1. Packaging identity and construction
Document one exact packaging construction at a time. Products can share a record only when the packaging components, materials and relevant specification are genuinely the same.
- Packaging name, type, version and internal identifier
- Products or SKUs using the exact construction
- Intended use, contact conditions and relevant claims
- Every component, material and weight
- Supplier and controlled specification for each component
- Design drawings or photographs used for identification
2. Requirements and evidence
Match evidence to the requirements that apply to the packaging. A generic supplier statement is not automatically sufficient for every material, version or intended use.
- Restricted substances and heavy-metals support
- Food-contact and PFAS support where relevant
- Recyclability information and later methodology review
- Recycled-content evidence for relevant plastic packaging
- Compostability or reusability support where claimed
- Minimisation assessment and empty-space calculation where applicable
- Artwork and labelling controls when the harmonised rules apply
3. Business and supply-chain facts
Collect facts instead of asking colleagues to choose legal labels. The same facts determine which company prepares, verifies or retains the documents.
- Whose name or trade mark is on the packaged product
- Who controls or specifies the packaging
- Where the packaged product is bought from
- Whether it is relabelled, repacked or otherwise modified
- Who first supplies it in each market
- Manufacturer, importer and supplier contact details
4. Review, Declaration and country actions
For the manufacturer route, connect the final assessment to the Annex VIII Declaration and named signatory. For importers and distributors, retain the real upstream Declaration and technical-document availability checks.
Keep national packaging registration and EPR actions in a separate country guide. Record a country as Registered only after the official result has been issued.
The checklist is a collection aid, not proof that every requirement applies or has been met. Use the factual route assessment and current official sources for the final decision.