Sales Units can contain user guidelines and manuals, but are these items considered packaging materials or not?
In the European Union, including countries like the Netherlands, Germany, and France, instruction manuals enclosed with products are generally not classified as packaging material under the Packaging and Packaging Waste Regulation (PPWR), which replaced Directive 94/62/EC.
The PPWR defines packaging as materials used for the containment, protection, handling, delivery, and presentation of goods. Instruction manuals, serving as product information or documentation, do not fulfill these functions and are thus excluded from the definition of packaging.
European Parliament
However, it's important to note that national interpretations can vary. For instance, in Germany, under the Packaging Act (VerpackG), the classification of such materials may depend on their specific use and presentation. If a manual is designed primarily for marketing purposes or is intended to be discarded after purchase, it might be considered packaging. Conversely, if it's meant to be retained by the consumer for product operation, it's typically not regarded as packaging.
Given these nuances, it's advisable to consult with the relevant national authorities or compliance schemes—such as Verpact in the Netherlands, Der Grüne Punkt in Germany, or CITEO in France—to obtain precise guidance tailored to your specific product and its packaging components.
Three types of documents
Product Information Document (PID) – Long-Term
-
Definition: Documents that are intended to be kept by the end user throughout the lifecycle of the product.
-
Examples: User manuals, safety instructions, maintenance guides, technical specifications.
-
Purpose: To inform proper usage, ensure safety, provide ongoing support.
-
Classification (Regulatory View): Typically not considered packaging under EU regulations because the document is retained and used continuously by the consumer.
Product Usage Aid (PUA) – Short-Term
-
Purpose: Facilitates initial setup or first use, but not kept long-term.
-
Examples: Quick start guides, single-sheet installation instructions, setup checklists.
-
Regulatory Status: May be considered packaging, as they are often discarded immediately and aid in product presentation or usage initiation—functions aligned with packaging as per the EU definition.
Sales or Promotional Material (SPM) – Short-Term
-
Definition: Documents or leaflets that are intended to be discarded shortly after unboxing.
-
Examples: Warranty cards, promotional flyers, marketing material.
-
Purpose: To facilitate immediate action (registration, promotion, support).
-
Classification (Regulatory View): May be considered packaging if their function aligns with presentation or marketing and they are disposed of with the packaging.
PUA and SPM are considered packaging, see IMDE Code list for Packaging Types