From 12 August 2026, the EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) will apply: every type of packaging placed on the EU market must have an EU Declaration of Conformity (DoC) and full technical documentation.From 12 August 2026, every type of packaging placed on the EU market will require a valid PPWR Declaration of Conformity and underlying technical documentation.

This guide gives compliance, quality, and packaging teams a practical, step-by-step roadmap (you can find more detailed explanations in the PPWR Guide 2026):

  • which documentation obligations specifically apply under the PPWR
  • how to build robust technical documentation for your packaging portfolio
  • how to make effective use of compliance checklists and templates
  • how to connect PPWR requirements with the German Packaging Act (VerpackG)
  • how to integrate processes into existing systems and automate them via digital packaging management (e.g. Packa software)

Note: This article does not replace legal advice. It shows how to build documentation in a structured, data-driven, and audit-ready way.

Before you start: Clarify prerequisites and fundamentals

Before you use PPWR checklists, Declarations of Conformity or technical dossiers, clarify the basic prerequisites.

Technical and organizational prerequisites

  • Roles & responsibilities
    • Who holds PPWR responsibility in your organization (e.g. QA/Regulatory, Head of Packaging, Sustainability Manager)?
    • What is your company's role under the PPWR (for more information: Overview of roles in the PPWR)?
  • Scope & markets
    • In which EU countries do you place packaging on the market?
    • Which country-specific obligations from EPR/VerpackG are relevant?
  • Governance
    • Do you have a defined approval process for new or changed packaging?
    • Who signs the Declaration of Conformity (authorized signatory)?

Data and system prerequisites

  • Complete overview of your packaging portfolio (main packaging types)
  • Access to relevant data:
    • ERP / PIM / PLM
    • Supplier specifications and certificates
    • Laboratory reports, recyclability assessments, internal test reports
  • An initial structure for central packaging data (e.g. via digital packaging management such as Packa software)

Prepare templates and checklists

Introduce standardized documents early on:

  • PPWR Declaration of Conformity template (compliance template)
    • Structured Declaration of Conformity with all mandatory fields (identification, manufacturer details, legal references, signature).
    • Practical template, for example in the Packa article "PPWR Declaration of Conformity Template" or in the form PPWR Declaration of Conformity Template.
  • PPWR compliance checklist
    • Checklist to cover all requirements (recyclability, data availability, labeling, DoC, technical documentation), for example with the free PPWR checklist.

Step 1: Clearly define PPWR scope and roles

Before building documentation, define which packaging you are responsible for and in which role.

1.1 PPWR and its relationship to the Packaging Act (VerpackG)

  • The PPWR is an EU regulation with direct effect in all member states.The PPWR (Regulation (EU) 2025/40) entered into force on 11 February 2025 and, after a transition period, will apply fully across the EU from 12 August 2026.
  • The German Packaging Act (VerpackG) regulates extended producer responsibility (EPR), system participation, and reporting; it applies in addition to the PPWR.
  • Compliance teams must take both into account: PPWR documentation obligations (DoC and technical documentation) plus national obligations (e.g. notifications to the packaging register).

1.2 Clarify roles along the supply chain

Clearly identify your role(s):

  • Manufacturer: produces packaging or components and provides technical information.
  • Producer: first places products on the market in the member state; typically the brand owner or importer.
  • Importer: brings packaged goods from non-EU countries into the EU.
  • Distributor/Retailer: sells products that have already been placed on the market.

Tip: Create a role matrix (packaging type × country × role). This shows for which packaging you must issue the PPWR Declaration of Conformity yourself and where you need supplier documentation.

Step 2: Packaging inventory and data model for technical documentation

The quality of your technical documentation depends directly on your packaging master data.

2.1 Carry out a complete packaging inventory

Use the Packa guides as a reference (you can also find a more in-depth step-by-step guide in the PPWR Guide 2026):

  1. Record all sales, grouped, and transport packaging (including e-commerce packaging).
  2. Cluster packaging in a targeted way (e.g. by material, function, brand, market).
  3. Define variants:
    • When does a new packaging type arise (change of material, barrier, size)?

2.2 Data model for technical PPWR documentation

For technical documentation, the PPWR refers to Annex VII; common practice and specialist literature further specify typical contents.Technical documentation under the PPWR refers to Annex VII and includes, among other things, material composition, supplier declarations, test reports, recyclability assessments, and evidence of traceability.

