Under the EU Packaging and Packaging Waste Regulation (PPWR), manufacturers must keep the technical documentation and EU declaration of conformity for five years for single-use packaging and ten years for reusable packaging. The clock starts on the date the packaging was placed on the EU market, according to Article 15(3) of Regulation (EU) 2025/40.
For a brand commissioning custom boxes, those periods need to stay connected to the packaging actually supplied. A repeat order can extend how long a shared file is needed. A changed material can require updated evidence while the earlier file remains relevant. Supply-chain identification and extended producer responsibility (EPR) records have their own rules, so one deletion date for everything labelled “PPWR” is unlikely to work.
The PPWR generally applies from 12 August 2026. Individual requirements have their own application dates; the technical documentation must address the requirements applicable to the packaging concerned.
Who must keep the conformity records?
| Responsible role | Document duty | Single-use | Reusable |
|---|---|---|---|
| Manufacturer — Article 15(3) | Keep the technical documentation and EU declaration of conformity. | 5 years | 10 years |
| Importer — Article 18(7) | Keep a copy of the EU declaration available to market-surveillance authorities and ensure the technical documentation can be made available to them on request. | 5 years | 10 years |
| Authorised representative — Article 17(2)(a) | Under the manufacturer’s written mandate, keep the declaration and technical documentation at the disposal of national market-surveillance authorities. | 5 years | 10 years |
Your brand can be the legal manufacturer even when a separate factory makes every box. Article 3(1)(13) generally assigns that role to the person having packaging or a packaged product designed or manufactured under its own name or trademark. Under Article 21, importers and distributors also take on manufacturer obligations when they place packaging on the market under their own name or trademark, or modify it in a way that could affect compliance.
An importer is an EU-established person placing packaging from a third country on the EU market. Identify the actual legal entities and their roles in your supply arrangement; manufacturing in China alone does not determine the brand’s role. For the Article 15 duties, Article 15(12) provides a specific exception for qualifying micro-enterprises whose packaging supplier is located in the EU. A direct purchase from a China-based supplier does not meet that supplier-location condition.
The Article 17 representative’s document-holding mandate is separate from an EPR representative’s work on national producer obligations. The manufacturer’s obligation to draw up the technical documentation remains outside the Article 17 mandate.
How reusable packaging changes the period
A rigid gift box may spend years on a customer’s dresser holding jewellery. That second life does not, by itself, make it reusable packaging under PPWR. The legal distinction concerns packaging conceived for repeated use for its intended packaging purpose. Article 11 sets conditions covering design for multiple rotations, safe emptying and refilling, reconditioning and other requirements. Article 27 also requires operators using reusable packaging to participate in compliant reuse systems.
A gift box designed only for the initial supply of your product therefore does not acquire a ten-year conformity-record period simply because consumers keep it. A packaging design intended for a return-and-refill arrangement needs evidence supporting its reusable status, including the relevant reuse-system compliance information in its technical documentation. Board thickness, durability and a “keep me” message cannot establish that status on their own.
Older reusable stock has specific transition treatment. The Commission’s guidance explains that Article 11’s criteria concern packaging placed on the market from 11 February 2025, with compliance checks applying from 12 August 2026. Packaging placed before 11 February 2025 need not be brought retroactively into conformity with those criteria. Preserve evidence of the original placement date when relying on that transition.
When the clock starts—and what a reorder changes
Article 3(1)(10) defines placing on the market as the first making available of packaging, empty or filled, on the Union market. The archive needs evidence of that event. Sample approval, payment or dispatch from a Chinese factory alone does not establish the EU market-placement date. Match the packaging to the relevant supply and import records for the actual route.
Later production introduces more packaging with later placement dates. Where one documentation set covers repeated production of a version, a practical archive policy is to keep that set until five or ten years after the latest placement it covers. This manages the overlapping statutory periods; it is an archive-management recommendation, rather than a prescribed PPWR filing method.
| Packaging event | Effect on the archive |
|---|---|
| Version A first batch placed on 15 September 2026 | That batch’s five-year period reaches 15 September 2031. |
| Unchanged Version A reorder placed on 20 March 2028, covered by the same evidence | The shared Version A file must also support this batch. Keep it through at least 20 March 2033 if this is the final placement it covers. |
| Version B, with different wrapping paper and adhesive, placed on 10 September 2028 | Assess the changes and update the relevant documentation. Keep Version B’s file through at least 10 September 2033 if this is its final placement. |
The colour and dimensions of Version B might look identical to Version A, while its material evidence needs reconsideration. The original board specification may still apply; a report covering the earlier paper-and-adhesive combination needs a coverage review. Preserve the earlier documentation and identify which evidence supports each version. If more Version A packaging is placed later, its shared file needs a later retention date too.
