TR CU 005/2011: documents for packaging and model media

Packaging is the only regulation that reaches almost everyone. You may not make cosmetics, import electronics or sew clothes, but you pack your goods into something. And if the product is in contact with the packaging, not only the content must be safe but also what is around it.

What TR CU 005/2011 regulates

The regulation applies to packaging and closures put into circulation in the territory of the Union. It covers consumer packaging and transport packaging, and also caps, stoppers and dispensers — all of these are closures with their own requirements.

Almost all materials are covered:

• Polymer packaging — films, bottles, jars, containers, bags
• Glass — jars, bottles, vials
• Metal — cans, tubes, aerosol cans, foil
• Paper and cardboard — boxes, bags, corrugated containers
• Made of combined materials — multilayer bags, Tetra Pak
• Made of textile and wood — sacks, crates, pallets

The key fork inside the regulation is whether the packaging is in contact with food products or not. The amount of tests depends on it, and the difference between the two cases is significant.

Who must issue the document

This is the question that is confused most often. The applicant under the packaging regulation is the one who puts the packaging itself into circulation — its manufacturer or importer. Not the one who pours something into it.

The third line is the most frequent situation for manufacturers. You do not need to issue your own declaration for a jar, but you must get it from the supplier and keep it: it is exactly what will be asked for when your product is checked.

Form of assessment and schemes

For packaging, declaration of conformity is provided. Certification is not used — that is, the applicant makes the decision and bears the responsibility, and test reports serve as the evidence.

• Schemes 3d and 6d — for serial production. 6d relies on a certified quality management system.
• Scheme 4d — for a batch.

A declaration for serial production is issued for up to five years. How the scheme affects the set of evidence and the time, we explained in a separate article.

Model media: the main thing to understand about tests

Packaging in contact with food is not tested "in general". It is tested in relation to what will be put into it. For this, model media are used — liquids that imitate the real product.

A practical consequence worth remembering: the test report is tied to the conditions of use. A document for a container tested for cold dry products does not confirm that it is suitable for hot filling, for a fatty medium or for a microwave oven. Formally the declaration exists, but in fact it is about another scenario.

What is determined in the laboratory

• Sanitary and chemical parameters: migration of substances from the packaging material into the model medium
• Organoleptic parameters: whether the packaging gives the product a foreign smell or taste
• Toxicological parameters for some types of materials
• Mechanical characteristics: strength, tightness of the closure
• Resistance to conditions of use: heating, freezing, sterilization — if they are declared

Organoleptic parameters are underestimated, and they fail batches no less often than chemistry: plastic with a foreign smell makes the whole product unusable, even if migration is within the norm.

Packaging marking

The packaging carries its own marking, and it is not the same as the marking of the product inside.

• The single mark of circulation (EAC) — confirms conformity with the regulation.
• The food contact symbol — the familiar glass and fork. It means the packaging is suitable for contact with food.
• Indication of the material — a letter or number code, helps to sort waste.
• The Möbius loop — a sign that the packaging can be recycled.
• Information about the manufacturer — name and address.
• Conditions of use — if there are limits on temperature, medium or repeated use.

A separate subtle point: the EAC mark on the packaging can relate both to the packaging and to the product. If the product falls under its own regulations, the mark is applied for the whole. More about the rules for applying the mark itself — in the article about EAC marking.

Importing packaging

If you import containers and do not produce them, the scheme is the usual one for import, but with a few special points.

• The applicant is an importer registered in the Union
• A specification of materials from the manufacturer is needed — without the composition it is impossible to choose the tests
• Model media are chosen for the use for which you will sell the packaging
• Samples must be from the batch, not display samples
• Marking is applied before the release into circulation
• Foreign food contact certificates do not replace the declaration, but they shorten the selection of tests

The last item is worth using: if the manufacturer has already tested the material by international methods, this data saves time, though it does not cancel the issuing here.

The environmental fee is a separate obligation

This is a topic that is regularly confused with technical regulation, although there is no link between them. Extended producer responsibility means that the one who puts goods in packaging into circulation is responsible for its disposal after use: either they ensure the recycling of the set share, or they pay the environmental fee.

• This is not a conformity document. A declaration under 005 confirms safety and does not solve the question of disposal.
• The obligation lies with the one who puts goods in packaging into circulation, not with the manufacturer of the container.
• Reporting is submitted separately, in its own forms and terms.
• Importers are also covered by this obligation for the packaging they import.

A practical conclusion: a declaration for the packaging does not close the question of the environmental fee, and the other way round. These are two independent lines, and they are checked by different authorities.

Typical errors

The first line is found most often: a roll of film and a bag made from this film are different products from the point of view of the regulation.

Order of actions

• Decide who you are in this chain: a packaging manufacturer, an importer of containers or the one who fills them
• If you fill — ask the supplier for the declaration for the packaging when buying, not later
• Check the supplier's document in the register and compare the model media with your product
• Make sure that 005 is included in the list of regulations in your product declaration
• Check the claims on the packaging: heating, freezing, reuse
• Agree on the layout of the packaging marking before printing the run
• Close the question of reporting on packaging disposal separately

How the packaging regulation fits into the general set for food products — in the article about TR CU 021/2011, and for cosmetics — in the review of the cosmetics regulation. To check the supplier's document in the register, use the material about electronic documents.