For a recyclable packaging claim, keep a record connecting the exact wording, the finished packaging, the assessment, the destination recycling route and the production version. Someone reviewing the claim should be able to follow the words printed on the box back to the evidence supporting them. For brands selling paperboard cartons or rigid gift boxes in the EU, that means accounting for the wrapping paper, coatings, glue, inserts and closures as well as the main board.

Start with the exact claim and its scope

Save the approved wording alongside the artwork, recycling symbols, translations and corresponding product-page copy. Identify whether the claim describes the outer box, an insert, the complete packaging unit or a wider range of packaging. A statement limited to the paperboard box on the artwork should retain that boundary in the online description. Record the countries or areas covered and any conditions attached to the statement.

Article 14 of the Packaging and Packaging Waste Regulation (PPWR) sets conditions for environmental claims concerning packaging properties regulated by the PPWR. Claims must concern properties exceeding the applicable minimum requirements, following the Regulation’s relevant criteria, methodologies and calculation rules. They must specify whether they concern the packaging unit, part of it or all packaging placed on the market by the operator. Compliance with these conditions must be demonstrated in the Annex VII technical documentation. The claim review therefore needs to explain both the supporting evidence and the relationship to the applicable legal minimum.

That comparison is date-sensitive. Article 6 schedules its detailed design-for-recycling condition and A/B/C grade-based market-access restriction for 1 January 2030 or 24 months after the relevant delegated acts enter into force, whichever is later. The recycled-at-scale requirement starts on 1 January 2035 or five years after the relevant implementing acts enter into force, whichever is later. Keep these staged requirements distinct from laboratory assessments: a 4evergreen technical recyclability score is not a PPWR performance grade.

Keep six connected groups of records

The following is a recommended working structure, rather than a statutory checklist of Annex VII contents. It can be a simple index linking existing documents. Use the same packaging reference and revision across the records so that a colleague can connect the claim to the specification, assessment and production order without guessing.

Make the assessment match the finished construction

Consider a skincare gift set in a wrapped rigid box, with a removable foam insert and a ribbon pull attached beneath the wrapping paper. A report covering the greyboard leaves the wrap, finish and assembly adhesive unassessed. A report covering the assembled box might still exclude the loose insert. Before approving a proposed claim about the complete packaging, the file needs to show how all those elements have been addressed. A claim about a named component has a narrower evidence boundary, while remaining subject to the applicable claims rules.

For Article 6’s staged recyclability assessments, integrated components are included in the assessment, while separate components are assessed separately. Integrated components that can separate through mechanical stress during transport or sorting also require separate assessment. Article 6(9) further requires components to be compatible with established collection, sorting and recycling processes and not hinder the main body’s recyclability. An annotated construction drawing makes these relationships visible.

If the assessment or claim depends on the consumer removing a component, retain photographs and a practical check of that removal, together with the intended instructions. A loose tray that lifts out and a ribbon glued beneath the wrap present different tasks. Laboratory sample preparation follows the test method; it does not establish that consumers will perform the same separation. The report should make clear how removed parts were accounted for and which parts its conclusion covers.

In our EU packaging projects, CMIC can bring together the construction breakdown, supplier information and sampling brief, and coordinate suitable assessment work. Agreeing these details before testing helps the sample, purchasing specification and proposed artwork describe the same packaging. It also gives the brand a useful intermediate result: a clear view of what the evidence covers and which design questions still need resolving.

Read what the laboratory result establishes

Paper recycling needs to recover usable fibres while controlling unwanted material. Cepi’s Version 3 laboratory method, published in February 2025, emulates pulping, screening and sheet formation in a recycling mill with a conventional process. The corresponding 4evergreen evaluation uses results concerning material yield and quality, including visual impurities and sheet adhesion—the tendency of the recovered material to form tacky sheets. These measurements help explain whether recovered fibre will be useful in subsequent papermaking.

A public, redacted DS Smith sample report illustrates why the complete conclusion matters. For a fibre-based pouch, it reports a screening yield of 89.5% and a final technical score of +50/100. It finds the sample suitable for standard-mill recycling, while identifying repulpability issues, visual impurities and a qualification that it should not be abundant in the processing mix. The report uses the older December 2022 beta protocol, so these figures illustrate report interpretation, rather than current benchmarks for another pack. Yield and technical score are different measurements; neither measures the proportion of sold packs actually collected and recycled.

