Everyone is looking for the same document: the official template for PPWR technical documentation. Many companies are waiting for it before they begin, convinced that the Commission will publish a form to fill in. That wait is a trap. Regulation (EU) 2025/40, applicable from 12 August 2026, requires technical documentation without fixing its format. No harmonised template is planned in time. Grasping this distinction means you stop waiting and start building your file now.
Two documents everyone confuses
The confusion arises because the PPWR creates two separate documentary obligations, only one of which has a prescribed template.
The declaration of conformity is a self-declaration signed by the manufacturer, attesting that a type of packaging meets the requirements of Articles 5 to 12. It has a precise legal basis, Article 39, and a prescriptive template set out in Annex VIII of the regulation. This template is binding: a missing field renders the declaration invalid, treated as if it did not exist.
The technical documentation is the body of evidence that supports this declaration. It falls under Annex VII, following module A, known as internal production control: the manufacturer assesses conformity itself, without a third-party body, and keeps the file available to the authorities. Annex VII lists what this file must contain, but says nothing about the form it must take. There is therefore neither template nor official form.
In other words: the declaration has a template, the file that justifies it does not.
What the technical documentation must contain
Annex VII sets the minimum content of the file. Beyond a general description, the essential task is to gather, for each type of packaging, the evidence of conformity with each applicable requirement.
The description and composition
The file opens with a general description of the packaging and its intended use, completed by drawings, diagrams and the actual material composition. For multi-material packaging, this composition is described layer by layer: it is the technical foundation from which everything else follows.
The standards or, failing that, your internal methods
The annex requires you to list the harmonised standards applied. Yet, in 2026, these standards do not yet exist. The file must then explicitly state the technical specifications or internal methods used to assess each requirement. This point catches people out, but it is central: the absence of a standard exempts you from nothing; it obliges you to document your own method.
The substances of concern
The file must demonstrate compliance with Article 5: restriction of intentionally added substances, heavy metals, and above all the ban on PFAS in food contact from August 2026. This is done through supplier declarations and, where these are not enough, test reports.
The qualitative sustainability assessments
The heart of the file gathers the assessments demonstrating compliance with the substantive requirements: recyclability under Article 6, recycled content under Article 7, minimisation under Article 10, reuse under Article 11, and where applicable bio-based content, compostability, harmonised labelling or environmental claims if you make any.
The register of evidence
Finally, the file must trace the origin of each piece of data, in particular your suppliers’ declarations. It is this register that makes it possible to respond to an inspection without rebuilding the information under pressure.
The whole is kept for five years for single-use packaging and ten years for reusable packaging, from the date it was last placed on the market.
Why the official template will not arrive in time
Waiting for a template is not absurd: it is simply disconnected from the real timetable. Several technical building blocks are still missing, and most will arrive after the deadline.
The harmonised recyclability standards are not published. The methodology for identifying material composition depends on an implementing act expected around August 2026. The detailed design-for-recycling criteria fall under delegated acts pushed back to 2028, for application in 2030. In spring 2026, close to thirty delegated and implementing acts remained to be published.
As for the guidance published by the Commission on 30 March 2026, it clarifies definitions, such as the distinction between manufacturer and producer, but remains interpretative: it is not a file template. Implementing acts may one day specify a format, but none is available today, and the obligation itself applies with no grace period on 12 August 2026.
Building your file without waiting
The right strategy is not to wait, but to build an in-house file now, structured around the headings of Annex VII. Three workstreams give a clear trajectory.
First, document the actual composition of your ranges, material by material, because it is the foundation of every assessment that follows. Next, formalise the internal methods you apply in the absence of harmonised standards, so that each assessment is reproducible and defensible. Finally, prepare a technical file and declaration of conformity template that you can adapt per reference, rather than starting from scratch for each product.
This logic connects directly to the obligations of the packaging supplier, the first link that must prove conformity, and to the mechanics of PPWR penalties, where the absence of evidence is often paid for in lost contracts well before any public inspection. To place this obligation in time, the deadlines calendar gives the overall view, and the complete PPWR guide sets technical documentation among the other obligations.
A question about your specific situation? Write to us at contact@packaginghub.fr.