PPWR technical documentation: What companies should prepare now

Why PPWR technical documentation is becoming important

The PPWR is an EU regulation on packaging and packaging waste. Unlike an EU directive, a regulation generally applies directly in the Member States. According to zmart information, the PPWR entered into force on 11 February 2025 and is expected to become mandatorily applicable from 12 August 2026. At the same time, new requirements for packaging design, recyclability, recycled content and evidence are emerging.

For companies, this primarily changes the evidence model. Until now, for many B2B providers in Germany, the Packaging Act with its requirements for registration, data reporting and participation in a system has been the main focus. The PPWR supplements this perspective: In the future, companies will need to demonstrate more clearly that their packaging itself meets specific requirements. Technical documentation serves as the internal evidence file.

Important: Technical documentation does not automatically replace existing obligations under the German Packaging Act. Anyone placing packaging subject to system participation on the German market must still assess whether registration, packaging licensing and data reporting are required.

What is technical documentation under the PPWR?

Technical documentation is a structured collection of documents relating to packaging. It is intended to demonstrate in a traceable way that the packaging meets the relevant PPWR requirements. Put simply, it answers questions such as:

• What materials is the packaging made of?

• Which substances or coatings are used?

• Is the packaging recyclable?

• Does the packaging contain recycled material?

• Has the packaging been designed to avoid unnecessary material use?

• Which tests, calculations or supplier evidence are available?

Technical documentation is closely linked to the PPWR declaration of conformity. The declaration of conformity is the formal declaration that packaging meets the relevant requirements. Technical documentation provides the basis for that declaration. Without reliable documentation, a declaration of conformity quickly becomes a claim without evidence.

We advise you on all matters relating to the VerpackDG/PPWR:

Who is affected?

The following types of companies may be affected in particular if they make packaging or packaged goods available in the EU for the first time:

• Packaging manufacturers

• Brand owners selling packaged products under their own name

• Importers bringing packaged goods from non-EU countries into the EU

• Retailers distributing packaging or products under their own brand

• Online retailers with own brands or direct imports

The exact scope of obligations depends on the role within the supply chain. A company that only resells third-party branded goods has different responsibilities than an importer or packaging manufacturer. Nevertheless, retailers should also request documentation from suppliers early. In practice, evidence is often passed along the supply chain.

An important term is “manufacturer”. In the PPWR framework, this generally means the economic operator that develops, arranges for the manufacture of or makes packaging available under its own name or brand. The company that actually fulfils this role should be assessed in each individual case.

Legal framework: PPWR, conformity and retention

The PPWR introduces new packaging requirements. These include rules on hazardous substances, recyclability, recycled content, packaging minimisation and labelling. zmart already points out that manufacturers must carry out a conformity assessment procedure before placing packaging on the market, prepare technical documentation and issue an EU declaration of conformity once conformity has been established. According to zmart information, documents must be retained for at least five years from the date packaging is placed on the market in the case of single-use packaging, and for ten years in the case of reusable packaging.

For B2B companies, one point is decisive: The obligation does not begin only when an authority makes an inquiry. Documents should be available before packaging is lawfully made available. Companies that only try to collect material data, test reports and supplier declarations retrospectively risk gaps in their documentation.

From 2030 onwards, additional requirements of particular practical relevance will become more important. These include packaging recyclability and minimum shares of recycled material in certain plastic packaging. zmart explains that, from 2030, all packaging in the EU must be recyclable or reusable and minimum quotas for recycled content will become binding. For companies, this means that technical documentation is not a one-off project, but an ongoing process.

What should be included in PPWR technical documentation?

The exact structure depends on the packaging type, material and the company’s role. As a practical starting point, however, a documentation structure with seven building blocks is recommended.

1. Packaging description

Describe the packaging clearly. This includes the product name, item number, packaging type, area of use and images or technical drawings. For composite packaging, all components should be listed separately, such as the carton, label, film, closure, insert or protective padding.

2. Material composition

Record the materials and weights for each packaging component. Typical information includes paper, cardboard, plastic type, glass, aluminium, steel, wood or composite material. Precise material designations are important. “Plastic” is generally not sufficient; specifications such as PET, PP, PE or a documented material composite are more appropriate.

