To document packaging minimisation under PPWR, build a traceable explanation of the approved design: what the packaging must do, which reductions were considered, what the evidence showed and why the remaining weight and volume are necessary. A specification records what you ordered. The minimisation assessment explains why that specification is justified.

Article 10 of Regulation (EU) 2025/40 requires packaging weight and volume to be reduced to the minimum necessary for functionality, taking account of its shape and material. Annex IV supplies the performance criteria for that assessment. For a product brand, the useful question is therefore more demanding than whether the new box is lighter than the old one: what prevents a further reduction while preserving the functions the pack needs?

Keep the dates separate. PPWR generally began applying on 12 August 2026; Article 10’s minimum-weight and minimum-volume design requirement has a 1 January 2030 deadline. Preparing this assessment belongs alongside your current compliance work. A later design deadline does not postpone other requirements already applicable to your packaging.

Start with an identifiable packaging configuration. A glass skincare bottle in a folding carton, its insert and the corrugated outer used for distribution form a particular protection system. The same carton used for a heavier bottle or sent individually through a parcel network may need a different assessment. Record the product and distribution conditions alongside the packaging version so that the evidence has a clear scope.

The following is a practical structure for the minimisation part of your technical documentation, rather than a prescribed EU form. A short assessment can link to existing drawings, specifications and reports; those records need to tell a consistent story about the same approved version.

Make the functional requirements specific enough to evaluate. “Protects the product” leaves too much unexplained. For a glass bottle, the relevant conditions might include preventing breakage and leakage, keeping the closure protected and holding the bottle securely during the intended handling sequence. For the carton, they might include reliable erection and closure, resistance to the expected stacking load and sufficient access to remove the bottle without forcing it.

Apply the same reasoning to components retained for information. If a sleeve carries required product information, identify that information and examine whether it can fit legibly on an existing surface. An artwork comparison may establish that the sleeve can be removed. Where a separate component remains necessary, record the requirement and the layout constraint that justify it. This gives the decision more substance than describing every printed piece as essential.

Choose evidence that answers the uncertainty. A measured fit check can establish whether fingers can reach a product; a strength question may need calculations and physical trials. For a test report, retain the sample revision, product configuration, method, conditioning, sample quantity, acceptance criteria and actual results. Photographs help show what happened, but an image of an undamaged sample alone says little about the conditions it survived.

At CMIC, we can develop smaller and lighter paper-packaging options, prepare the associated specifications and coordinate suitable evaluation. Separating the questions often makes the work clearer: compare a reduced footprint first, then examine a lighter board or a different insert arrangement. A useful intermediate result is a comparison sheet that connects each sample to its dimensions, component weights and observations, giving your team a manageable basis for a decision.

Consider a 50 ml glass skincare bottle sold in a folding carton and distributed inside a specified corrugated outer. The product reference, closure, fill specification and outer shipping arrangement remain unchanged during the comparisons. Acceptance requires the bottle to remain intact, leak-free and securely held after the defined handling sequence, and the carton to remain stable under the specified stacking conditions. All figures, trial outcomes and the completed assessment below are illustrative. Box dimensions are external; weights are finished paper-component weights.

Version B uses about 24% less paper-component mass and occupies about 30% less external box volume than version A. Those figures describe the improvement. The assessment then needs to explain the remaining limits: why the carton needs its retained strength and why the bottle needs the retained protective clearance. These are separate questions, supported by different observations.

Before approving B, the follow-up work investigates whether changes to the board or folds could recover the lost performance. It also separates D’s dimensional changes so that the effect of reducing the footprint can be distinguished from reducing the height. In this illustration, the resulting records close those questions as follows.