For reusable packaging, distinguish initial market placement from later rotations. Article 15(3) expresses the ten-year conformity-record period from placement, rather than from the last reuse or disposal. Newly added packaging has its own placement dates; later supply transactions also need to remain traceable under the separate supply-chain rules.
Keep the evidence behind each packaging version
The EU declaration states that conformity has been demonstrated. The technical documentation provides the basis for that statement. Keeping only the signed declaration leaves out much of the manufacturer’s retention obligation. Annex VII requires documentation sufficient to assess conformity, including an analysis of the risks of non-conformity.
- Packaging identity and intended use: a description that connects the file to the packaging concerned.
- Design and materials: drawings, component materials and explanations needed to understand the construction.
- Assessment basis: applicable requirements, standards or technical specifications used, and the solutions adopted to demonstrate compliance.
- Supporting evidence: relevant test reports, supplier documentation and descriptions of the applicable recyclability, minimisation and reuse assessments.
- Reusable-packaging information, where relevant: system-compliance documentation and the required confirmations from system participants.
Article 39(2) requires the declaration to be continuously updated. Preserve the earlier declarations and supporting files needed for earlier packaging while keeping the current set accurate. A report’s date is not the retention trigger: a 2026 report used to support packaging placed in 2028 may still be needed throughout that packaging’s retention period. Equally, keeping a report for five years does not establish that it remains suitable for every material change during those years.
At CMIC, we can help bring together the approved box specification, component information and relevant supplier or test evidence for a project. When a material or finish changes, we can help review which information still applies and coordinate additional evidence or appropriate testing where needed. Agreeing the document set alongside sample approval gives your team a clearer handover: information tied to the packaging version, ready to connect with your finished-product and market-placement records.
Supply-chain and EPR records need separate schedules
Article 22(1) requires economic operators, on request, to identify both the operators that supplied them and the operators they supplied with packaging or packaged products. Article 22(2) expressly assigns five-year and ten-year periods to the supplier-identification information referenced in paragraph 1(a), for single-use and reusable packaging respectively. Its trigger is the date the operator supplied or was supplied with the packaging—a supply-date clock, distinct from the conformity file’s market-placement clock.
As an internal policy, keeping linked incoming and outgoing business-supply records for at least the corresponding five- or ten-year periods makes both directions easier to trace. Purchase orders, delivery records and invoices are useful when they connect the business identities, dates and packaging concerned. This coordinated policy should remain distinguishable from the narrower paragraph reference in Article 22(2).
EPR registration and reporting form another record set: registrations, mandates, submitted returns, packaging-weight calculations and related scheme records. Article 44 and Annex IX establish registration and reporting requirements but do not set a single EU-wide retention period for those records. Determine their schedule from the applicable national rules and any relevant contractual requirements of the EPR scheme. Where the same evidence also supports a conformity file, preserve it for as long as either applicable obligation requires.
Article 44(12)’s three-year rule concerns removal from the producer register; it is not a document-disposal deadline. For the wider relationship between these responsibilities, see our guide to PPWR labels, technical documentation and EPR.
Keep the archive usable after the project ends
Retention includes being able to produce the records. Under Articles 15(10) and 18(8), manufacturers and importers must make the relevant documents available within ten days of receiving a reasoned request from a national authority. They must provide them electronically and, on request, on paper, in one or more languages the authority can easily understand.
A backed-up company archive with an owner and a clear version index is a useful starting point. If an importer relies on the manufacturer to hold the technical documentation, agree how it will remain accessible throughout the required period, including after a supplier relationship ends. An expiring download link or an old employee’s inbox is a fragile basis for that access. Test retrieval using a superseded version, where missing connections are more likely to surface.
Discontinuing a product or changing packaging suppliers does not shorten a retention period already running. Make the document handover part of that change: preserve the relevant versions, the evidence they rely on and the records establishing their dates. Treat a calculated retention end date as a review point, checking for later placements and other applicable obligations before deleting anything.
For a new box or a material change, discuss your EU packaging project with us. We can start with the existing specification and evidence, then work through what can carry forward, what needs updating and what information should accompany the next order.
