting evidence.

The PPWR places the EU Declaration of Conformity in a separate Annex VIII framework rather than treating it as the technical documentation itself. EUR-Lex

What Is Annex VII Under PPWR?

Annex VII describes the content expected in the technical documentation used for PPWR conformity assessment.

The technical file should be detailed enough to assess whether the packaging meets the relevant requirements.

Depending on the packaging, this can include information such as:

• a general description of the packaging;
• intended use;
• design information;
• manufacturing information;
• relevant drawings;
• descriptions of materials and components;
• explanations needed to understand those drawings or designs;
• standards or specifications applied;
• design calculations or examinations where relevant;
• qualitative assessments;
• relevant test reports.

This is why a supplier’s marketing brochure cannot replace a technical file.

A brochure tells you what the supplier sells.

Technical documentation tells you what the packaging is and what evidence supports it.

The Regulation makes Annex VII part of the conformity-assessment framework.

The First Document to Ask For: Finished Packaging Specification

I would start here.

Before asking for certificates, make sure both sides agree on what product is actually being assessed.

For a compostable bag, the finished specification might include:

• bag width;
• bag length;
• gusset;
• flap;
• thickness;
• bag weight;
• material structure;
• colour;
• printing;
• ink system;
• adhesive;
• release liner;
• bags per roll;
• intended use.

For example:

Compostable mailer
350 × 450 + 50 mm flap
60 μm
Green
Two-colour printing
Self-seal adhesive strip

That is much more useful than:

Compostable mailing bag.

The technical evidence should connect to a defined packaging type.

Otherwise, you can end up with a folder full of valid documents that do not clearly match the product you are buying.

Why Finished Product Identification Matters

Imagine you approve this bag:

23 × 33 cm
20 μm
Purple
White one-colour printing
15 bags per roll

Your supplier has a certificate for a compostable resin.

That is helpful.

But what exactly does it prove about your finished bag?

The finished product also contains or reflects:

• film thickness;
• colour masterbatch;
• printing ink;
• processing conditions;
• finished dimensions.

If you later change from:

20 μm

to:

25 μm

or from:

unprinted

to:

two-colour printing

the technical question may change.

This is why the finished packaging specification should sit near the front of the PPWR technical file.

What Material Information Should a Buyer Ask For?

The next layer is material information.

For a biodegradable or compostable bag project, that may include information about:

• PBAT;
• PLA;
• starch;
• additives;
• colour masterbatch;
• printing ink;
• adhesive;
• release liner.

But there is an important commercial point.

A buyer does not necessarily need the supplier’s complete confidential recipe.

There is a difference between:

compliance-relevant material information

and:

confidential formulation know-how.

The purpose of the documentation request should be to gather enough information to assess compliance.

It is not automatically a request for every proprietary manufacturing detail.

For B2B sourcing, this distinction can avoid unnecessary conflict between the buyer’s compliance team and the manufacturer’s IP concerns.

What Should a Material Declaration Show?

Depending on the PPWR requirement being assessed, a material or supplier declaration may help identify:

• main material category;
• relevant polymers;
• additives relevant to compliance;
• coating or adhesive information;
• ink system;
• restricted-substance information;
• percentage composition where needed;
• supplier or material grade;
• batch or material reference.

The correct level of detail depends on the requirement.

Do not collect data simply because a checklist says:

“Material certificate required.”

Ask:

What compliance question does this document answer?

That makes the technical file easier to manage.

Do You Need Test Reports?

Often, yes, where testing is needed to support an applicable requirement.

But a test report should have a purpose.

For example, depending on the packaging and claims, supporting evidence may concern:

• compostability;
• material composition;
• restricted substances;
• food-contact performance;
• physical properties;
• other PPWR-related requirements.

Annex VII specifically includes relevant test reports among the types of evidence used in technical documentation. EUR-Lex

The mistake is asking:

“Please send all your laboratory reports.”

That can produce 40 PDFs and very little clarity.

A better request is:

“Please provide the test report that supports this requirement for this product or material.”

Now each report has a job.

Certificate vs Test Report: What Is the Difference?

These are often treated as the same thing.

They are not.

Certificate

A certification body may issue a certificate confirming that a product or material falls within the scope of a certification scheme.