Illustrative assessment conclusion: Approve version B at 65 × 65 × 145 mm, with a nominal 26 g carton and 9 g insert, using the specified board grades, folds and tolerances. The retained weight is justified by stacking stability and bottle restraint; the retained dimensions provide the validated cushioning, base support and closure clearance at the permitted dimensional limits. The assessed lighter and smaller alternatives compromise those functions, including after the recorded construction changes. B meets the acceptance criteria for the defined bottle, fill specification, shipping outer and distribution conditions. The conclusion is supported by drawing B, its component specification, dimensional checks and the initial and follow-up trial records.

The completed entry connects each retained feature to a necessary function and the evidence that limits further reduction. Further investigation is warranted if a failure remains unexplained, a credible reduction has not been evaluated or passing samples do not cover the stated tolerances. Those gaps would leave the assessment open even if B showed an impressive saving over A. Here, the follow-up findings support the decision for the defined construction and conditions.

Keep the surrounding packaging visible in that reasoning. If a lighter sales carton requires a heavier shipping outer or additional cushioning, record those changes and reassess the relevant configurations. Otherwise, a reduction recorded for one component can conceal additional material elsewhere. Equally, changing an insert may allow both the sales carton and its shipping outer to become smaller—a useful result that a carton-weight comparison alone would miss.

The minimisation assessment forms part of the broader technical documentation addressed by Annex VII. That documentation supports the conformity assessment and the EU declaration of conformity. The declaration is the formal statement of conformity; the underlying records explain its basis. A material certificate or substance test report can support another aspect of compliance, but it cannot explain why a particular box needs its dimensions or board weight.

Identify the responsible companies early. The PPWR manufacturer is not necessarily the factory physically making the box. A brand commissioning packaging under its own name or trademark can be the manufacturer in the legal sense, including when the packaging is made in China. Record the role determination for the actual supply arrangement, alongside the practical division of work.

• The manufacturer is responsible for the applicable conformity assessment, technical documentation and EU declaration of conformity.
• The packaging supplier provides the information and documentation needed to support that assessment. For custom paper packaging, this can include component specifications, drawings, sample records and relevant evaluation evidence.
• An EU importer, where applicable, has verification duties, retains a copy of the declaration and must ensure that the technical documentation can be made available to the authorities.

This division works best when the brand’s product and distribution knowledge meets the supplier’s structural and manufacturing knowledge. We can help organise the packaging evidence and identify which questions need further evaluation. Your team contributes the actual product conditions, intended market use and information requirements. Agreeing who supplies, reviews and keeps each record reduces the risk of discovering that an approved sample and its supporting report describe different versions.

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. Importers have corresponding declaration-retention and documentation-availability duties. Link the retained evidence to the relevant packaging versions and market-placement records so that replacing a design does not make the earlier assessment disappear.

Also identify the assessment methods and standard editions used. EN 13428:2004 is the established source-reduction standard discussed in guidance on the transition to the PPWR minimisation framework. Where it informs your assessment, record how it was applied and review the work against the applicable Article 10 and Annex IV requirements as standards and methods develop. An unexplained standard number contributes little to the design justification.

Review the assessment when a change affects its basis: a heavier product, different bottle dimensions, a new board grade, revised insert, changed pack quantity or different delivery route. The review should establish which evidence remains applicable and which needs updating. An artwork adjustment may leave the mechanical evidence intact, while a material change may affect strength even if the drawing is unchanged. Record that judgment and connect the approved revision to production specifications.

Keep Article 24 empty-space calculations distinguishable from the Article 10 minimisation reasoning. Empty-space requirements concern how packaging is filled; the minimisation assessment also addresses the material and structure needed to perform its functions. The external-volume comparison in the example above is a design comparison, not an Article 24 calculation. For the wider relationship between these rules, see our guide to PPWR packaging minimisation and empty-space rules.

A well-developed record lets someone follow the decision from product need to approved packaging without reconstructing months of emails. If you have an existing box, a sample or an early packaging idea, discuss it with us. CMIC can help develop meaningful reduction options, compare their performance and organise the supporting packaging records, giving your team a clearer basis for both the design decision and its documentation.