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.
You find the technical documentation under Packaging → Packaging units on each unit’s detail page, in the Declaration of Conformity section.
Technical documentation and Declaration of Conformity panel on the packaging unit detail page
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)
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.
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.
The recyclability grade (A / B / C or Non-recyclable) is a declared value. The EU assessment methodology under Art. 6 is expected via a delegated act (around 2028) — Polygon One contains no grading engine and simply reflects the grade you provide. Likewise, recycled content (Art. 7, minimum quotas from 2030) is purely informational.
Before you generate the documentation, Polygon One shows directly on the component which entries are missing or still need substantiating:
Gap notes and badges on the components of a packaging unit
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.
Go to Packaging → Packaging units and open the unit you want.
2
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”.
3
Download the PDF
Use “Download PDF” to get the complete documentation as a PDF file (file name TD-….pdf).
Generated technical documentation as a PDF
The uploaded evidence (test reports, technical drawings, supplier declarations) is appended to the PDF under “Attachments / evidence”, so the documentation is self-contained.
The PDF is generated in German and English. 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.
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).
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 (where you choose between Single-use (5-year retention) and Reusable (10-year retention)). The technical documentation itself is regenerated from the current data at any time.
EU Declaration of Conformity (Annex VIII)
How to issue the Declaration of Conformity, collect it from suppliers, and start the retention clock.
