(PPWR 3) Traceability and Documentation: New Obligations for Professionals

Minerya
Mar 25
2 min read

Paperwork becomes strategic: European Regulation 2025/40 imposes an enhanced traceability system. Practical guide to stay compliant and avoid sanctions.

The Declaration of Conformity: Your Mandatory Passport

Since January 2025, each food contact material must have its official "identity card" (Article 9). This declaration of conformity is no longer optional but a legal obligation for all actors in the chain.

What your declaration must contain

The identity and address of the manufacturer
Precise identification of the material or object
Date of issuance
Confirmation of compliance with Regulation 2025/40
Usage specifications (types of food, temperature, contact duration)
List of substances used subject to restrictions
Applicable specific migration limits

⚠️ Attention

This declaration must be updated with each change in composition or manufacturing process.

Technical Documentation: The Complete File to Compile

Article 10 requires the compilation of a detailed technical file, available for control authorities. This is no longer the time to improvise!

Essential elements of the file:

1. Information on Materials

Complete composition with percentages
Technical sheets of raw materials
Detailed manufacturing processes
Transformation conditions

2. Test Results

Migration analysis reports
Global and specific migration tests
Risk assessments
Certificates from accredited laboratories

3. Calculations and Modeling

Exposure estimates
Worst-case usage scenarios
Justifications for applied limits

💡 Practical Tip

Organize your documentation in digital format with a versioning system to track all changes.

Traceability: Track Your Materials from A to Z

The new traceability system (Article 11) requires the ability to trace the entire supply chain up and down within 24 hours.

Information to record for each transaction

Upstream: name and address of suppliers, delivery dates, batch identification
Downstream: professional clients, shipping dates, batch numbers
Conservation: minimum 5 years after market release

Recommended System

Assign a unique code per batch
Centralized database
Regularly tested recall procedures
Staff training on procedures

Cooperation with Authorities: Mandatory Transparency

Article 12 establishes a duty of total cooperation with control authorities.

Your obligations

Provide all documents within 48 hours
Allow access to production sites
Communicate in case of detected non-compliance
Facilitate sample collection

In case of control

Appoint a "MCDA compliance" officer
Prepare a ready-to-use control file
Train your teams on inspection procedures

Documentary Compliance Checklist

✅ Up-to-date declaration of conformity for each product

✅ Complete and organized technical file

✅ Operational traceability system

✅ Documented recall procedures

✅ Supplier and client registry

✅ Secure archives (minimum 5 years)

✅ Designated compliance officer

✅ Tracked staff training

Mistakes to Absolutely Avoid

❌ Using generic non-specific declarations

❌ Neglecting updates after modifications

❌ Keeping only paper documents

❌ Underestimating response times to authorities

❌ Omitting certain intermediaries in the chain

Next Steps for Your Company

Immediate Audit of your existing documentation
Implementation of a document management system
Training your teams on new requirements
Testing your traceability procedures