Packaging technical file · Art. 38 and Annex VII · Regulation (EU) 2025/40

PPWR technical documentation: how to draw it up, what it contains, where the evidence comes from

The PPWR technical documentation (Art. 38 and Annex VII) is the evidence file behind the PPWR declaration of conformity: everything that proves the packaging meets the requirements of Regulation (EU) 2025/40. It is drawn up for every packaging type, before placing on the market, and kept for 5 years (10 for reusable packaging). Below: the eight elements, where each piece of evidence comes from and the mistakes we see most often.

Try it free →See the eight elements ↓

Keep in mind: the technical documentation is not sent anywhere and is not signed - it is kept available to the authorities and shown on request. The PPWR declaration of conformity is its signed summary. If the declaration claims something the documentation cannot prove, at an inspection the problem is the declaration.

The PPWR technical documentation in 30 seconds

1One file for every packaging type, not for every batch or product.

2Eight elements (Art. 38 and Annex VII): description, drawings and components, the requirements assessed, the standards, test reports, recyclability, minimisation, reuse.

3The evidence comes from the packaging suppliers (technical sheets, declarations, test reports) and from your own assessments.

4Kept for 5 years (10 for reusable) and updated at any change of material, weight or test.

5By hand: files scattered across e-mails and folders. In Yvora: generated from the packaging sheet, with the reports attached and read automatically.

Drawing up the PPWR technical documentation: the eight elements of Art. 38 and Annex VII and what Yvora does at each

The example used: 500 ml PET bottle for still water, with HDPE cap and PP label - the same packaging as on the PPWR declaration of conformity page.

1General description of the packaging and its intended use

What the packaging is, its level (sales / grouped / transport), the product it is intended for, single-use or reusable, the markets where it is sold.

Where the evidence comes from:

the packaging sheet and the purchasing specification.

What Yvora does

The description is written once in the sheet and appears identically in the PPWR technical documentation and in the declaration, RO + EN.

The common mistake: describing the product („Aqua still water 0.5 l”) instead of the packaging (500 ml PET bottle, HDPE cap, PP label).

2Drawings, diagrams and the list of components

The body and every component: material and sub-material, weight, colour, pieces, how they are joined (glued, welded, detachable). The supplier's drawings or technical photos.

Where the evidence comes from:

the packaging supplier's technical sheet; where missing, your own scale and photo.

What Yvora does

Components are chosen from the PPWR lists (16 materials, 170 sub-materials, 60 component types); when the supplier does not send the data, the photo analysis proposes the components and the consultants validate them.

The common mistake: the cap and the label are missing from the file, although they decide recyclability and, often, the PFAS.

3Assessment of the Art. 5 requirements - substances of concern

Heavy metals: the sum of Pb + Cd + Hg + Cr(VI) below 100 mg/kg. PFAS: for food-contact packaging, below 25 ppb / 250 ppb / 50 ppm. How it was checked and with what result.

Where the evidence comes from:

the supplier's test reports per material or component; your own tests at an ISO/IEC 17025 accredited laboratory when the supplier has none.

What Yvora does

You upload the report in any language; Yvora reads the values, compares them with the PPWR thresholds and flags „compliant”, „missing” or „exceeded” before validation.

The common mistake: „compliant” ticked without a report in the file - the claim without evidence is exactly what an inspection looks for.

4Harmonised standards and specifications applied

The list of standards or common specifications used (EN 13430 recyclability, EN 13432 compostability, EN 13428 minimisation, EN 13429 reuse) and, where no standard was applied, the description of the technical solution adopted.

Where the evidence comes from:

your own assessments and the supplier's reports; standards are cited with number and year.

What Yvora does

The standards ticked at assessment appear automatically in the PPWR technical documentation and at point 6 of the declaration - the same list in both.

The common mistake: one standard cited in the declaration and another in the documentation - the first inconsistency an inspector sees.

5Results of calculations and examinations

The calculations behind the assessments: total weight per component, the share of each material, recycled content, empty space, weight / volume ratio.

Where the evidence comes from:

the packaging sheet; the supplier's recycled-content certificates.

What Yvora does

The calculations are done automatically from weights and pieces; the total weight is recalculated at any change of a component.

The common mistake: weights rounded from memory or copied from a similar packaging.

6Test reports

Laboratory reports (heavy metals, PFAS, migration where relevant), recyclability or compostability test reports, with date, laboratory and method.

Where the evidence comes from:

the packaging or material supplier; your own accredited laboratory.

What Yvora does

All reports sit attached to the technical documentation of that code, translated into Romanian if they come in another language, with the upload history.

