| 1. Verify the wipe substrate composition | Ask whether the non-woven substrate contains plastic polymers, such as polyester or polypropylene, and distinguish these from cellulosic fibres such as viscose or lyocell. | Written fibre-composition specification for each product, including percentages and any coatings or binders. | EU single-use-plastics labelling rules cover wet wipes containing plastic. “Non-woven” describes a fabric structure and does not, by itself, mean plastic-free. | Directive (EU) 2019/904, Article 7 and Annex, Part D |
| 2. Confirm whether the EU label requirement applies | Determine whether the product is a wet wipe intended for personal care or domestic use and whether it contains plastic. | Product classification, intended-use description, and documented assessment of the applicable EU labelling requirement. | Article 7 of Directive (EU) 2019/904 sets marking requirements for covered wet wipes containing plastic when placed on the market in EU Member States. | Directive (EU) 2019/904 |
| 3. Check the harmonised label artwork | For products in scope, check that the packaging uses the applicable harmonised marking, including the prescribed wording and graphic layout. | Final pack artwork and a review against the applicable EU implementing regulation and its annexes. | The format and specifications for the wet-wipe marking are set out in Commission Implementing Regulation (EU) 2020/2151; a custom symbol should not be treated as a substitute. | Commission Implementing Regulation (EU) 2020/2151 |
| 4. Check language and placement for each market | Confirm that the required text is provided in the official language or languages determined by the Member State where the product is marketed, and that the marking is placed as required. | Country-specific packaging versions, language review, and print-ready proofs showing label size and position. | Labelling details can affect packaging approval across different EU markets. Validate the current requirements for each destination country. | Implementing Regulation (EU) 2020/2151, including its annexes |
| 5. Request substantiation for environmental claims | Review claims such as “plastic-free,” “biodegradable,” “compostable,” or “flushable” against the product’s actual composition and the conditions or standards cited. | Test reports or technical documentation that identify the tested product, method, conditions, and limitations of each claim. | Claims should be specific and supported. A claim does not replace a legally required marking where the product falls within the scope of the EU rules. | Directive (EU) 2019/904 |
| 6. Assess quality controls and traceability | Check how the supplier controls fibre composition, lotion application, dimensions, packaging, and batch consistency. | Product specifications, batch records, inspection procedures, change-control process, and complaint or recall procedure. | Documented controls help buyers confirm that delivered products match approved specifications and packaging artwork. | Review the supplier’s product and quality documentation for the specific item being sourced. |
| 7. Confirm change notification and market documentation | Agree that changes to substrate, formulation, manufacturing site, or packaging will be communicated before implementation. | Written change-notification terms, current technical file, and an agreed process for checking revised EU-market artwork. | A change in materials or packaging may affect product claims, label applicability, or the accuracy of previously approved documentation. | Implementing Regulation (EU) 2020/2151 |