Annex IV Performance Criteria: The Justifications That Make Material Lawful

Annex IV lists the performance criteria packaging must satisfy, and Article 10's minimisation duty is judged against them: weight and volume are lawful to the extent a criterion requires them. The criteria run: product protection; packaging manufacturing processes; logistics (transport, warehousing, handling); functionality for the user; presentation of information; hygiene; safety; and other legal requirements. A heavy pack that protects a fragile product through a documented distribution chain is minimised in law. A light pack that fails its product is not virtuous - it is under-packaged, with the waste of the product itself as its environmental cost.

The criteria are therefore the vocabulary of the technical file's design argument. This guide works them as a checklist a designer can argue from, in the order products usually need them.

Product protection is the criterion with data behind it: distribution testing (drop, vibration, compression), damage and return rates by specification, shelf-life trials where barrier is the protection. Argue from the data or expect the argument to be discounted; 'we have always used this gauge' is not a criterion. Logistics extends the argument along the chain: pallet stability and cube utilisation, automated handling requirements, retail-ready formats the chain mandates. Note the interplay with the empty-space cap: logistics may justify a standard carton across a range (cube efficiency at pallet level) while the consignment ratio still disciplines its use per order - the criteria argue at their own levels, and the file should keep the levels distinct rather than letting a pallet argument answer a parcel question.

Functionality covers the pack's working features: reclosability that preserves the product, dispensing that doses it, child-resistance and tamper evidence where required, accessibility features. Hygiene and safety carry particular weight for food and contact uses: barrier and seal integrity, migration control, the sterile or aseptic formats whose material intensity is the price of the safety function. Legal requirements catch the residue: pharmaceutical and dangerous-goods packaging whose specifications are set by other regimes, labelling space genuinely required by information law. Each is a real criterion; each is also capable of being inflated. The file discipline is specificity - name the requirement, cite the instrument or the test, quantify the material it drives. Criteria invoked in general nouns ('safety', 'quality') without their specifics are the audit's first target.

A minimisation justification that holds up has four parts. The baseline: what the pack must do, stated as measurable functions. The options: the lighter candidates considered, with the test or calculation that eliminated each - because an argument with no considered alternatives is a conclusion, not a justification. The decision: the specification chosen, tied criterion by criterion to the functions. And the review trigger: the condition under which the justification reopens (a new material, a changed distribution chain, a damage-rate movement). Kept per packaging family rather than per SKU where families genuinely share a design, this is an afternoon's documentation per family - and it converts minimisation from the programme most businesses fear into the one with the clearest paper.

A premium food jar is 40 percent heavier than the category's lightest equivalent. The file argues: protection - the product is a fragile, high-value preserve whose breakage cost (product, refund, brand) at the light gauge is documented from a two-lane field trial at three times the heavy pack's rate; logistics - the jar's geometry is the pallet pattern's module, and lightening its walls without changing its footprint buys nothing in cube; hygiene - the seal land's width, which the wall carries, is what the hermetic seal's validation specifies. Information, safety and law: neutral. Conclusion: the weight is the criteria's sum, the lighter candidate was tested and eliminated on evidence, review reopens if the seal system changes. That is a minimisation file. The same jar with a file reading 'premium feel' is a finding awaiting a date.