Under Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), national authorities may ask you to make conformity information available. Manufacturers and importers must respond within 10 days of a reasoned request. This guide summarises confirmed PPWR text on retention, hand-over timing, Annex VII content and complete packaging units. Product Registry helps you organise files; it never submits to authorities.
Reasoned requests and the 10-day hand-over
Article 15(10) PPWR states that relevant documents shall be made available within 10 days of receipt of the request from the national authority for manufacturers. Article 18(8) uses the same sentence for importers. Article 17(2)(d) sets the same 10-day rule for authorised representatives acting for a manufacturer.
Distributors must provide information on request under Article 19(6) PPWR, but the Regulation does not set a 10-day deadline for distributors in the same way. Confirm your role and deadlines with your adviser.
In Product Registry you can log an authority request on a packaging record to track scope, request date and a countdown for your own workflow. The app does not transmit files to any authority.
How long to keep the technical file and EU DoC
Article 15(3) PPWR requires manufacturers to keep technical documentation and the EU declaration of conformity for 5 years from the date single-use packaging was placed on the market, or 10 years for reusable packaging.
Store signed declarations and underlying evidence where your team can retrieve them quickly. Product Registry drafts Annex VIII declarations and indexes Annex VII style documentation linked to each packaging unit.
Annex VII technical documentation (Module A)
- General description of the packaging and intended use.
- Conceptual design, drawings and materials of components.
- Explanations needed to understand those drawings and the operation of the packaging.
- List of harmonised standards or common specifications applied, or a description of solutions adopted where standards were not applied.
- Qualitative description of assessments under Articles 6, 10 and 11 PPWR.
- Test reports and an adequate analysis and assessment of risks of non-conformity.
Complete packaging units
Article 6(9) PPWR requires that where a unit of packaging includes integrated components, the assessment of compliance with design for recycling and recycled-at-scale rules includes all integrated components. Separate components are assessed separately.
Article 3(1)(45) defines a unit of packaging as a unit, including integrated or separate components, which as a whole serves a packaging function. Record every component on the PPWR sheet before you answer an authority request about recyclability.
How Product Registry helps
Use the packaging authority mode to log a reasoned request, attach scope notes and export a hand-over pack you submit yourself through the channel your authority expects.
Product Registry does not send email to authorities, does not simulate a submission and does not certify conformity. You remain responsible for the content and timing of your response.
Primary legal text
Product Registry organises evidence and inspection files. It is not legal advice and does not file anything with an authority for you.