Annex VII Technical Documentation: The Complete Contents Checklist

Annex VII prescribes the technical documentation's contents: a general description of the packaging and its intended use; design, manufacturing and composition information sufficient to identify exactly what was assessed; the list of applicable requirements with the harmonised standards, criteria or other specifications applied to each; and the evidence itself - design calculations, risk and conformity assessments, test reports, supplier documentation and the recycled-content, recyclability, minimisation and substance dossiers the earlier stations built. The documentation must make conformity assessable by an authority that has never seen the product before.

This guide converts the annex into an assembly checklist, with the failure each element exists to prevent marked beside it.

Description and identity: the packaging's identity (drawings, photographs, specification references), its intended products and markets, and its component breakdown - the same component map the labelling station uses. Composition: materials per component with grades and suppliers, including recycled content basis and substance-relevant inputs. Requirements index: every requirement of the regulation assessed for applicability to this packaging (with non-applicability reasoned, not omitted), and the route taken for each - standard, criteria act, or direct assessment. Evidence set: calculations (recycled content, empty space), assessments (recyclability grading, minimisation justification, substance inventory and minimisation record), test reports (PFAS and metals screens, performance validation), supplier declarations and certificates. Closure documents: the declaration itself, its version and signatory authorisation, and the change log that keeps the file's history legible.

Of the checklist, the applicability index is the one most often missing and most diagnostic when present. A file that contains evidence only for the requirements its author remembered invites the question of what else was forgotten; a file whose index works through the regulation's requirements one by one - applicable, with evidence reference; not applicable, with the reason (not food-contact; not reusable; below the format's scope) - demonstrates that the assessment was systematic. Build the index as a table generated from the requirements register, per packaging family, and review it whenever the regulation's second layer adds requirements. It is an hour's work per family and the single best predictor of how the rest of the file reads.

The documentation's quality standard is usability by a stranger: a surveillance officer, a new compliance hire, an importer's verifier - each should be able to take the file cold and answer, per requirement, what was required, what route was taken, and where the proof sits. Files fail the reader test through archaeology (evidence present but unfindable), through orphans (reports that name no specification version), and through narrative (essays where an index should be). Assemble for the reader: indexes over folders of PDFs, references over attachments, versions over volume. The file's job is not to be large; it is to be conclusive at reading speed.

Reusable packaging's files carry the system's documents beside the asset's (system description, rotation evidence, the label and QR specification); transport packaging's files lean on the consignment-level records (film specifications, case and pattern data); imported packaging's files are assemblies of the upstream manufacturer's documentation plus the importer's verification record, the subject of its own guide in this station. The checklist's spine - identity, composition, applicability index, evidence, closure - holds across all of them; what changes is which evidence dominates. Build the spine once as the house template and let each family's file declare its own centre of gravity.

For a new packaging line, assemble in dependency order: identity and composition first (everything references them), applicability index second (it commissions the evidence), evidence third (generated against the index, not against memory), declaration last (it states what the evidence supports, and cannot honestly be drafted earlier). Teams that draft the declaration first and gather evidence to fit it have inverted the system's logic, and the inversion is visible in the file's dates. Keep the honest order and the dates corroborate you.