For compostable packaging, examples may include certification related to:

• EN 13432;
• industrial compostability;
• home compostability.

Test report

A laboratory test report provides results from specific testing.

It tells you what was tested, under what method and with what result.

A certificate may rely on testing.

But the two documents still serve different purposes.

For PPWR buyers, I would ask for both only where both are relevant.

Do not collect documents for decoration.

Does an EN 13432 Certificate Count as PPWR Technical Documentation?

It can be part of the supporting evidence.

It is not the full technical file.

This matters for compostable packaging buyers.

EN 13432 relates to packaging recoverable through composting and biodegradation and remains an important industrial-compostability reference. PPWR’s 2026 Commission Guidance also discusses the transition toward updated harmonised standards under the new regulatory framework. EUR-Lex

But an EN 13432 certificate does not by itself provide:

• the full finished-product description;
• all PPWR assessments;
• traceability;
• manufacturing information;
• all applicable test evidence;
• the EU Declaration of Conformity.

So I would write this clearly in a supplier checklist:

EN 13432 certificate: supporting evidence where relevant, not a substitute for the PPWR technical file.

For a detailed comparison, see our PPWR vs EN 13432 guide.

Raw Material Certificate vs Finished Packaging Evidence

This is one of the most important questions for custom packaging.

Suppose the certified material is converted into:

450 × 600 mm compostable mailer
65 μm
Black
2-colour print
Double adhesive strip

The finished package may involve:

• the certified base material;
• colour masterbatch;
• printing;
• adhesive;
• liner;
• additional processing.

So ask:

What exactly does the certificate cover?

• raw material?
• compound?
• film?
• finished package?

What thickness does it cover?

Are colour and printing within scope?

Does the evidence address adhesives or other components?

A document can be genuine and still be irrelevant to your exact finished packaging.

That is why certificate scope is often more important than certificate quantity.

What Is a PPWR EU Declaration of Conformity?

The EU Declaration of Conformity, often shortened to DoC, is the manufacturer’s formal declaration that the packaging meets the applicable PPWR requirements covered by the conformity assessment.

PPWR provides the model structure in Annex VIII.

A DoC is not the same as:

• an EN 13432 certificate;
• a TDS;
• an SDS;
• a laboratory report;
• a supplier specification.

Those documents may support the conformity assessment.

The DoC is the formal declaration resulting from that process.

Who Issues the PPWR Declaration of Conformity?

This is where role definitions matter.

Do not assume:

physical factory = always the PPWR legal manufacturer.

PPWR assigns obligations according to economic-operator roles.

Depending on the supply chain, those roles can include:

• manufacturer;
• supplier;
• importer;
• distributor.

The manufacturer has the core obligation to carry out conformity assessment, prepare Annex VII technical documentation and draw up the EU Declaration of Conformity. Suppliers have duties to provide manufacturers with the information and documentation needed to demonstrate compliance. Importers have their own verification obligations before placing imported packaging on the EU market.

That matters for private-label packaging.

The physical producer in China may provide a large amount of technical evidence.

But you still need to identify who is acting as the manufacturer for the PPWR project before deciding who prepares and signs the final DoC.

Supplier vs Manufacturer: Why the Difference Matters

Imagine this supply chain:

Chinese Packaging Factory
          ↓
Technical product data
Test reports
Material evidence
Certificates
          ↓
EU Brand / Importer
          ↓
Packaging placed on EU market

It is tempting to call every company simply:

supplier.

But PPWR duties are role-specific.

That is why your sourcing team should first map:

• Who makes the physical packaging?
• Who markets it under whose name?
• Who imports it?
• Who is the legal manufacturer?
• Who maintains the technical file?
• Who issues the DoC?

Then documentation responsibilities become clearer.

What Does PPWR Article 16 Mean for Suppliers?

Article 16 is especially relevant to supply chains.

It requires suppliers of packaging or packaging materials to provide manufacturers with the information and documentation needed to demonstrate conformity with applicable PPWR requirements.

For a buyer, this means supplier cooperation matters.

The supplier may need to provide technical inputs such as:

• product specifications;
• material data;
• certificates;
• test results;
• drawings;
• component information;
• other compliance evidence.

This is much more specific than:

“Supplier shall comply with PPWR.”

