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.The technical documentation is available independently of the Declaration of Conformity. You can generate it at any time from the unit’s current data — even before an EU Declaration of Conformity has been issued.
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:| Section | Content | Data source |
|---|---|---|
| Risk analysis | Assessment of the risk of non-conformity (Low / Elevated / Not assessed) with rationale | Derived from the weakest component (substance values + basis of claim) |
| 1. Packaging master data | Manufacturer, address, article number, GTIN, image/technical drawing, functional description, breakdown | Settings (manufacturer identity), packaging unit, components, evidence |
| 2. Assessment object | Main material type, packaging category, packaging format, weight, recyclability grade | Packaging unit + components |
| 3. Category-specific documentation | Constituents, material composition (mass shares), recyclability calculation | Components (material, weight) |
| 4. Further elements (c–f) | Drawings, standards/measurement methods, qualitative assessment under Art. 10/11, test reports (heavy metals, PFAS, recycled content) and the attached evidence | Component substance data + uploaded evidence |
Values that were not captured are explicitly marked “not recorded” in the document — Polygon One never invents values. This makes it immediately clear which entries are still missing.
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 substantiates compliance).
Gaps and readiness
Before you generate the documentation, Polygon One shows directly on the component which entries are missing or still need substantiating:
| Indicator | Meaning | Blocking? |
|---|---|---|
| Missing | Data fields are incomplete (e.g. mass, heavy metals, recycled content, PFAS) | No — advisory |
| Basis missing / Claim basis missing | A declared Art. 5 value has no basis of claim (test report or supplier declaration) | Yes — blocks submission |
| No evidence in documentation | An applicable substance has not been recorded at all | No — advisory |
| No test report | Compliant, but only evidenced by a supplier declaration (no test report) | No — advisory |
Only a missing basis of claim is a real block. All other badges are informational and prevent neither the technical documentation nor the Declaration of Conformity.
Generating the technical documentation
Generate the documentation
In the Declaration of Conformity section, click “Generate technical documentation”.If no components have been recorded yet, the button is disabled and shows the hint “Components missing — please record them first”.
The PDF is generated in German. For markets with another official language, a translation may be required to place the packaging on the market — Polygon One points this out in the panel but does not perform the translation itself.
Alternatively: upload your own documentation
If you already have a technical documentation (or a supplier has provided one), you can attach it via “Upload technical documentation”. It is then used as the unit’s Annex VII documentation and marked with a provenance chip (Generated, Self-uploaded or Supplier-provided).When generation is not possible
| Situation | Behaviour |
|---|---|
| No or incomplete component data | Generation is not possible until at least one complete component has been recorded. |
| An issued Declaration of Conformity exists whose data now differs from the unit | The technical documentation is considered out of date. Issue a new version of the Declaration of Conformity so both match again. |
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
EU Declaration of Conformity (Annex VIII)
How to issue the Declaration of Conformity, collect it from suppliers, and start the retention clock.