The common mistake: reports for a different material than the one in your packaging or older than the change of supplier.

7Assessment of recyclability (Art. 6) and recycled content (Art. 7)

The result of the recyclability assessment per component and per packaging (grade A / B / C, from 2030), what lowers and what raises the score, and, for plastic, the recycled content and how it was calculated.

Where the evidence comes from:

your own assessment under the validated protocols; recycled-content certificates.

What Yvora does

Yvora calculates the recyclability grade per component and per packaging and opens the „Full assessment”, an internal document with the correction proposals until 2030. In the PPWR technical documentation the description stays qualitative, as the Regulation requires.

The common mistake: the recyclability score written in the declaration - PPWR does not ask for the score there, but for proof of the assessment in the file.

8Minimisation (Art. 10) and, where relevant, reuse (Art. 11)

The justification that weight and volume are reduced to the minimum necessary (the Annex IV criteria), the empty space, and, for reusable packaging, the number of rotations and the reuse system.

Where the evidence comes from:

the design specification, your own calculations, the contract with the reuse system.

What Yvora does

The sheet asks for empty space and the reuse regime; Yvora puts them in the PPWR technical documentation and, for reusable packaging, applies the 10-year retention automatically.

The common mistake: minimisation „to be done by 2030” - the documentation requirement already exists, even if the 50 % empty-space threshold applies from 2030.

Step by step

How to draw up the PPWR technical documentation in a week

Inventory the packaging types

The same physical packaging = one type, regardless of flavour or shade. A hundred products may mean fifteen packaging types.

What Yvora does

Excel import: the template is checked before import, row by row.

Ask suppliers for the documents (Art. 16)

The technical sheet for each component, their declaration of conformity, heavy-metal and PFAS reports, recycled-content certificates. EU suppliers are obliged to give them to you.

What Yvora does

The „to be confirmed by suppliers” list becomes your Art. 16 request, with the e-mail template from the consultant.

Fill in the sheet and assess

Components, weights, materials; then the Art. 5, 6, 7, 10 assessment for each type. Where a report is missing, note what you order from the laboratory.

What Yvora does

The detailed per-packaging analysis builds the sheet in a minute when the supplier stays silent; the consultants validate it.

Generate, archive, keep up to date

The PPWR technical documentation for each type, then the PPWR declaration of conformity. Archive for 5 / 10 years, with version history. At any change of material or test, redo both.

What Yvora does

„Download all”: the sheet, documentation, declaration and assessment for every code, in a single ZIP, RO + EN.

PPWR · authority inspections

Authorities will ask for the complete PPWR file of every packaging.

With Yvora you download it as a single file, archived for 5 or 10 years, with 100 % traceability.

100 %traceability
every version, every transmission

You download it as a single file, archived for 5 or 10 years: the sheet, PPWR technical documentation, PPWR declaration of conformity, versions and transmissions - who, when, what changed, who received it.

Try it free →archive with version and transmission history

Frequently asked questions about the PPWR technical documentation

Is the PPWR technical documentation sent anywhere?

No. It is kept and presented at the request of the authorities (Art. 39) or of partners who ask for it. What circulates is the PPWR declaration of conformity. In Yvora you can send the documentation to partners, if you wish, or give them portal access.

Is there an official PPWR technical documentation template?

There is no Commission form. Art. 38 and Annex VII gives the list of elements; the form is yours. What matters is that every element exists and is proven. The structure on this page follows Art. 38 and Annex VII exactly and is the one Yvora generates.

My supplier will not give me the packaging technical sheet. What do I do?

You send the request in writing, citing Art. 16 (suppliers must provide the information needed for conformity) and with a deadline. Meanwhile, you build the sheet from what you can measure and photograph; in Yvora, the detailed per-packaging analysis does this in a minute and the consultants validate it. When the supplier data arrives, it only confirms.

Are PFAS and heavy-metal tests needed for every packaging?

Not for every code. The proof is made per material or component: the supplier's report for that material covers all packaging made from it. You run your own tests when the supplier has no reports, when you change the material or the ink, or for food packaging made of treated paper and board. Details in the PPWR Guide, section „PFAS and heavy-metal testing”.

How long is it kept and what happens at a change?

5 years from placing the last unit on the market, 10 years for reusable packaging. At a real change - material, weights, components, test results - the documentation is updated and the declaration gets a new version; the old version stays in the archive.

Draw up the PPWR technical documentation on your own packaging, in the Yvora PPWR software

Free demo account, 48 hours, 2 packagings: sheet, assessment, PPWR technical documentation and complete PPWR declaration of conformity - no card.

Try it free →The PPWR declaration of conformity, point by point →