A good supply agreement should address the evidence needed to support the actual product.

What Should an EU Importer Verify?

Importers have their own PPWR responsibilities.

Before placing relevant imported packaging on the Union market, an importer should verify matters including whether the conformity-assessment process has been carried out and the required technical documentation exists. The Regulation also addresses manufacturer identification, applicable marking/labelling and documentation.

For procurement teams, I would translate this into a simple rule:

Do not wait until customs clearance or a customer audit to ask where the technical file is.

Documentation should be discussed during supplier qualification.

Ideally, before mass production.

PPWR Technical Documentation Checklist for EU Buyers

Here is a practical starting checklist.

1. Finished Packaging Specification

Ask for:

• product name;
• SKU/article number;
• size;
• thickness;
• weight;
• intended use;
• construction;
• colour;
• printing;
• closures or adhesives.

2. Material and Component Information

Ask for information relevant to:

• main material;
• polymer system;
• masterbatch;
• inks;
• adhesives;
• labels;
• liners;
• other components.

3. Manufacturing / Design Information

Where relevant, collect:

• drawings;
• dielines;
• dimensions;
• construction details;
• manufacturing specifications.

This helps connect the evidence to the finished design.

4. Applicable Standards

Identify which standards or technical specifications are being used.

For a compostable project, this might include an industrial-compostability standard where relevant.

For another packaging format, different standards may apply.

Do not use one standard as a universal answer to PPWR.

5. Test Evidence

Ask for the tests needed to support the applicable requirements.

Possible examples include:

• compostability testing;
• restricted-substance testing;
• material analysis;
• food-contact tests where separately applicable;
• other relevant performance or compliance testing.

6. Certificates

Ask:

• Who issued the certificate?
• Who holds it?
• What does it cover?
• What thickness range?
• Which materials?
• Which colours?
• Which printing conditions?
• Is it still valid?

7. Conformity Assessment Information

Confirm:

• which PPWR requirements were assessed;
• what evidence supports them;
• who conducted the assessment;
• which version of the packaging was assessed.

8. EU Declaration of Conformity

Where required, confirm:

• legal manufacturer;
• product identification;
• applicable PPWR requirements;
• signatory;
• issue date;
• link to supporting technical documentation.

9. Traceability Information

Ask how the product can be connected to:

• SKU;
• product type;
• production batch;
• purchase order;
• certificate;
• test report;
• technical file.

This should not rely on someone’s memory six months later.

Why Traceability Matters

Traceability means being able to follow a product through the supply chain and identify which documentation applies to it.

For a simple purchasing team, I would think of it like this:

Finished Bag
    ↓
SKU / Article Number
    ↓
Specification Revision
    ↓
Batch / PO
    ↓
Material Information
    ↓
Test Evidence
    ↓
Technical File
    ↓
DoC

If you cannot connect those items, your document system is weak.

You may have certificates.

But you do not have strong traceability.

PPWR includes product-identification and traceability obligations within the manufacturer framework.

Type Number, Batch Number and Product Identification

For B2B packaging, I recommend using a consistent identifier.

It might be:

• SKU;
• article number;
• internal item number;
• product type;
• batch number;
• purchase-order number.

The key is consistency.

For example:

Customer SKU: ABC-MAILER-350450-60
Supplier Item: OZ-M350450-60-GRN
PO: 260812-01
Batch: 202608-M03

Now a test report, specification and production batch can be connected.

That is far better than naming files:

new certificate final latest.pdf

Good documentation should still make sense two years later.

Does Every SKU Need Its Own PPWR Technical File?

Not necessarily in the sense of creating a completely separate folder from zero for every minor variation.

But the technical documentation must clearly cover the packaging being placed on the market.

A manufacturer may have product families that share:

• materials;
• processes;
• tests;
• construction.

But differences can matter.

For example:

Same mailer material
Different size

may be easier to group than:

Same size
Different polymer formulation
Different adhesive
Different print system

The real question is:

Can you clearly demonstrate which evidence covers each finished packaging type?

If not, create a clearer separation.

A Practical Documentation Example: Compostable Mailer

Imagine you are an EU importer buying:

350 × 450 + 50 mm
60 μm
green compostable mailer
2-colour printing
double adhesive strip

What would I ask the supplier for?

