Professional technical documentation should reflect the actual packaging: its design, materials, suppliers, tests, calculations and assessments must all relate to the same product version.
The basis: Annex VII of the PPWR
Technical documentation must enable assessment of packaging conformity with the applicable requirements. It should not be a collection of unrelated files: its structure must lead from packaging identification to specific evidence.
1. Identify the packaging clearly
Start with the product code or SKU, design version, format, material, target market and intended use. If the documentation covers a family of variants, the grouping rules must be justified.
2. Define the material structure
Prepare drawings and a bill of materials covering the body, closures, labels, sleeves, adhesives, printing inks, barrier layers, seals and other relevant components. Record the material, weight and supplier for each element.
3. Link specifications to suppliers
A general description such as “PET bottle” or “PE film” is usually insufficient. Specifications should match the materials actually used in production and be linked to the correct product version.
4. Identify how conformity is demonstrated
Where a harmonised standard, common technical specification or another method is used, define its scope clearly. If no relevant standard is available, the documentation should describe the solution used to demonstrate conformity.
5. Document the required assessments and tests
Depending on the packaging, relevant evidence may include recyclability assessment, packaging minimisation, reuse, recycled content and the appropriate test reports.
Every report should link to the correct sample and product version. Avoid relying on a test result for an outdated packaging configuration.
6. Introduce version and change management
Changes to the material, supplier, thickness, barrier, label, adhesive or recycled content may affect conformity. The system should identify who approves a change and when reassessment is required.
7. Link the documentation to the EU declaration of conformity
The declaration of conformity should concern the same packaging configuration as the evidence. The manufacturer retains the technical documentation and declaration for 5 years for single-use packaging and 10 years for reusable packaging.
An example folder structure
- 01 – identification and scope;
- 02 – drawings and bill of materials;
- 03 – material specifications;
- 04 – suppliers and certificates;
- 05 – recyclability;
- 06 – recycled content;
- 07 – minimisation and reuse, where applicable;
- 08 – test reports;
- 09 – conformity assessment;
- 10 – EU declaration of conformity;
- 11 – change history.
Key point
A complete folder does not itself establish conformity. The value of the documentation depends on whether all evidence concerns the correct packaging, the correct version and the actual production process.