PPWR Series: Technical Dossier
Accountability under PPWR: Declaration of Conformity and Technical Dossier for Packaging
Compliance under the Packaging and Packaging Waste Regulation (PPWR) is not just about recycled content, recyclability, hazardous substances and so on, but it’s also about being able to demonstrate your compliance via a Declaration of Conformity (DoC) and supporting Technical Dossier. These will be key documents that prove to the authorities that packaging placed on the market in the EU meets the new obligations as they become applicable.
What Is the Declaration of Conformity?
A Declaration of Conformity (DoC) will need to be created for every item of packaging placed on the EU market. This document must clearly identify the packaging it refers to and confirm that it meets all the relevant requirements under the PPWR e.g. recyclability, heavy metals, recycled content.
The DoC must be kept together with the technical documentation and made available to national authorities if requested for up to:
5 years for single-use packaging
10 years for reusable packaging
What Is the Technical Dossier?
Supporting the Declaration of Conformity is the Technical Dossier. Just like the Product Information File for a cosmetic product, this is a structured collection of evidence that demonstrates that compliance has been achieved. As we’ve seen in our earlier articles, many of the details of ‘how’ to comply with requirements of the PPWR are yet to be decided and so the exact content of the technical dossier cannot be fully determined at this time (e.g. choice of assessments and methodologies). However, as deadlines approach and more detail becomes available over aspects such as determining recyclability, this dossier will need to be populated and updated to document and demonstrate design choices, materials used, recyclability assessment, and other relevant test results.
What Can We Expect
The PPWR represents a huge shift towards the aspirations of a circular economy and the Declaration of Conformity and Technical Dossier provide the foundation for accountability and enforcement. We can certainly expect that authorities will increasingly rely on these documents to monitor compliance in the future, meaning that companies must be prepared to not only adhere to the new requirements but be ready to also prove that their packaging meets the required standards.
At Bloom we’re helping clients across a number of industries and the packaging value chain understand what the PPWR means for their business and for their industry partners. In addition to our Packaging Minimisation Dossier Template, we are also working with companies to establish how their wider scope Technical Dossier will be structured, what it will include and how to construct their Declaration of Conformity.
Get in touch with us to find out how we can support your readiness.
Amanda Isom