A packaging specification sheet should let your brand, packaging supplier and compliance reviewer identify the same box, down to its materials, artwork and approved revision. For custom paper packaging made in China for EU sale, that connection matters: changing an insert or coating can alter product fit, material composition and the relevance of the evidence behind an approval.
The sheet brings together what will be manufactured, how it will be checked and which records support it. It also gives everyone a way to resolve discrepancies before production. A physical sample can show the opening experience beautifully; the specification preserves the construction details needed to reproduce it.
Define the packaging, destination and responsible parties
The Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, has applied generally since 12 August 2026, with individual requirements introduced on different timetables. Record the intended EU market-placement date and destination Member States. These determine the requirements to review; a manufacturing date or the name of an arrival port gives only part of the picture.
Identify the physical packaging supplier separately from the legal manufacturer under PPWR. A brand commissioning packaging under its own name or trademark can be the legal manufacturer even when another company makes the box. Establish the roles for the actual supply arrangement, including the EU importer where relevant and the party responsible for extended producer responsibility (EPR) in each destination country. The manufacturer’s conformity duties, the importer’s checks and the supplier’s information obligations need named owners.
A copyable packaging specification sheet
This example concerns a rigid box for an adult pendant and chain, sourced from China for sale in France and Germany. It is non-food-contact sales packaging, with a separate mailer used for ecommerce delivery. The dimensions, materials and document codes below are illustrative draft entries. Sample trials and review would establish the values and records for an actual order.
| Field | Example or information to enter | Record or responsibility |
|---|---|---|
| Packaging identity and status | JB-01, revision B; status: draft. Add issue date, document owner and change summary. | One master specification maintained by the nominated project owner. |
| Product and intended use | Pendant and chain; identify product SKU and product sample. Record contact between jewellery and insert, packing arrangement, and intended sales use. Food contact: no. | Brand confirms product details and use; supplier develops the fit. |
| Markets, timing and supply route | France and Germany; intended market placement in Q4 2026. Manufacture in China; record where the boxes are filled and how packaged goods reach customers. | Brand and relevant EU compliance owner confirm the route. |
| Responsible entities | Enter packaging supplier, legal manufacturer, importer where applicable, and contact for destination-country EPR arrangements. | Confirm legal roles separately from commercial job titles. |
| Structure, drawings and dimensions | Lift-off lid and base with removable folded-card insert. Proposed external size: 90 × 90 × 30 mm, ±1 mm. Drawing DWG-JB-01-B defines dimension order, internal clearances, lid overlap and insert position. | Supplier proposes feasible tolerances; brand confirms fit and handling through samples. |
| Component materials | Proposed 1.2 mm greyboard, 120 g/m² wrapping paper and 350 g/m² card insert. Add supplier and grade codes, plus ink, varnish and adhesive identities, to the bill of materials. | Supplier supplies construction and material information; evidence is linked by component code. |
| Component and finished weights | Record grams per component and per finished empty box. Identify measured and calculated values, measurement basis and agreed production tolerances. | Supplier completes the weight record; reporting and technical-documentation owners use the relevant data. |
| Artwork and finishes | Artwork ART-JB-01-B; one spot-colour logo and clear varnish. Specify colour reference, printed faces, finish product code, coverage and decoration position. | Brand approves appearance and content; supplier confirms production details. |
| Identification and market information | Show approved locations for packaging identification, required operator details and applicable sorting or product information. Identify country and language variants. | Compliance reviewer approves content; artwork file fixes its position and presentation. |
| Performance and appearance | Define product retention, clearance, closure operation, acceptable cosmetic defects and protection after agreed handling or transport tests. State test configuration, sample quantity and pass criteria. | Linked acceptance protocol and approved reference sample. |
| Regulatory requirements and evidence | For each requirement, record legal reference, applicability, application date, acceptance rule, evidence reference, reviewer and status. Link technical documentation and the EU declaration of conformity. | Legal manufacturer owns the conformity assessment; suppliers provide supporting information. |
| Approval and order release | Record drawing, artwork and sample revisions; sign-off names, dates and scope. The purchase order identifies the released specification revision and attachments. | Separate appearance, technical and compliance decisions so approval has a clear meaning. |
| Changes and open entries | Record proposed substitutions, affected evidence, responsible person, due date and any release condition. Identify the first order or batch using an approved change. | Supplier notifies changes; designated approvers review their consequences. |
Distinguish legal requirements from your purchasing and quality requirements. The illustrative ±1 mm tolerance is a proposed manufacturing agreement, while an applicable substance limit comes from legislation. Both deserve clear acceptance criteria, but they have different origins and approval routes. A draft can contain open entries; each needs an owner and a decision point.
