Fulfilling this obligation correctly will require producers to contact their manufacturers to obtain accurate technical information. Many producers rely on third-party companies for this, often based in different countries.

“Accurate technical information” is not a vague ask: under Annex VII of the PPWR, the technical documentation behind the Declaration of Conformity must contain, wherever applicable, at least:

• A general description of the packaging and its intended use.
• The conceptual design, manufacturing drawings and materials of its components.
• The descriptions and explanations needed to understand those drawings, and how the packaging is put together and works.
• A list of the harmonised standards, common specifications or other relevant technical specifications used, or, where none of these were applied, a description of the solutions adopted instead.
• A qualitative description of how the assessments required under Articles 6, 10 and 11 were carried out.
• Test reports.

This is exactly the kind of detail that only the manufacturer can provide, which is why getting it organised early, before every other company selling into the EU joins the same queue, makes such a difference.

Right now, with every company selling into the EU needing to complete its Declaration of Conformity at the same time, manufacturers are gathering packaging technical information for many clients at once. As a result, some producers are already experiencing delays in getting the information they requested.

It is also worth planning for how long that technical documentation needs to be kept, not just how accurate it is. Current guidance points to a retention period of five years from the date the packaging is placed on the market for single-use packaging, and ten years for reusable packaging, so producers should build that into their record-keeping from the start, rather than treating the DoC as a one-off filing exercise.