3. Substance restrictions and safety evidence

The PPWR includes requirements for substances in packaging. You should therefore document supplier declarations, material data sheets or test evidence relating to relevant substance restrictions. This may include, in particular, evidence concerning heavy metals or other regulated substances.

4. Recyclability assessment

Recyclability will become a key criterion from 2030. Companies should therefore document early whether packaging can be recovered through existing collection, sorting and recycling infrastructure. Relevant information includes material combinations, colours, labels, adhesives, coatings and the ability to fully empty the packaging.

5. Recycled-content information

Minimum shares of post-consumer recycled content may become relevant for plastic packaging in the future. Post-consumer recycled content means recycled material derived from waste generated after use by end consumers or comparable places of waste generation. Companies should collect supplier evidence, certificates and calculations relating to recycled content.

6. Evidence of packaging minimisation

Packaging should not be larger or heavier than necessary. Therefore, document why the selected packaging is required for protection, hygiene, transport, shelf life or product safety. Comparative calculations, tests with alternative packaging or internal approvals from procurement, quality assurance and logistics can be helpful.

7. Version control and responsibilities

Every documentation file requires clear responsibilities. Define who maintains material data, who checks supplier evidence, who approves changes and how long documents are archived. Packaging often changes unnoticed, for example because of new suppliers, new labels or different film thicknesses. Without version control, it will be difficult later to determine which packaging was used at a particular time.

We advise you on all matters relating to the VerpackDG/PPWR:

Practical implementation: Step by step

Step 1: Record your packaging portfolio

Start with a list of all packaging. Separate it by packaging type, material, supplier, country and intended use. For many companies, this inventory is the greatest effort, but it is also the most important starting point.

Step 2: Clarify roles in the supply chain

For each package, clarify whether you are the manufacturer, importer, retailer, brand owner or merely a reseller. Your role determines which evidence you must prepare yourself and which evidence you need to obtain from suppliers.

Step 3: Prioritise risk groups

Not every type of packaging is equally critical. Prioritise packaging with high sales volumes, complex composite materials, plastic content, food contact, an import connection or own brands. These are typically the areas with a higher risk of missing evidence.

Step 4: Request supplier documentation

Request structured information, including material data, weights, recycled content, test evidence, certificates and recyclability information. Ideally, use a standardised form. This helps avoid each supplier providing different information in a different format.

Step 5: Create a documentation file for each packaging type

Create a digital file for each package or packaging family. At a minimum, it should contain master data, material data, evidence, assessments, approvals and version history. For smaller companies, a clear folder structure with a spreadsheet is often sufficient at the beginning. Larger companies should consider a product data management or compliance system.

Step 6: Prepare the declaration of conformity

Once all evidence is available, the conformity assessment can be carried out. Only then should the PPWR declaration of conformity be prepared. It is important that the declaration matches the technical documentation. Inconsistencies between the declaration, material data and supplier evidence are a common mistake.

Step 7: Update the process regularly

Review the documentation whenever packaging changes. This includes new suppliers, changed materials, new printing inks, different adhesives or changed fill quantities. New delegated acts, guidance or national enforcement rules may also make adjustments necessary.

Common mistakes in PPWR technical documentation

Mistake 1: Preparing only the declaration of conformity

The declaration of conformity is important, but it comes at the end of the process. Without technical documentation, there is no basis for it. Companies should collect and assess the evidence first.

Mistake 2: Grouping packaging too broadly

A packaging family can be useful. However, different materials, suppliers or coatings should not be included in one documentation file without critical assessment. Otherwise, the evidence may not match the packaging actually used.

Mistake 3: Accepting supplier statements without review

Supplier declarations are important, but they do not replace every internal review. Companies should at least assess whether information is complete, up to date and appropriate for the specific packaging.

Mistake 4: Failing to document changes

Many compliance issues do not arise during the initial approval, but later. A different label, new adhesive or modified film can affect recyclability. Each documentation file therefore requires a version history.

Mistake 5: Confusing the PPWR with packaging licensing

PPWR technical documentation demonstrates product-related packaging characteristics. Packaging licensing, by contrast, concerns participation of packaging subject to system participation in a dual system in Germany. Both obligations can affect the same company, but they are different.