Technical Documentation (Annex VII)

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Overview

The technical documentation (Annex VII) is the evidence that a packaging unit meets the requirements of Regulation (EU) 2025/40 (PPWR) — in particular the Art. 5 substance restrictions. Polygon One generates it per packaging unit from the current master, component and evidence data. You do not assemble a document yourself: the platform builds the complete Annex VII structure automatically. You find the technical documentation under Master data → Packaging units on each unit’s detail page, in the Declaration of Conformity section.

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What the technical documentation contains

The generated documentation follows the Annex VII structure (Module A — internal production control) and adopts the ZSVR sample document as its template. It consists of the following sections:

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Substance compliance under Art. 5

Substance compliance is the core:

• Heavy metals — the sum of lead, cadmium, mercury and chromium VI, limit ≤ 100 mg/kg. The measured value, basis of claim and measurement method are shown per component.
• PFAS — only for food-contact components. Evidenced via an attestation or via a total-fluorine value; < 50 mg/kg demonstrates compliance with the three PFAS limits of Art. 5(5) PPWR — the screening route follows from the Commission guidance. Total-fluorine analysis is the starting point for enforcement (Commission FAQ III.20), and a harmonised testing methodology is still being developed (FAQ III.19). The limits apply equally to intentionally added and unintentionally present PFAS (FAQ III.16); a CAS list will not be published (FAQ III.18).

Every substance value carries a basis of claim: test report or supplier declaration. Both are valid bases under Art. 16 — a separate lab report as a file is not strictly required; a supplier declaration is sufficient.

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Gaps and readiness

Before you generate the documentation, Polygon One shows directly on the component which entries are missing or still need substantiating:

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Generating the technical documentation

The uploaded evidence (test reports, technical drawings, supplier declarations) is appended to the PDF under “Attachments / evidence”, so the documentation is self-contained.

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Alternatively: upload your own documentation

If you already have your own technical documentation, you can attach it via “Upload technical documentation”. It is then used as the unit’s Annex VII documentation and marked with the provenance chip Self-uploaded: “You uploaded a technical documentation for this unit. It is used as the unit’s Annex VII documentation.”

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A supplier-provided documentation does not replace yours

Where a supplier has provided technical documentation, it appears with the chip Supplier-provided — but it does not automatically become your unit’s Annex VII documentation. Polygon One says so explicitly:

“The supplier provided technical documentation for this unit. It serves as Art. 16 input for the unit’s own Annex VII documentation — as the manufacturer you must draw that up yourself; drawing it up cannot be delegated. Use “Generate technical documentation”.”

You can download the supplier’s document and use it as your basis of claim; you still generate the unit’s Annex VII documentation yourself.

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If you are the supplier

Where the packaging unit’s role is supplier, the card is headed Technical Documentation (Annex VII) rather than “Declaration of Conformity” and carries the note: “As a supplier you create the technical documentation (Annex VII) for your customers. You do not issue a Declaration of Conformity of your own.” The technical documentation is then your whole contribution here — no Declaration of Conformity is demanded from you.

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When generation is not possible

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Retention

Under the PPWR, the technical documentation and the Declaration of Conformity must be retained:

• Single-use packaging: 5 years from issuance
• Reusable packaging: 10 years from issuance

The retention period starts with the issuance of the Declaration of Conformity. Which of the two periods applies is not chosen in the dialog but derived from the packaging unit’s Reusable packaging toggle — Single-use (5-year retention) or Reusable (10-year retention). The technical documentation itself is regenerated from the current data at any time.