Yes, you may compile the technical file for your packaging yourself. The regulation does not prescribe who compiles it, only what it must contain and that it is substantiated and up to date. The question is therefore not whether you may, but whether it is practically feasible within your organization.
With a simple packaging made of a single material, such as a cardboard box without printing containing heavy metals or additives, a file can often be prepared in an afternoon. With multiple packaging variants, mixed materials or supplies to different EU countries, the work grows quickly, and that is where many entrepreneurs get stuck on time, not on knowledge.
What a technical file actually contains
A technical file is the substantiation behind the declaration of conformity prescribed by Annex VIII of the regulation. It typically contains a description of the packaging and the materials used, data on any heavy metals or PFAS, the harmonised standards or technical specifications applied, and references to test reports or material certificates from your supplier. Where relevant, it should also include the substantiation of the name and address on the packaging.
The core of the work is not in writing the file itself, but in collecting the right evidence. Many SMEs find that their packaging supplier has this data, but does not send it as standard. That is where the practical bottleneck begins.
What it requires from your own organization
Compiling a file yourself means you know which standards apply to your type of packaging, that you ask your supplier the right questions, and that you keep the file up to date if the packaging changes. This last point is often underestimated: a file is not a one-off document but something that evolves with changes in material, supplier or design.
For companies with one or two packaging types and a fixed supplier, this is easy to do yourself. For companies that regularly change suppliers, carry private label products, or have packaging assembled by a fulfilment partner, it becomes more difficult to keep the overview complete. In that situation, it helps to first clarify which role you have exactly per packaging type and per country, for example with the role finder that maps that out in a few questions.
Where doing it yourself ends and guidance begins
The boundary usually does not lie in knowledge, but in scale and repetition. One file for one product is manageable. Ten variants for five countries, each with slightly different requirements for language or registration number on the packaging, is a different story. Add to this the fact that a file you compile yourself must also be kept up to date yourself with every change in packaging or regulations.
Epria.eu does not make a legal judgment on your specific situation in this process and does not become a party that collects contributions on your behalf or acts as a waste management organization. What is possible is the system around it: a fixed place where the file, the declaration of conformity and the registration per country are located together, with an annual reporting calendar so nothing falls between the cracks. How that structure works exactly and which sources underpin it is explained on the page that explains where the information comes from.
In summary
Compiling a technical file yourself is not a problem as long as the packaging is simple and you keep track of changes. As soon as the number of variants, materials or countries increases, the question shifts from "am I allowed to do this" to "how do I keep this manageable". If you have doubts about the content of a standard reference or a test report, the regulation itself or an expert is the appropriate place to verify that; epria.eu cites the guidelines and refers to them.
If you first want to know which documents are relevant for your packaging and country, check out the knowledge base with topics selected for each situation or compare what a guided trajectory adds via the overview of what is included.
Do you have half an hour and want to know where you stand for your own packaging? Do the free quick scan or browse through the topics in the knowledge base to see what applies to your situation.