The Declaration of Conformity (DoC) is your public-facing compliance statement. Annex VIII technical documentation is the evidence file that backs it up. If a national market surveillance authority inspects your packaging and requests your documentation, Annex VIII is what you hand over.
Getting this right matters: an inadequate Annex VIII file is grounds for a finding of non-compliance, even if your packaging itself is compliant.
PPWR Article 6(7) states that the producer must "draw up technical documentation" before placing packaging on the market. Annex VIII of the PPWR specifies the minimum content of this documentation.
The structure mirrors the EU's "New Legislative Framework" approach used for product safety regulations (machinery, medical devices, electronics) — the same DoC + technical file model. If you've handled CE marking, this structure is familiar.
Unlike the DoC (which is a short declaration), the technical file is a comprehensive evidence package. It doesn't have a prescribed length — it contains whatever documentation is needed to substantiate every claim in the DoC.
Based on PPWR Annex VIII, the technical documentation must contain:
A complete description of each packaging type covered by the documentation:
In practice: This is a structured packaging specification sheet. For a brand with 3 packaging formats (outer box, product box, poly mailer), you create a description entry for each.
Technical drawings or photographs showing:
For standard corrugated boxes and basic plastic packaging, photographs with dimension annotations typically suffice. Complex multi-layer packaging (flexible films, composite cartons) benefits from actual technical drawings showing the layer structure.
A complete material declaration for every component of the packaging, including:
For composite materials (e.g., a paperboard with a PE laminate): break down by layer, with the weight fraction of each layer.
The supplier documentation to collect:
This is the most technically substantive section. You must demonstrate that your packaging meets the PPWR recyclability requirements.
Before the delegated acts (pre-2028): Assessment against the PPWR's general recyclability principle (Art. 6(1): "packaging shall be recyclable") using current harmonised standards and assessment methodologies.
After the delegated acts (2028+): Assessment against the formal A–E grade criteria.
What the assessment should contain:
For plastic packaging:
For paper and cardboard:
For glass:
For metals:
For composite materials:
Minimum recommended content: A table listing each packaging component, the assessment methodology applied, the outcome, and the reference standard or certification.
Documentation demonstrating that the packaging has been minimised to the extent necessary for function:
Practical approach: Take a photograph of a typical packed order next to a ruler. Estimate void percentage visually, and add a brief statement of why current dimensions are necessary (fragile product → protective void; irregular product shape → dimensional constraint).
For standard e-commerce brands: this section can be brief. The PPWR's minimisation requirements are met by using appropriately sized boxes without excessive filler. If you've right-sized your packaging in response to DIM weight shipping charges (which most e-commerce brands have), you've likely already addressed the minimisation requirements.
Documentation that the packaging does not contain prohibited substances above specified thresholds:
Substances to document:
Collection approach:
Include copies of supplier declarations in the Annex VIII file, clearly labelled and dated.
From 1 January 2030, the technical documentation must include an assessment demonstrating compliance with minimum recycled content targets.
Pre-2030: This section can be preliminary — document current recycled content levels in your packaging as a baseline, and note the planned transition path to meet 2030 targets.
From 2030: Include:
A list of all harmonised standards, assessment methodologies, and certification schemes referenced in the documentation:
This section ties the documentation together — it tells an inspector which technical framework you applied and where to find the standards if they want to verify.
Organisation:
Structure the technical file with a cover sheet (linking it to the DoC) and one section per Annex VIII component listed above. For each packaging type covered, either maintain separate files or use a clear tabbed/sectioned structure.
Retention:
PPWR Article 6(7) requires technical documentation to be retained for 10 years after the packaging is last placed on the market. If you discontinue a packaging format in 2027, the documentation must be retained until 2037.
Format:
No specific format is mandated. PDF, organised file system, or dedicated compliance software all work. The critical requirement is that it can be produced on request to an authority within a reasonable timeframe. A well-organised digital file is standard practice.
Version control:
When packaging changes — new supplier, new dimensions, new coating — update the technical documentation immediately. Retain the previous version with its validity dates. The documentation must always match the packaging currently being placed on the market.
Relying on generic supplier declarations: A generic declaration that a supplier's products are "PPWR-compliant" without specifics on the materials and properties of your specific packaging item is insufficient. You need declarations specific to the grade and specification you're buying.
Missing recycled content chain of custody: Claiming 30% recycled content without a chain-of-custody certificate from the supplier is not verifiable. Authorities will treat it as unsubstantiated.
Outdated documentation: Maintaining a DoC and Annex VIII file for a packaging version you changed 18 months ago, without updating. Any packaging change that affects recyclability, material composition, or prohibited substance status requires documentation update.
Insufficient void space analysis: Simply stating "our packaging is minimised" without any calculation or justification. For products with variable sizing needs, include the reasoning.
No recyclability methodology reference: The recyclability assessment section says "our packaging is recyclable" without citing any assessment methodology or standard. An authority needs to understand how you reached that conclusion.
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For the DoC document itself, see The Declaration of Conformity: a step-by-step guide for brands. For how recyclability grades will affect future documentation requirements, see Recyclability grades A–E and EPR fee impact.