| Intended use and market category | Confirm whether the wipes are designed for personal care or domestic use, and document their intended users and use instructions. | Record product type, intended use, wipe count, sheet dimensions, and target countries for each SKU. | EU Directive 2019/904 covers certain single-use plastic products, including wet wipes for personal care and domestic use that contain plastic. Confirm applicability for the specific product. |
| Nonwoven composition | Obtain a material declaration identifying each fibre and its percentage by weight. | Example specification: 70% viscose and 30% polypropylene by weight. Treat this as an illustrative data point, not a universal product formula. | Do not describe a wipe as plastic-free unless its composition and supporting evidence substantiate the claim. Natural-origin fibres such as viscose do not, by themselves, establish that the finished wipe contains no plastic. |
| Plastic presence and evidence | Request signed composition declarations, bill-of-material records, and supporting test or supplier documentation. | Check the wipe substrate, binders, coatings, packaging films, and closures separately; identify the material and evidence for each component. | For covered wet wipes, the harmonized marking requirements are set out in Commission Implementing Regulation (EU) 2020/2151. Confirm that the required marking is used where applicable. |
| Harmonized on-pack marking | Review the artwork against the applicable wet-wipe marking design and technical requirements before printing. | Keep an approved artwork file and a version record for each market and packaging format. | The marking informs consumers about plastic content and the environmental harm associated with littering or incorrect disposal. Do not substitute a generic disposal icon for a required harmonized marking. |
| Language and market coverage | Check the languages and consumer-information requirements for every country where the product will be sold. | Maintain a country-by-country artwork matrix, including language versions, label placement, and approval status. | Verify applicable national implementation and language expectations with the importer or local compliance adviser; avoid assuming one language version is suitable for all EU markets. |
| Disposal instructions | Ensure consumer guidance is clear and consistent with the product, packaging, and local waste systems. | Use instructions that distinguish the wipe from the empty package where needed, and check that claims are supported. | Do not imply that a wipe is suitable for flushing unless that claim is appropriately substantiated and permitted. The EU single-use-plastics marking does not replace local disposal guidance. |
| Pack format and label visibility | Assess the label on the actual retail pack, including flexible packs, tubs, and multipacks. | Check legibility, contrast, print durability, and visibility after sealing, folding, or application of an outer label. | Confirm the harmonized marking remains visible and follows the applicable technical specifications in Implementing Regulation (EU) 2020/2151. |
| Supplier documentation | Request current technical data sheets, material declarations, artwork proofs, and change-notification procedures. | Store documents by SKU, production site, revision date, and destination market; recheck them after any material or artwork change. | Keep evidence linking the composition assessment to the compliance decision and final packaging artwork. |
| Import and quality controls | Include substrate identity, wipe dimensions, count, seal integrity, and label checks in the inspection plan. | Set acceptance criteria before production and retain batch records and approved samples. | Inspect production packaging against the approved market-specific artwork, rather than relying only on a supplier’s general compliance statement. |
| Claim and risk review | Review environmental, biodegradability, compostability, and flushability claims separately from regulatory marking. | Require claim-specific evidence and check that wording matches the product tested and the intended disposal conditions. | A claim does not replace mandatory marking or establish compliance with Directive 2019/904. Avoid broad environmental claims that cannot be substantiated. |