Blog
Insights, tutorials, and updates about Digital Product Passports.
PPWR Technical File (Annex VII): What Packaging Companies Must Prepare Before August 12, 2026
Quick answer: PPWR Annex VII technical file Every packaging manufacturer must compile a technical file (Annex VII of EU Regulation 2025/40) before signing the Declaration of Conformity. It contains the evidence that your packaging meets PPWR requirements on minimisation, recyclability, recycled content, and labelling. No notified body is required — this is Module A (internal production control). Retention: 5 years for single-use packaging, 10 years for reusable. Market surveillance authorities can demand access within 10 days. Deadline: 12 August 2026.
PPWR Penalties & Non-Compliance: What Happens After August 12, 2026
PPWR quick answer: From 12 August 2026, packaging placed on the EU market without a valid Declaration of Conformity (DoC) and supporting technical documentation can be prohibited, withdrawn from sale, or blocked at customs. Regulation (EU) 2025/40 requires Member States to set penalties that are effective, proportionate, and dissuasive — with no EU-wide cap on fines. The Packaging and Packaging Waste Regulation — Regulation (EU) 2025/40 — entered into force on 11 February 2025 and applies from 12 August 2026. That date is not a transition deadline: it is when market surveillance authorities across the EU acquire full enforcement powers over packaging compliance. For manufacturers, importers, and distributors placing packaging on the EU market, understanding exactly what non-compliance triggers — and how fast consequences materialise — is now a business continuity question.
PPWR Declaration of Conformity: Requirements for Packaging Manufacturers 2026
From 12 August 2026, every packaging item placed on the EU market under Regulation (EU) 2025/40 needs an EU Declaration of Conformity signed by the manufacturer. The document is short, often a single page, but it sits on top of a technical file that can run to dozens of pages per SKU. Get the structure wrong and the declaration is legally invalid, the packaging cannot be marketed, and the manufacturer carries the liability. This guide breaks down what goes into the DoC, what backs it up in the technical file, and how to scale the workflow across thousands of references.