A PPWR technical file assembled before 12 August 2026 holds the internal production control procedure (Annex VII, Article 38), the technical documentation demonstrating each applicable requirement, and the EU Declaration of Conformity (Annex VIII, Article 39), kept available for authorities, alongside recycled-content evidence and substance-compliance records for PFAS and the heavy-metals limit.
The four items in the conformity file
Before packaging is placed on the EU market under Regulation (EU) 2025/40, the manufacturer must demonstrate that it meets the applicable PPWR sustainability requirements. From 12 August 2026 three deliverables form the technical file, and a fourth duty keeps them retrievable.
| Document | Basis | Purpose |
|---|---|---|
| Internal production control procedure (conformity assessment) | Annex VII, Article 38 | Confirms the packaging meets the substance limits, recyclability, recycled-content and minimisation requirements that apply to it |
| Technical documentation | Annex VII, Article 38 | Records the packaging description, design and material data, test or calculation results, and the evidence for each requirement |
| EU Declaration of Conformity | Annex VIII, Article 39 | A single declaration drawn up to the Annex VIII model, stating the applicable requirements are met and identifying the packaging covered |
| Kept available | Articles 38, 39 | The documentation and Declaration are retained, produced for authorities on request, and updated when the packaging or the requirements change |
The substance records inside the file
Two substance records sit inside the file because their limits also apply from 12 August 2026 under Article 5. Food-contact packaging may not be placed on the EU market with per- and polyfluoroalkyl substances at or above 25 ppb for any single PFAS measured by targeted analysis, 250 ppb for the sum of PFAS measured by targeted analysis, or 50 ppm including polymeric PFAS as total fluorine. These are placing-on-the-market restrictions triggered at the stated limits, not a complete ban on every PFAS. Separately, the sum of the concentrations of lead, cadmium, mercury and hexavalent chromium present in packaging must not exceed 100 mg/kg, a combined limit for the four metals. Recycled-content evidence is prepared alongside these records so the file stands as one proof set.
Where the file sits for an Indian exporter
For an Indian business supplying an EU importer rather than placing packaging on the market itself, the file is prepared so the importer, the producer under Article 3(15), can rely on it. The manufacturer self-declares under internal production control, so no third-party verifier or certificate is issued under this route. The EU PPWR consulting service assembles the conformity assessment, the technical documentation and the Declaration of Conformity, while the EU PPWR guide and the PPWR discovery brief map each requirement to the evidence it needs.
Sources: Regulation (EU) 2025/40 (EUR-Lex) · European Commission, Packaging waste · European Commission, PPWR FAQ