Keeping the File: Retention for Five and Ten Years

The technical documentation and the declaration must be kept available for five years after the packaging is placed on the market - ten years for reusable packaging, whose service life and return cycles justify the longer memory. The clock runs per placing, so the archive is not a project with an end date but a rolling obligation whose oldest live entries age out continuously. 'Kept available' means producible to an authority, legible, and connected to the placing it covers - a standard that bites hardest not in year one but in year nine, after two system migrations and a reorganisation.

This guide is the retention architecture: ownership, formats, events, and the retrieval drills that prove the archive works.

Archives rarely die of neglect; they die of events. ERP and document-system migrations that map the present and orphan the past. Acquisitions and divestments, where the packaging business changes hands and the files' custody is a schedule nobody drafts. Site closures, where the plant's records meet the skip. Supplier exits, where evidence held 'at the supplier' evaporates with the relationship. Each event has the same antidote: the conformity archive treated as a named asset with an owner, included in migration scopes and transaction schedules expressly, and held - or escrowed - independently of any single supplier relationship. Due-diligence checklists for packaging businesses should list the Article 15 archive by name; acquirers who discover its absence after completion have bought the liability without the defence.

Ten years outlives file formats, software versions and storage media. The archive's format discipline: records in durable, documented formats (PDF/A for documents, structured exports for data), with the reading path independent of the originating application; certificates and declarations as rendered documents plus their underlying data where data exists; and a migration review on the records calendar - every system change tests a sample of the oldest live records for legibility as part of its acceptance. Cryptographic fashions will change across the decade; plain legibility will not. Favour it.

Reusable packaging's ten-year horizon interacts with the assets' own lives: the file must connect the declaration to the asset population (marks, batches, system records) across the years the assets circulate, including the system's changes (new wash processes, label revisions, operator changes). The system's records and the conformity file should reference each other by design, so that year-nine questions - was this batch's label the version declared? - are answered by lookup rather than by archaeology. Operators building systems now hold an advantage: instrument the join from launch, because retrofitting ten years of asset history is the expensive direction.

Availability is proven by retrieval, and retrieval should be drilled: annually, select placed packagings from the oldest live cohort, produce their complete files against a clock, and log the result. The drill finds the migration orphans, the departed employee's personal drive, the supplier evidence that was never actually received - while the finding is still an internal embarrassment rather than an authority's conclusion. Keep the drill log with the archive's governance records; like the surveillance rehearsal of the assessment guide, the log itself is evidence of a system that works.

A retention subtlety worth stating plainly: the clock runs from the placing of the packaging - each production run's placing starts its own documentation clock for the file version that covered it. The archive therefore retires by version-cohort, not by product: a line placed continuously for a decade holds files whose clocks expire in the order of their placings, while its current file remains live until five years after its last placing. Retention schedules built by product ('delete three years after delisting') routinely breach the rule at both ends. Build the schedule from the placing records, which the traceability duty already keeps, and let the cohorts expire arithmetically.