The April 2025 edition of 4evergreen’s evaluation protocol explicitly excludes collection, sorting, the effects of recycling different packaging items together and food residues. Its scores are specific to the recycling process assessed and cannot be transferred between process types. Retaining the method version, underlying results and interpretation preserves the useful technical finding while leaving market-route questions clearly identified for separate assessment.

Label other supporting documents by the property they address. A recycled-content declaration concerns material input; a fibre-sourcing chain-of-custody certificate concerns the documented sourcing chain. These records can support their respective claims, but neither establishes the collection or recycling performance of the finished box.

Keep evidence for the destination recycling route

For packaging made in China and sold with a product in the EU, the relevant disposal conditions are those in the destination market. Retain dated acceptance guidance or an assessment from appropriate collection authorities, recovery organisations or assessment providers. The evidence should address the particular format and construction, the collection stream, sorting where needed and compatible processing. Record the territory each source covers, especially when combining evidence for a launch across several countries.

The disposal setting can change the answer even within one country. An outer carton unpacked by a retailer may enter an agreed commercial paper collection. The gift box carried home by the shopper follows household collection arrangements. Records for the retailer’s waste contractor support the first situation; the consumer-facing gift box needs evidence relevant to the second.

For a construction that needs a specialised recycling process, the assessment should explain how collection and sorting direct it to that process. As 4evergreen’s collection and sorting guidance explains, specialised mills have different input requirements and cannot automatically handle every fibre-based composite. An assessment provider familiar with the destination can help connect these stages. Keep the acceptance conditions and supporting documents, including dated copies of web guidance, so the basis of the decision remains available when services or guidance change.

Who must hold the documents, and for how long?

Under the PPWR, commissioning packaging or a packaged product under your own name or trademark generally makes your business the manufacturer, even when another company physically makes the box. Specific micro-enterprise exceptions involving EU-based suppliers can change that allocation and need checking against the actual arrangement. An importer is an EU-established operator placing packaging from a third country on the EU market. For packaging sourced from China, identify these responsible entities explicitly when agreeing who prepares and supplies the documentation.

• Manufacturer: Article 15 requires the manufacturer to carry out or arrange the applicable conformity assessment and prepare Annex VII technical documentation before placing packaging on the market. Once conformity with the applicable requirements has been demonstrated, it must draw up the EU declaration of conformity. The technical documentation and declaration must be retained for five years for single-use packaging or ten years for reusable packaging, measured from the date the packaging was placed on the market.
• Importer: Article 18 requires checks that include ensuring the manufacturer has carried out the conformity assessment and prepared the required technical documentation. The importer must keep a copy of the EU declaration of conformity and ensure the relevant technical documentation can be made available to market surveillance authorities. The same five-year and ten-year periods apply, starting from market placement.

Article 16 requires suppliers to provide the manufacturer with the information and documentation necessary to demonstrate packaging and material conformity. Supplier declarations and material data therefore feed into the responsible manufacturer’s assessment. Agree which party will provide each item and how any missing information will be resolved; a broad assurance that the packaging is compliant leaves the underlying evidence difficult to examine.

The retention clock starts when packaging is placed on the market, rather than when a laboratory issues its report. A report supporting later batches can remain needed long after its test date, which is why order, batch and market-placement records belong alongside the version history. Articles 15(10) and 18(8) also require manufacturers and importers to make relevant documents available within ten days of receiving a reasoned request from a national authority. A named file owner and dependable access make that obligation workable.

Keep the evidence relevant through reorders and changes

Article 15(4) requires manufacturers to maintain conformity in series production, account for relevant design and specification changes, and reassess when conformity could be affected. In practice, record the proposed change, the affected evidence and the decision on whether further assessment or testing is needed. Where an existing assessment remains applicable, retain the technical reasoning for that conclusion.

A reorder may keep the same dimensions and appearance while changing the wrapping paper, adhesive or protective coating. Those substitutions can affect recycling behaviour despite the visual match. Agree notification of relevant material and construction changes with suppliers before production. CMIC can help coordinate the revised specification, supplier information and assessment questions so the brand can decide whether the existing claim still has support.

A new destination market also deserves review, even when the packaging itself is unchanged, because collection and processing conditions may differ. Preserve earlier artwork, specifications, reports and decisions with their applicable orders instead of overwriting them. The resulting history should explain both the claim used today and the claim printed on packaging already supplied.

For a new design or a claim already in use, a useful starting point is the packaging drawing or sample, the intended EU markets and the exact proposed wording. Share those with CMIC, and we can help organise the construction details, supplier evidence and suitable assessment work. That gives your team a clearer basis for choosing the packaging and approving what it says.