Your data model should include at least the following fields for each packaging type:

  • Identification: internal ID, article number, where applicable EAN, brand/product family
  • Structure: primary/secondary/tertiary packaging, e-commerce packaging
  • Material data:
    • Main materials (e.g. PET, HDPE, PP, board)
    • Layers (film, barrier, coatings, varnishes, adhesives)
    • Weights per component
    • Recycled content (post-consumer/pre-consumer)
  • Substance-related aspects:
    • Food contact, PFAS, heavy metals, other regulatory restrictions
  • Recycling information:
    • Classification according to a recognized method (e.g. minimum standard, industry guidelines)
  • Functional data: reusability, fill volume, empty space ratio (especially for e-commerce), service life for reusable packaging
  • Sources and evidence:
    • Supplier specifications
    • Test reports/lab reports
    • Supplier declarations and certificates

Common mistake: Packaging lists that are too high level (e.g. "brown board 200 g/m²"). For the PPWR you need a precise description of materials and layers.

Step 3: Collect data and evidence from suppliers in a structured way

Without complete supplier data, you cannot create correct Declarations of Conformity or assessments.

3.1 Create standardized request documents

Define uniform data requirements for all suppliers:

  • Technical specifications (layer structure, grammages, tolerances)
  • Evidence of recyclability and sortability
  • Details of recycled content and origin
  • Compliance with substance regulations (e.g. food contact, PFAS, heavy metals)
  • Existing Declarations of Conformity and certificates

Where possible, use compliance templates for each material group.

Tip: Use digital supplier portals or automated queries. Solutions like Packa combine structured questionnaires with automatic data capture and validation.

3.2 Identify and prioritize data gaps

Packa projects show that a large share of packaging data is often incomplete.In many companies, a structured data gap analysis typically reveals 30-70% missing or incomplete packaging data. Set up gap reporting:

  • Which packaging has critical data gaps (e.g. unknown coatings, missing recyclability assessments)?
  • Which suppliers regularly provide incomplete information?
  • Which items have high revenue or volume and should be prioritized?

Step 4: Systematically carry out PPWR conformity assessments

Every Declaration of Conformity requires a documented assessment of whether the packaging meets PPWR requirements.

Typical review areas:

  1. Recyclability
    • Does the design meet the requirements (material combinations, colors, labels, closures)?
    • Are there supporting documents, expert opinions, or industry standards?
  2. Packaging minimization and formats
    • Does the weight meet the minimum required for protection and function?
    • Is the empty space ratio in e-commerce packaging compliant?
  3. Material restrictions and critical substances
    • Compliance with bans/limits (e.g. PFAS, heavy metals)
  4. Reusability and recycled content quotas
    • Evidence of reuse criteria and recycled content
  5. Labeling and data access
    • Are material codes, recycling instructions, and digital information taken into account?

Tip: Also document the assessment method - for example, the recyclability standard used or your reasoning for minimization. This is an indispensable part of the technical file.

Step 5: Create the EU Declaration of Conformity (DoC) in a structured way

The PPWR Declaration of Conformity provides legally compliant documentation for authorities and business partners.

5.1 Mandatory contents under PPWR (Annex VIII)

According to Annex VIII, the EU DoC must include, among other things, a unique identification number, manufacturer details, a clear identification of the packaging, the formal declaration of conformity with Articles 5-12, and the signature of an authorized person.

A typical DoC structure:

  1. Unique identification number
  2. Name and address of the responsible party
  3. Packaging identification (designation, type, material, optionally image/drawing)
  4. Legal reference - PPWR (Regulation (EU) 2025/40) and relevant articles
  5. Reference to technical documentation (internal document ID / storage location)
  6. Applied standards/methods
  7. Declaration wording and signature

Further explanations can be found in the Packa guide, in the section PPWR Declaration of Conformity as well as in the complementary PPWR Guide 2026.

5.2 Practical mini-checklist for every DoC

Before approval, check each DoC using this compliance checklist:

Common mistake: Descriptions that are too generic, such as "bottle 1 L", cause confusion during audits. Use internal article numbers and precise descriptions.

Step 6: Compile, version, and retain technical PPWR documentation

The Declaration of Conformity is only valid together with the associated complete technical documentation.

