Technical Documentation
Overview
Technical documentation is the fifth step of a packaging item's journey. It is the evidence file that stands behind the item's conformity: the information Annex VII requires, assembled from the item's classification, master data, marking evidence, and the supplier documents you filed earlier. The Declaration of Conformity in the final step rests on this file.
What feeds the file
The technical documentation comes together from what you already maintained in the earlier steps, mirrored rather than re-entered:
| Input | Maintained in | Annex VII role |
|---|---|---|
| Classification verdict, type, and attributes | Classification | The description of the packaging and its intended use. |
| Marking record and artwork | Master Data & Marking | Evidence of the marking as displayed on the pack. |
| Materials specification of components | Supplier Information | Annex VII 2(b). |
| Manufacturing process description | Supplier Information | Annex VII 2(c). |
| Substance evidence | Supplier Information, evaluated in Substances | The conformity basis for the Article 5 requirements. |
How to work this step
- Review what is present. The step shows the state of the file: which inputs are in place and which are still missing.
- Close the gaps at the source. Missing pieces are maintained in their home steps (Classification, Master Data & Marking, Supplier Information); fix them there and the file updates.
- Aim for a file you could hand over. The test for technical documentation is whether it would satisfy an authority asking you to demonstrate the item's conformity.
Retention
Keep the documentation available after placing the item on the market for the periods of Art. 15(3): 5 years for single-use, 10 years for reusable packaging, following the item's classification.
Tips
- Work the steps in order and this step largely fills itself; it is where the evidence chain becomes visible as one file.
- When a pack or its material changes, revisit the source steps; documentation must describe the packaging as actually placed on the market.
ℹ️ Regulatory context. The content of the technical documentation is set by Annex VII of the regulation, with the materials specification in 2(b) and the manufacturing process description in 2(c). The Declaration of Conformity (Articles 38, 39) is drawn up on the basis of this documentation. See Regulation (EU) 2025/40.