10 days to show documentation to an authority: what you need ready

Where this deadline comes from

Article 15(10) of PPWR says that, on a reasoned request from the competent authority, the manufacturer provides all the information and documentation needed to demonstrate the conformity of the packaging, in a language the authority can understand, in electronic form, within 10 days of receiving the request.

These are calendar days, not working days. The clock runs through holidays too. The Regulation does not provide for an automatic extension on request.

The same obligation and the same deadline apply to the manufacturer's authorised representative (Article 17(2)) and to the importer (Article 18(8)). The difference is in scope: an importer shows what it holds, usually a copy of the declaration, not the manufacturer's full technical documentation.

What an authority can ask for

A request covers two separate documents that are worth telling apart. Technical documentation is the evidence. The declaration of conformity is the conclusion drawn from that evidence. An authority can ask for both at once.

• Technical documentation for the packaging in line with Annex VII, including the risk analysis.
• An EU declaration of conformity matching the Annex VIII template, for the specific type of packaging under inspection.
• Documents proving specific requirements are met, for example test results on heavy metals or PFAS.
• Information about the suppliers and recipients of a given packaging, which every economic operator has to be able to provide on an authority's request (Article 22).

What the technical documentation has to contain

Annex VII, point 2, lists six elements. An authority requesting the documentation checks all of them at once, not just the ones you happen to have ready.

• A general description of the packaging and its intended purpose.
• Design, technical drawings and the materials each component is made from.
• Descriptions needed to understand the drawings and how the packaging works.
• A list of the standards applied, or a description of the solutions adopted where none were used.
• An account of the assessments covering recyclability, minimisation and reuse, to the extent those requirements already apply.
• Test results, including for heavy metals and PFAS.

What the declaration of conformity has to contain

The EU declaration of conformity follows the template in Annex VIII. The manufacturer draws it up separately for each type of packaging, not one combined declaration for the whole catalogue.

• A number uniquely identifying the packaging.
• The manufacturer's name and address.
• A statement that the declaration is issued under the manufacturer's sole responsibility.
• A description of the packaging that allows it to be identified and linked to the technical documentation.
• The requirements the packaging complies with.
• A reference to any standards applied.
• Place, date, name, position and signature of the person issuing it.

Why 10 days is not enough to start from zero

Collecting heavy metal and PFAS test results from several suppliers, for each packaging component separately, usually takes longer than a week even when suppliers reply straight away. Adding a risk analysis on top, which no supplier sends ready-made, takes further time of its own.

So the 10-day deadline in Article 15(10) only makes sense as a check on what you already have, not as time to build the documentation from scratch. If it is not ready before the request arrives, in practice you will not meet the deadline.

How to have a full set ready in advance

The simplest approach is to keep your documentation organised the way an authority's request is structured, not as a folder of supplier letters in whatever order they arrived.

• A list of every type of packaging, each with its own complete set of documents.
• For each type of packaging: a list of its components and the supplier of each one.
• For each component: a material data sheet, heavy metal and PFAS test results, and the document expiry date.
• A written risk analysis, updated whenever a supplier, material or construction changes.
• A signed declaration of conformity for each type of packaging, in the language of the country of sale.
• One person responsible for keeping the set current and for everyone knowing where to find it if a request comes in.

Common gaps that only surface at inspection

These are the gaps that turn up most often in the documents companies show on a first request.

• There is a declaration, but no technical documentation to back it up.
• Documents cover only the main component, say the bottle, and not the closure, liner or label.
• There is no risk analysis, because nobody wrote one.
• The declaration is generic and cannot be matched to the specific type of packaging a request concerns.
• Documents only exist in one language, while the authority needs its own, or the other way round, because nobody checked which authority they would go to.
• Nobody in the company knows where the documents are, because the person who handled them has since left.