6.1 Contents of the technical documentation

Technical PPWR documentation includes:

  • Complete material and structure details for each packaging
  • Supplier specifications and declarations
  • Test and analysis reports (e.g. food contact, PFAS, heavy metals)
  • Recyclability assessments including the methods used
  • Evidence of packaging minimization and empty space ratio
  • Drawings, bills of materials, design and process documentation
  • Traceability: assignment to batches, production sites, supply chain

6.2 Retention periods and access

Manufacturers must retain the EU Declaration of Conformity and the technical documentation for at least five years for single-use packaging and ten years for reusable packaging.

Ensure that you have:

  • Fast access for authority requests
  • Clear access rights (e.g. compliance, quality, procurement)
  • Clean version control (change history, approved versions)

Tip: Use a central PPWR data register linking all relevant documents, status indicators, and responsibilities.

Step 7: Integrate into existing systems and automate with digital packaging management

For larger portfolios, Excel spreadsheets and shared drives quickly reach their limits. Specialized digital packaging management solutions, such as Packa, solve this problem.

7.1 Why Excel is no longer sufficient

  • Manual data maintenance does not scale for large portfolios
  • Cross-functional version control is hard to trace
  • Audit readiness and evidence are difficult to document
  • PPWR updates or new requirements cannot be applied automatically

7.2 Benefits of digital packaging management software (example: Packa)

With Packa software for digital packaging management, you manage your PPWR documentation systematically and automatically:

  • Central packaging database for specifications, materials, and evidence
  • AI-supported specification digitization
  • Integrated compliance checks for PPWR and other requirements
  • Automated supplier communication and certificate management
  • Audit-ready documentation and reporting for authorities and internal audits

This turns your PPWR documentation into a continuous, transparent process.

Practical tip: Start with a pilot category (e.g. bottles and closures), digitize specifications and DoCs, and then scale the approach.

Talk to Packa

Next steps: How to further build out your PPWR documentation system

Once you have completed steps 1-7, you have a solid PPWR documentation system. Typical next steps (you can find further recommendations in the PPWR Guide 2026):

  • Deepen your gap analysis
  • Plan DoC rollout
    • Create a roadmap by packaging group outlining when a signed DoC must be available.
  • Embed processes
    • Integrate PPWR requirements firmly into approval processes and supplier contracts.
  • Train teams
    • Train specialist departments on roles and data requirements - for example with free packaging webinars from Packa.

With checklists, templates, and digital workflows, you can turn PPWR documentation into a scalable part of your packaging management.

FAQ on technical PPWR documentation and Declarations of Conformity

1. Do I need a separate PPWR Declaration of Conformity for each individual packaging?

As a general rule, you need a separate declaration for every distinct packaging type.Under the PPWR, a separate declaration is generally required for each distinct packaging type. If materials, structure, and function are identical, you can group packaging together. Significant changes (material, barrier, size, operating conditions) require new DoCs.

2. How are PPWR documentation and the Packaging Act (VerpackG) related?

The PPWR regulates design, recyclability, and documentation obligations (including technical documentation and DoC). The Packaging Act (VerpackG) remains relevant for EPR, system participation, and reporting. Your packaging data must be structured so that you can meet both sets of requirements.

3. What minimum data should my technical documentation contain?

For every packaging type, document at least:

  • Unique identification (ID, description, optionally image/drawing)
  • Complete material and layer composition, including additives
  • Weight per component, recycled content
  • Relevant test reports (e.g. food contact, PFAS, heavy metals)
  • Recyclability assessment including recognized method used
  • Evidence of minimization, reusability, and empty space
  • Supplier declarations and certificates
  • Reference to the associated DoC including version

4. How long do I need to keep PPWR documentation and Declarations of Conformity?

The PPWR sets the following periods:Typically at least five years of retention for single-use packaging and up to ten years for reusable packaging, calculated from the time of placing on the market. Check national additions and industry-specific requirements.

5. Is specialized packaging management software worth it compared with Excel?

You can manage small portfolios with Excel, but if you work across several countries and many items, you gain substantial benefits from specialized solutions:

  • High transparency and data quality
  • Automated compliance checks and deadline monitoring
  • Structured supplier data flows
  • Audit-ready documentation at the touch of a button

Practice and studies show that companies handle PPWR and EPR obligations more efficiently and securely with digital packaging management. Tools like Packa provide central packaging data, automated workflows, and compliance functions - a reliable foundation for your PPWR management (for a more in-depth introduction, see the PPWR Guide 2026).