Documentation

The PPWR paperwork: Declaration of Conformity and technical file

Under PPWR, packaging is treated like a regulated product: you assess conformity, you compile a technical file, and you sign a declaration. Most of the substance of that file comes from your suppliers. This page is the checklist — what you must produce, and what to demand from whoever sells you recycled pellets.

Quick answer

PPWR requires economic operators to carry out a conformity assessment, draw up technical documentation following Annex VII and issue an EU Declaration of Conformity following Annex VIII. The declaration identifies the packaging, the responsible operator and the requirements it conforms to, and is signed on the operator's responsibility. The technical file behind it must substantiate every claim, including material composition and the basis of the recycled-content calculation — which is where supplier certificates and batch datasheets belong.

Conformity assessment obligation under PPWR (EU) 2025/40
Annex VII — technical documentation contents
Annex VIII — EU Declaration of Conformity template
Recycled-content claims must be substantiated in the file
PolyAl batches ship with documentation and technical datasheets

1. What the Declaration of Conformity contains

The declaration is short — typically one page — but it is a legal statement. It identifies the packaging unambiguously, names the manufacturer or importer, lists the requirements declared against, and is dated and signed by an authorised person. Its credibility comes entirely from the file behind it.

Identification of the packaging (type, reference, image if needed)
Name and address of the responsible economic operator
Statement that the declaration is issued under sole responsibility
The requirements of the Regulation conformity is declared against
Place, date and signature of the authorised person

2. What goes in the Annex VII technical file

The technical file is where the recycled-content number lives. It should let a reader reconstruct how you arrived at the declared percentage without asking you a question.

General description of the packaging and its intended use
Material composition, including polymer types and non-polymer fractions
The recycled-content calculation, its basis and its period
Supplier certificates evidencing post-consumer origin and share
Batch traceability records linking deliveries to production
Test reports and applicable harmonised standards

3. What to demand from your resin supplier

A supplier that cannot deliver these documents routinely — not on special request — will become the weak point in your file. Make them contractual.

Written statement of post-consumer origin, per batch
Recycled share and how it was determined (physical or allocated)
Third-party certification of the recycler and its scheme reference
Technical datasheet: density, MFI, softening point, composition split
Traceability reference linking the delivery note to the batch
Origin documentation (for PolyAl: EUR.1 preferential EU origin)

4. Enforcement reality

Penalties are set nationally under Article 68, and national frameworks are changing alongside PPWR — Germany's VerpackDG replaces the VerpackG from 12 August 2026. Auditors and customers usually surface a weak declaration long before an authority does, so treat the file as a commercial document, not just a legal one.

This page is general information about EU legislation, not legal advice. Check the consolidated text of each instrument and your national transposition before you rely on a figure.

Document checklist

EU Declaration of Conformity	Annex VIII — signed, per packaging type
Technical documentation	Annex VII — composition, calculation, evidence
Supplier certificate	Post-consumer origin and recycled share
Batch datasheet	Technical properties and composition split
Third-party certification	Recycler scheme certificate (EN 15343-based)
Traceability	Delivery note ↔ batch ↔ production order
Origin	EUR.1 for preferential EU origin

Documentation FAQ

Who signs the PPWR Declaration of Conformity?

The economic operator placing the packaging on the market — the manufacturer, or the importer for packaging brought into the EU — through an authorised person, on their sole responsibility.

Do I need a separate declaration for every SKU?

You need it per packaging type covered by the assessment. Grouping is possible where the packaging is genuinely equivalent, but the technical file has to support the grouping.

Does my supplier's certificate transfer compliance to them?

No. The declaration is yours. Supplier certificates are evidence inside your file; the responsibility for the calculation and the declaration stays with the operator placing the packaging on the market.

What documents do you supply with PolyAl?

Documentation of production following UNE 53925:2026, a batch technical datasheet with the polymer and non-polymer split, a statement of post-consumer origin and EUR.1 preferential-origin documentation.

Get the supplier documents up front

Ask us for the full documentation pack before you qualify the material — production standard, batch datasheet, origin and traceability, plus 20% off your first order to test.

Request the documents