The EU Declaration of Conformity and Technical Documentation: Annex VII Explained

The PPWR runs on the Union's standard conformity machinery. Before placing packaging on the market, the manufacturer draws up the technical documentation prescribed by Annex VII and issues an EU declaration of conformity stating that the packaging meets the applicable requirements - the sustainability and safety requirements of the regulation that apply to it. The declaration and documentation are retained for five years after placing for single-use packaging and ten years for reusable packaging, and are produced to market surveillance authorities on request. Importers verify that both exist before they place; distributors check the declaration accompanies the packaging through the chain.

There is no notified body and no approval: the manufacturer assesses, declares and answers for it. That self-assessment character is what makes the file's quality the whole game - this station is the file's operating manual, station by station of the evidence it must hold.

Three artefacts carry the system. The declaration is the public legal act: a structured statement, identifying the packaging and the manufacturer, listing the requirements and standards applied, signed by a person authorised to bind the business. The technical documentation is the proof: design and composition data, the assessments and test reports behind each applicable requirement, the calculations, the supplier evidence - the whole evidentiary trail the other stations of this guide series have been building, filed in one architecture. And the standards layer gives presumption of conformity: where harmonised standards or the regulation's own criteria and methodologies exist for a requirement, following them is the recognised route to meeting it, and the file records which route each requirement took.

Annex VII's contents come first as a working checklist, then the declaration itself - its fields, its signatory, its language and availability duties. Then the assessment discipline: self-assessment without a notified body and the internal production control that keeps production married to the assessed design. The evidence standards follow (what makes a test report count), then the retention architecture for the 5 and 10 year horizons, the importer's documentation pack, change management for declarations, supply-chain documentation flows, the common gaps auditors find, and the digital systems that hold it all at portfolio scale.

Assemble the station in miniature for a single juice carton. The declaration names the carton family and its sizes, the manufacturer, the requirements applied (substances, recyclability grade, minimisation, labelling) and the criteria and standards routes taken for each. The file behind it: the component map (board, polymer layers, cap, label); the substance inventory and the total-fluorine screen for the board's coating; the grade assessment with its points worksheet; the minimisation justification (headspace from the filling process, argued with the capability data); the recycled-content position stated as not applicable to the plastic layers' category with the reason recorded; supplier declarations for board and cap resin; the artwork proof with its label register entry. One family, one afternoon to index, five years of answerability. That ratio - an afternoon against five years - is the conformity system's true price, and it is lower than the incident it insures against by any measure the business keeps.

The system's duties are the same for a four-person converter as for a multinational; their discharge is proportionate. Family-level declarations and files where designs genuinely share, supplier evidence gathered through the declaration machinery rather than duplicated testing, the challenge function performed by reciprocal review - the system's shape holds at every scale, only its staffing changes. What does not scale down is the existence of the artefacts: the smallest manufacturer still holds the index, the evidence and the signed declaration, or holds none of the defence the system offers. Proportionality is a doctrine about effort, never about absence.