Using the same controlled specification also makes quotations easier to compare. Our guide to sourcing PPWR-ready custom paper packaging places this step within the wider buying process.
Describe the whole material combination
A bill of materials is the component list behind the box. It should identify the board, wrapping paper and insert, together with the inks, adhesives, coatings and any other decoration or accessories used. Two visually similar wraps can have different coating compositions. A finish description such as matte or water-based therefore needs a material reference: neither term establishes the finished pack’s recyclability.
Keep thickness, paper grammage and component weight in separate fields. A wrapping paper specified at 120 g/m² describes its mass per square metre; it does not tell your reporting team how many grams are used in one box. Record finished component weights, and identify calculated contributions for dry ink, adhesive or coating where separate weighing is impractical. Reconcile the component total with the finished empty box, avoiding double-counting coatings already included in a component’s weight.
Describe how components are attached and separated. A loose card insert, an insert glued to the base and a card insert laminated with fabric are different constructions. Article 6 of PPWR distinguishes integrated and separate components in recyclability assessment. Drawings and material records should make those differences visible, including components that might otherwise disappear under the description paper gift box.
At CMIC, we can translate a desired appearance into specific materials, finishes and construction options, then coordinate the corresponding supplier information. This helps make a comparison useful: an uncoated textured wrap and a printed, varnished wrap can be evaluated for touch, appearance, durability and evidence needs as complete alternatives.
Give each legal requirement a scope, date and evidence reference
A regulatory entry should explain what applies to this packaging and how conformity will be demonstrated. Use the PPWR text and applicable current guidance as the basis. The following examples show how legal requirements can become usable specification entries; the complete register depends on the product, materials and market route.
| Requirement | What to record in the specification or linked register |
|---|---|
| Heavy metals: Article 5 | For ordinary paper gift packaging, the combined concentration of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg in packaging or packaging components. Record the covered materials and components, supporting declarations or reports, sample identity and assessment conclusion. Include the contribution of printing and finishes in the evidence review. |
| Identification and operator details: Articles 15 and 18 | Record the required packaging identifier and manufacturer/importer information, its approved location, and any permitted alternative used. The artwork should preserve the legibility of information required for the packaged product as well. |
| Environmental claims: Article 14 | For claims about packaging properties regulated by PPWR, document how the claimed property exceeds the applicable minimum requirement and specify whether the claim concerns the whole packaging unit, a part or all packaging placed on the market by the operator. Link the supporting technical documentation to the exact wording. |
| Recyclability, minimisation and harmonised labelling | Record the assessment basis and application date for each relevant provision. Separate the requirements for the planned market-placement date from later detailed criteria and label obligations. Where a deadline depends on a further EU act, retain that trigger alongside the date and schedule a review before a future reorder. |
The intended-use field keeps testing relevant. Our jewellery-box example records no food contact. If the structure is adapted to hold unwrapped confectionery, food-contact legislation and PPWR’s food-contact PFAS restrictions become part of a new applicability review. The familiar box shape does not preserve the original assessment when its use changes.
For each destination, review applicable national sorting information, language needs and product-specific labelling alongside the packaging requirements. Keep EPR registration and reporting responsibilities in a linked country record. The specification supplies useful material and weight data for that work; the responsible producer still needs to manage the applicable country arrangements.
Connect the sheet to the technical documentation
Under Article 15 and Annex VII, the manufacturer must prepare technical documentation and carry out conformity assessment before placing packaging on the market. The documentation includes applicable requirements, an analysis and assessment of non-conformity risks, the intended use, drawings, component materials, relevant specifications, assessment explanations and test reports where applicable. The specification sheet supplies much of the manufacturing description and can serve as an index into this material. Once conformity has been demonstrated, the manufacturer draws up the EU declaration of conformity.
