PPWR introduces a structured model for assessing packaging conformity with the requirements of the Regulation. Technical documentation and the declaration of conformity are linked, but they are not the same document. The first contains material allowing the packaging to be assessed; the second is a formal statement by the manufacturer drawn up after the proper procedure has been carried out.

Start with unambiguous identification of the packaging

The document should not concern an unspecified box or bottle. Identification is needed of the packaging type, its intended use, level, components and variants. It is worth indicating the product or product group with which the packaging is used, and the conditions relevant to the assessment.

If the material, grammage, closure, label or component supplier changes, it must be determined whether the existing documentation still describes the actual configuration. The system should retain the previous snapshot instead of overwriting it with new values.

What technical documentation covers

Annex VII to the PPWR describes the elements of the documentation, including a general description of the packaging and its intended use, materials and design documentation, explanations needed to understand the design, the standards or specifications applied, a description of the assessments carried out and test reports, where applicable.

A list of files is not yet technical documentation. It is necessary to indicate which requirement is being assessed, which evidence supports it and to which configuration it relates. If a calculation has been used, the input data, method, units, author and version should be known.

Assessment of risk of non-conformity

The documentation should include an appropriate analysis and assessment of the risk of non-conformity. This is not a copy of the GPSR product safety analysis. It concerns the requirements applicable to the packaging and how their fulfilment is demonstrated. The scope may change with the design and with the date on which a particular requirement enters into force.

In the process, it is worth separating the requirement, data, evidence, assessment result and decision. A lack of data should not automatically become a positive result. It should create a task, indicate the person responsible and block approval where evidence is necessary.

Standards, specifications and methods

If a company applies a harmonised standard, a common specification or another technical method, it should record its exact designation, version and scope of application. Partial application must be described, as must the solution used where a given standard has not been applied.

A standard should not be entered only because it appears in a supplier document. It must be checked whether it relates to the correct requirement and configuration. An update to a standard or method should trigger a review of dependent assessments.

EU declaration of conformity

The declaration states that fulfilment of the relevant PPWR requirements has been demonstrated and should contain the elements arising from the Regulation. In drawing it up, the manufacturer assumes responsibility for the conformity of the packaging. It must therefore not be produced as an automatic printout from unverified fields.

A draft declaration may be generated on the basis of an approved snapshot. Before signing, however, the identity of the packaging, the completeness of the documentation, the applicable requirements, the manufacturer's details and the authorised person must be confirmed. The signed version should be frozen and retained together with the basis.

Retention and availability of documents

The PPWR provides for the declaration and documentation to be kept for a specified period after the packaging has been placed on the market. The periods differ for single-use and reusable packaging. The retention system should be based on the type of packaging and the actual date, not a single general file deletion date.

The documents should be capable of being presented to the competent authorities. However, access does not mean that every user in the company should be able to change them. Roles, download history and locking of an approved revision help preserve credibility.

Minimum workflow

Role of the platform

GPSR / PPWR can connect the packaging configuration, supplier data, requirements, evidence and revisions. It helps prepare controlled material and a draft document. It does not sign the declaration and does not replace the manufacturer's assessment. This division makes it possible to automate order without automating responsibility.

Whenever a component or method changes, it is worth opening a new revision and indicating which parts of the assessment remain valid. As a result, the next declaration is not produced from an accidental mix of old and new data.