Product data

• finished specification;
• dimensions;
• thickness;
• film construction;
• adhesive-strip design.

Material information

• base material;
• colour masterbatch;
• ink;
• adhesive;
• release liner.

Supporting evidence

• relevant compostability certificate/test evidence;
• certificate scope;
• applicable substance evidence;
• other relevant reports.

Traceability

• item number;
• batch;
• PO;
• specification revision.

PPWR documentation

Then determine:

• applicable PPWR requirements;
• conformity-assessment responsibilities;
• Annex VII technical-file content;
• DoC responsibility.

Notice the order.

I would not begin by asking:

“Where is your PPWR certificate?”

A Second Example: Compostable Produce Bag

Now imagine:

260 + 60 × 2 × 450 mm
12 μm
250 bags/roll
green tint
one-colour printing
direct food-contact use

The documentation question changes.

You may now need to review:

• very lightweight carrier-bag classification;
• Article 9 pathway;
• target Member State;
• compostability evidence;
• food-contact documentation;
• film thickness;
• colour;
• printing.

One certificate cannot answer all of those questions.

This is why PPWR technical documentation should follow the product, not a generic corporate certificate folder.

For the specific produce-bag regulatory issues, see our PPWR compostable produce bags guide.

What About Food-Contact Documents?

Food-contact compliance is separate from PPWR.

If packaging is designed to touch food, the applicable EU food-contact framework also needs to be considered.

Do not mix these into one vague statement such as:

“The bag is EU certified.”

Ask which legislation each document supports.

A food-contact migration report answers a different question from:

• EN 13432;
• PPWR material data;
• recyclability evidence.

Different requirement.

Different evidence.

PPWR Supplier Documentation Matrix

This table can be used directly by a purchasing team.

What to ask for	Why you need it	Typical source	Part of technical evidence?
Finished specification	Defines actual packaging	Supplier/manufacturer	Yes
Material information	Supports material assessment	Material/packaging supplier	Yes
Drawing/dieline	Defines construction	Manufacturer	Yes
Test report	Supports a requirement	Lab/supplier	Yes
Compostability certificate	Supports compostability claim	Certification body	Where relevant
Supplier declaration	Provides component/material data	Supplier	Where relevant
Batch/type ID	Traceability	Manufacturer	Yes
Annex VII technical file	Evidence supporting conformity	Manufacturer	Core file
Annex VIII DoC	Formal conformity declaration	Manufacturer	Separate but linked

The main idea is simple:

Documents need roles.

A PDF that does not answer a defined compliance question is just another PDF.

Do Not Ask for “All PPWR Documents”

This is a common sourcing mistake.

The buyer writes:

Please send all PPWR certificates and documents.

The supplier sends:

• EN 13432;
• ASTM D6400;
• BPI;
• factory ISO;
• SDS;
• TDS;
• food-contact report;
• old product certificate.

Twenty attachments arrive.

The buyer still does not know:

Which documents cover my bag?

A better request is structured.

For example:

Please provide the finished-product specification, relevant material/component information, applicable test reports and certificates, certificate scope, product/batch identification and any technical evidence needed to support the applicable PPWR requirements for this packaging.

Much better.

What Should a Supplier Document Request Look Like?

For a first supplier request, I would keep it practical.

You could ask for:

Product Identification

• product name;
• article/SKU;
• specification;
• intended use.

Composition

• main material;
• relevant components;
• ink;
• masterbatch;
• adhesives.

Evidence

• relevant certificates;
• test reports;
• supplier declarations.

Traceability

• batch/type identification;
• manufacturing site;
• product revision.

PPWR Support

• applicable technical documentation;
• available conformity information;
• supporting evidence for the requirements relevant to the product.

Then fill gaps after review.

Do not demand every theoretical document before you even know the product specification.

What Is a Supplier Declaration?

A supplier declaration is a statement provided by a material or component supplier.

For example, it might confirm:

• material identity;
• composition information;
• restricted-substance information;
• grade;
• compliance with a defined requirement.

It can be useful evidence.

But a supplier declaration is not automatically equivalent to an independent test report.

Which type of evidence is sufficient depends on the requirement and the assessment method.

