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The Packaging and Packaging Waste Regulation (PPWR) introduces new documentation requirements for packaging (including product packaging). This guide serves as an introduction to several key documents required under the PPWR.
- Supplier documentation
- Declaration of Conformity (DoC)
- Technical documentation
Manufacturers
The company, defined as the manufacturer (of packaging or packed products), is generally responsible for creating the DoC and the technical documentation. There are also some circumstances in which the packaging supplier is responsible.
Suppliers
A supplier is the entity that supplies packaging or packaging materials to a manufacturer. Most product manufacturing companies do not produce packaging (or at least not the materials) in-house and procure from upstream suppliers instead. This entity is also responsible for providing certain documentation.
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Supplier documentation
Article 16 of the PPWR states that the (packaging) supplier must provide information and documentation needed by the manufacturer to demonstrate compliance.
This can include the following:
1. Files required for the technical documentation
Here are examples of information the manufacturer may need to obtain from the packaging supplier:
- Material specifications
- Dielines
2. Files pursuant to Articles 5 to 11 of the PPWR
- Heavy metals test reports
- PFAS test reports
- Recyclable content information
- Biobased feedstock information (if relevant)
- Compostability information
- Packaging minimisation information
- Resuabiltity information
Declaration of Conformity
Article 15 of the Packaging and Packaging Waste Regulation (PPWR) states that the manufacturer must issue a Declaration of Conformity:
- DoC requirements can be found in Article 39
- The DoC model can be found in Annex VIII
Who must create the PPWR DoC?
The DoC must be created by the manufacturer, which can be:
- The factory
- Companies ordering products from external factories
- The supplier of the packaging or packaging materials
Before you draw up a DoC, you must determine which company is defined as the manufacturer.
| Who is the manufacturer? | Example |
| A: The company that manufactures packaging or a packaged product | A Spanish jewellery factory produces jewellery packed in boxes in its own facility |
| B: The company that has packaging or a packaged product designed or manufactured under its own name or trademark | A Spanish jewellery brand orders custom-designed necklaces packed in boxes from a factory in China |
| C: The supplier of the packaging, if:
i. The company that has packaging or a packaged product designed or manufactured under its own name or trademark is a micro-enterprise. ii. The packaging supplier is located in the same member state as the company mentioned above (i). |
a. A small-scale jewellery brand in Spain orders jewellery boxes from a packaging factory in Spain.
b. The packaging factory (not the jewellery brand) is the manufacturer in this scenario. Note: Only relevant if the two companies are located in the same EU member state. |
Who is defined as a micro-enterprise?
The definition of a micro-enterprise can be found in Recommendation 2003/361/EC, which defines micro-enterprises based on the following criteria:
- Employs fewer than 10 persons
- Annual turnover and/or annual balance sheet total does not exceed EUR 2 million
What is the definition of a supplier?
A supplier is the entity that supplies packaging or packaging materials to a manufacturer. Most product manufacturing companies do not produce packaging (or at least not the materials) in-house and procure from upstream suppliers instead.
Model
| Item | Description / Examples |
| EU declaration of conformity No … | Identification number of the declaration |
| 1. No … (unique identification of the packaging): | This can include the packaging name, type, and materials |
| 2. Name and address of the manufacturer and, where applicable, the manufacturer’s authorised representative: | This is the name and address of the company defined as a manufacturer |
| 3. This declaration of conformity is issued under the sole responsibility of the manufacturer. | Compliance statement |
| 4. Object of the declaration (identification of the packaging allowing traceability): description of the packaging: | This can include a description, bill of materials, and images/artwork |
| 5. The object of the declaration referred to point 4 is in conformity with the relevant Union harmonisation legislation: … (reference to the other Union acts applied). | This must include the PPWR and other EU regulations and directives that apply to the product. |
| 6. References to the relevant harmonised standards or the common specifications used or references to the other technical specifications in relation to which conformity is declared: | Specify harmonised standards and other specifications that demonstrate compliance with applicable requirements
Examples EN 13428 – Packaging – Requirements specific to manufacturing and composition – Prevention by source reduction EN 13432 – Packaging – Requirements for packaging recoverable through composting and biodegradation – Test scheme and evaluation criteria for the final acceptance of packaging |
| 7. Where applicable, the notified body … (name, address, number) … performed … (description of intervention) … and issued the certificate(s): … (details, including the date of the certificate(s), and, where appropriate, information on the duration and conditions of validity). | Notified body details |
8. Additional information:
|
The DoC must be signed and dated |
Technical documentation
The company, defined as the manufacturer, must also create technical documentation based on the model in Annex VII.
| Item | Description / Examples |
| (a) a general description of the packaging and its intended use; | Packaging description, materials, and the type of products it is intended to contain |
| (b) conceptual design, manufacturing drawings and materials of components |
|
| (c) descriptions and explanations necessary for the understanding of the drawings provided under point (b) and the schemes and operation of the packaging | Provide comments to help the reader understand the files listed above |
(d) a list of (applied in full or in part):
|
Specify harmonised standards and other specifications that demonstrate packaging compliance with the PPWR
Note: Test reports or other documented assessments must generally support this list. |
| (e) a qualitative description of how the assessments provided for in Articles 6, 10 and 11 have been carried out | The assessment shall cover the following aspects for the packaging:
|
| (f) test reports | i. Include copies and references to test reports that demonstrate compliance with PPWR requirements.
ii. This can, for example, include test reports demonstrating compliance with heavy metals and PFAS restrictions under the PPWR. |