For each report or declaration, record its issuer, date, document reference, material or sample identity, relevant method and result, and the packaging revisions it supports. Review whether it concerns a raw material, an individual component or an assembled pack. A report on unprinted board may contribute useful evidence, while the coloured wrap, varnish and insert still need an appropriate basis for assessment. Where coverage is incomplete, identify the particular information or testing needed to close the gap.
PPWR’s Annex VII procedure is Module A, internal production control. Laboratory work can support it, while the manufacturer remains responsible for the conformity conclusion and production controls. Choose evidence to answer defined questions about the specified packaging, rather than treating a collection of certificates as a general approval for every material combination.
The declaration must identify the packaging it covers. Linking that identity to the specification and revision history makes it possible to trace actual orders back to the assessed construction. Manufacturers must retain the technical documentation and declaration for five years after single-use packaging is placed on the market, or ten years for reusable packaging. Preserve the relevant approved versions alongside those records.
Make sample approval reproducible
The drawing defines dimensions and construction; a physical reference sample helps define colour, touch and workmanship. Identify the revision of each and resolve disagreements before release. For the example box, an acceptable external size alone cannot establish fit: insert position, clearance above the pendant and space for the chain determine whether the assembled pack works.
- Fit and handling: test the actual product in the assembled box. Define acceptable retention, lid clearance and removal, including whether the chain catches or the jewellery moves against an abrasive surface.
- Appearance: identify the colour master and viewing conditions, decoration position and acceptable limits for wrinkles, exposed board, glue marks and surface damage. Agree how the sample will be used to judge production.
- Protection: define a handling or transport test appropriate to the sales route. Record the product, insert, mailer and shipping carton versions used, the sample quantity and pass criteria, such as no product damage and continued closure operation.
These records can also explain why a particular material thickness or clearance is needed. If a thinner-board trial distorts under the agreed load, its result provides a concrete reason for the selected construction. Annex IV’s minimisation assessment considers protection, manufacturing, logistics and other packaging functions, including the reasons preventing further reduction. Record what each necessary layer does and investigate reductions without losing that function.
We can help turn a preference such as a secure fit or an easy-opening lid into a small number of sample comparisons. Agreeing what will be compared—and what would count as an acceptable result—makes the next decision clearer without requiring your team to develop every manufacturing detail.
Carry approved changes through to production
Suppose a heavier pendant prompts a change from the folded-card insert to a foam insert. The new sample may hold the product more securely, but that approval has several consequences: the material list and weights change, the cavity and internal clearances may change, and the substance and recyclability evidence needs review. Any relevant sorting information or environmental claim must still describe the resulting pack accurately.
- Describe the change. Record the previous and proposed material or construction, the reason, and the affected drawing, artwork and sample references.
- Assess its consequences. Review fit, appearance, protection, weights and evidence coverage. Under Article 15(4), changes that could affect conformity require reassessment.
- Approve the revised record. Update the specification and relevant technical documentation, and review whether the declaration’s coverage needs updating. Record each approval’s scope and date.
- Identify where it starts. State the first purchase order or production batch using the new revision and make the production and inspection records refer to it.
Apply the same discipline to a proposed equivalent paper grade or varnish when a material becomes unavailable. Give an unresolved entry a specific action, owner, due date and release condition—for example, supplier composition information required before approving the substituted finish. Separate permission to make a trial sample from approval for production, and confirm that the evidence needed for EU market placement is complete.
Before production release, compare the purchase order, drawing, artwork, approved sample and evidence index together. Each should point to the agreed construction and current revision. This is where a specification earns its value: purchasing knows what was ordered, the supplier knows what to reproduce, and the compliance reviewer can identify the packaging behind the documentation.
If you have a reference box, an early design or an incomplete specification, send us your product information, destination countries and existing packaging records. We can help develop the manufacturing details, coordinate material information and sample trials, and resolve discrepancies with you before the next version is approved.