Again, ask:

What does this document prove?

SDS and TDS: Are They Enough?

Usually not by themselves.

An SDS, or Safety Data Sheet, focuses mainly on chemical safety and handling.

A TDS, or Technical Data Sheet, provides technical product information.

Both can be useful.

But neither automatically proves PPWR conformity.

They may support the technical file.

They do not replace the conformity assessment.

This distinction is especially important when sourcing resins or compounds.

Who Should Hold the Technical File?

The legal responsibility sits with the relevant manufacturer under PPWR.

But documents can come from different parts of the supply chain.

For example:

Raw Material Supplier
        ↓
Material data / declarations
        ↓
Bag Manufacturer
        ↓
Finished specification / production evidence
        ↓
Testing / Certification Body
        ↓
Test reports / certificates
        ↓
Legal Manufacturer
        ↓
Annex VII Technical Documentation
        ↓
EU Declaration of Conformity

In practice, several companies may contribute evidence.

That does not mean all of them have the same legal role.

How Long Must PPWR Technical Documentation Be Kept?

PPWR requires manufacturers to retain the Annex VII technical documentation and EU Declaration of Conformity for defined periods.

For single-use packaging, the retention period is generally five years after the packaging is placed on the market.

For reusable packaging, the period is generally 10 years after the packaging is placed on the market.

This means document storage should not depend on one employee’s email inbox.

Use a structured system.

When Should the Technical File Be Updated?

A technical file should not be treated as a document you create once and never look at again.

PPWR requires manufacturers to consider changes in packaging design, characteristics, standards or specifications that may affect conformity. EUR-Lex

For custom bags, I would review the file when something important changes.

Examples include:

• polymer formulation;
• raw-material supplier;
• film thickness;
• colour masterbatch;
• printing ink;
• print coverage;
• adhesive;
• release liner;
• bag structure;
• intended use;
• applicable standard.

Not every minor production variation means starting from zero.

But compliance-relevant changes should be reviewed.

Change Notification Should Be Part of Supplier Management

This is something I would put into B2B purchasing terms.

Ask suppliers to notify you before making compliance-relevant changes.

For example:

Please notify us before changing the base material, formulation, masterbatch, printing ink, adhesive, coating or other component that may affect the approved specification or compliance evidence.

Why?

Because the buyer may have approved one technical file.

A quiet material change can make part of that evidence outdated.

Supplier documentation is not only about getting files at the beginning.

It is also about controlling changes later.

Version Control Matters

Suppose you have:

Mailer Specification V1
60 μm
Green
1-colour print

Then six months later:

Mailer Specification V2
55 μm
Green
2-colour print
New adhesive

Do not overwrite V1.

Keep clear revision records.

For example:

OZ-MAILER-001
Rev 01 – 60 μm / 1C
Rev 02 – 55 μm / 2C / Adhesive B

Then link each revision to the evidence that applies.

Simple version control can prevent major confusion.

Seven Documentation Mistakes EU Buyers Should Avoid

1. Asking for a “PPWR certificate”

PPWR compliance is not reduced to one universal certificate.

Ask for supporting evidence instead.

2. Treating EN 13432 as the complete PPWR file

It may support compostability.

It does not cover the entire PPWR assessment.

3. Accepting raw-material documents without checking finished-product scope

Your customer buys the finished bag.

Review the finished bag.

4. Collecting test reports without knowing what they support

Every report should answer a defined question.

5. Ignoring traceability

Documents should connect to the actual product, SKU and batch.

6. Ignoring supplier changes

A technical file based on an old formulation may no longer support a changed product.

7. Assuming the physical supplier must issue every PPWR document

Map the legal roles first.

Supplier, manufacturer and importer are not automatically the same entity.

A Better Supplier-Onboarding Workflow

I would use this order.

Step 1 — Define the packaging

Agree on:

• size;
• thickness;
• material;
• printing;
• use;
• target country.

Step 2 — Identify applicable PPWR requirements

Do not request documents without knowing what you are assessing.

Step 3 — Identify supply-chain roles

Who is:

• supplier?
• manufacturer?
• importer?

Step 4 — Request supporting evidence

Ask for the documents relevant to the product.

Step 5 — Match evidence to the finished packaging

Check scope.

