PPWR documentation requirements: what you must produce within 10 days

The PPWR documentation duty in one sentence

The PPWR documentation requirements mean that for every packaging unit you manufacture, import or place on the EU market, you must hold an EU Declaration of Conformity and its supporting technical documentation, keep it for 5 years for single-use packaging and 10 years for reusable packaging, and produce it to a national authority within 10 days of a request.

That is the whole obligation, and it is now live. Regulation (EU) 2025/40 applies from 12 August 2026, with no grace period for the duties that start on that date. Because the PPWR is a Regulation rather than a Directive, it is directly applicable in all Member States without national transposition. There is no local law to wait for.

The practical consequence is unglamorous. This is not a materials problem, it is a records problem. The question an inspector asks is not whether your packaging is compliant in principle, but whether you can show it in ten days.

What you must actually be able to produce

Compliance under the PPWR is evidenced by a small set of documents, and most organisations discover that these live in four places and are owned by nobody in particular.

The EU Declaration of Conformity. The primary artefact: the statement that a given packaging unit meets the applicable requirements of the Regulation, issued under your responsibility. It is what an authority asks for first, and the document with the explicit retention period attached.

The technical documentation behind it. A declaration that cannot be substantiated is a piece of paper. Behind it sit the material composition data, test results and assessments that justify it.

Manufacturer or importer identification. The responsible economic operator must be identifiable in connection with the packaging: your own identification data, and for importers, the trail back to the manufacturer outside the EU.

EPR registration records. Extended producer responsibility registration is a separate track from the Declaration of Conformity, and the one most often treated as a finance matter rather than a compliance record. Registration confirmations, producer numbers and reporting submissions evidence that you are registered where you are obliged to be. Filing the EPR registration records alongside the conformity file, rather than in the mailbox of whoever handled registration, is what makes the picture producible at once.

Supplier declarations. If your conformity position rests on what a converter or co-packer told you about recycled content or recyclability, their declarations are load-bearing evidence in your file. When the supplier relationship ends, that evidence does not stop mattering. Your retention clock keeps running.

Retention periods

• EU Declaration of Conformity, single-use packaging: 5 years.
• EU Declaration of Conformity, reusable packaging: 10 years.
• Production window: 10 days from the authority request.
• Technical documentation and supplier declarations: retain at least as long as the declaration they substantiate, since a declaration without its evidence is not defensible.

The split between 5 and 10 years matters more than it looks. Your retention rule cannot be one global setting. It is driven by an attribute of the packaging itself, single-use or reusable, so that attribute must be recorded on the document at the moment of filing. If nobody classifies the packaging when the declaration is created, in year six you will be guessing which files you were allowed to delete.

Why "it is somewhere in email" fails a 10-day window

Ten days sounds generous until you count what happens inside it. Someone works out which packaging units are in scope. Someone finds the current version of each declaration, not a superseded draft. Someone locates the technical file behind it, which may have arrived three years ago as an attachment from an employee who has since left. Then it all has to be assembled coherently.

Email fails this structurally, not because people are careless. Mailboxes are personal, so the file leaves with the person. Attachments have no version identity, so you cannot prove which declaration was in force when a given batch was placed on the market. There is no retention logic, so the message is either purged early by a quota or kept forever with no defensible rule. And there is no completeness check, so you learn what is missing when an authority is already waiting. A shared drive solves persistence and fails on the rest.

What a workable retention setup looks like

The requirements translate into a narrow set of design decisions. Each packaging unit needs an identifiable file, not a folder of loose attachments. Each file needs a single-use or reusable classification, because that drives whether the clock stops at 5 or 10 years. Each declaration needs a version history, so that "what was in force in March 2027" has an answer. Each document needs an owner who is a role rather than a person, so a resignation does not orphan the evidence. And supplier declarations belong with the declaration they support, not in the procurement thread.

The test worth running before an authority runs it for you is simple. Pick one packaging unit at random, ideally from a line that changed suppliers, and assemble its complete file: declaration, technical documentation, identification data, EPR registration proof and supplier declarations. Time it. If one unit takes days of chasing rather than minutes of retrieval, ten days is not a margin. It is a deadline you miss the first time a request covers twenty units.

Enforcement sits with national authorities, and their procedures differ. The expectation created by the Regulation does not: the evidence exists, it is retained for the required period, and it can be handed over on request. Whether that is routine retrieval or a fortnight of panic is decided by how documents are filed, long before anyone asks to see them.