Step 6 — Identify gaps

Do you need:

• additional testing?
• a supplier declaration?
• a new specification?
• clearer traceability?

Step 7 — Complete conformity assessment

Build the Annex VII technical file.

Step 8 — Prepare the DoC

Once applicable conformity has been demonstrated.

Step 9 — Control changes

Do not let the approved product change without documentation review.

That is a much stronger process than:

certificate → purchase order → hope.

How ORIZON Supports B2B Packaging Documentation

For custom compostable bag projects, our role is to provide product and manufacturing information relevant to the finished packaging we supply.

Depending on the project, that can include information such as:

• finished-bag specification;
• dimensions and thickness;
• material information;
• available compostability certificates;
• certificate scope;
• relevant test documentation;
• printing information;
• batch/product identification;
• OEM production details.

We manufacture formats including:

• compostable garbage bags;
• supermarket shopping bags;
• produce bags;
• compostable mailers;
• garment bags;
• dog waste bags;
• custom OEM formats.

For an EU project, I prefer to identify the finished specification first.

That means asking for:

• target country;
• bag application;
• dimensions;
• thickness;
• colour;
• printing;
• certification needs;
• documentation needs;
• order quantity.

Then the technical discussion has a real product behind it.

For custom specifications, see our OEM compostable bags.

If you already have an EU project and want to discuss specifications and available documentation, you can contact us.

FAQ

What is PPWR technical documentation?

PPWR technical documentation is the evidence file used to support packaging conformity assessment under Regulation (EU) 2025/40.

Annex VII sets out the technical-documentation framework.

What must be included in a PPWR technical file?

Depending on the packaging, the file can include product descriptions, intended use, design and manufacturing information, material/component information, relevant standards, assessments and test reports.

Is a PPWR Declaration of Conformity the same as technical documentation?

No.

The technical file contains the evidence supporting conformity.

The EU Declaration of Conformity is the manufacturer’s formal declaration that the packaging meets the applicable requirements.

What is Annex VII under PPWR?

Annex VII sets out the technical documentation used in the PPWR conformity-assessment process.

It covers information needed to describe the packaging and support compliance with applicable requirements.

What is Annex VIII under PPWR?

Annex VIII sets out the structure of the EU Declaration of Conformity for packaging.

Does PPWR require test reports?

Relevant test reports can form part of Annex VII technical documentation where testing is needed to support the applicable requirements.

The exact tests depend on the packaging and requirements being assessed.

Does an EN 13432 certificate count as PPWR documentation?

It can support the technical file where industrial compostability is relevant.

It does not replace the complete PPWR technical documentation or EU Declaration of Conformity.

Who prepares PPWR technical documentation?

The manufacturer has the responsibility to prepare the required technical documentation as part of the PPWR conformity-assessment process.

Suppliers may provide supporting information and documents.

Who issues the PPWR EU Declaration of Conformity?

The manufacturer draws up the EU Declaration of Conformity after the applicable conformity requirements have been demonstrated.

The supply-chain roles should be identified carefully in OEM and private-label projects.

What should an EU importer ask a packaging supplier for?

Depending on the product, ask for the finished specification, material/component information, relevant test reports, certification scope, supplier declarations, product identification and traceability information, plus other evidence needed to support applicable PPWR requirements.

How long must PPWR technical documentation be retained?

The manufacturer generally retains technical documentation and the EU Declaration of Conformity for five years for single-use packaging and 10 years for reusable packaging after the packaging is placed on the market.

Does each packaging SKU need a separate PPWR technical file?

Not necessarily a completely separate file in every case.

But the manufacturer must be able to show clearly which technical evidence applies to each packaging type or product family.

Conclusion

PPWR technical documentation is not one certificate.

EU buyers should focus on whether the documents match the finished packaging they are buying.

At minimum, check:

• finished product specification;
• material and component information;
• relevant test reports and certificates;
• traceability;
• Annex VII technical documentation;
• EU Declaration of Conformity where applicable.

The key question is simple:

Does the evidence clearly support this exact packaging specification?

If not, ask for clarification before mass production.

For custom EU packaging projects, you can also review our OEM compostable bags or contact us to discuss the finished specification and available documentation.

This guide provides general B2B packaging information and is not legal advice.