EPR Packaging Data From a Supplier: The Fields You Need

E2 · Extended producer responsibility

The Supplier Data You Need Before You Can File an EPR Return

9 min readFoliware India LLPReviewed 14 September 2026

The short answer

Every European packaging extended producer responsibility scheme prices your contribution on material and weight per packaging component, not per shipment. That means a weight in kilogrammes for each of the carton blank, inner bag, tape, label, stretch film, corner boards, top sheet and pallet, with each material stated. A supplier who has only weighed a full carton cannot give you that, and a first return is where importers find out.

Why the data arrives late, every time

The failure is structural rather than anyone’s fault. A manufacturer weighs a packed carton, because that is what the shipping line, the airline and the invoice need. A producer responsibility scheme wants the opposite number: the mass of the empty packaging, split by component and material, with the product taken out.

Nobody measures that until somebody asks. So the request goes out in January, the factory has to weigh sample blanks it no longer has in the same board grade, and a declaration due on 28 February in France or 1 April in the Netherlands is filed on an estimate that will not survive an audit.

The fix costs nothing and it is a paragraph in the request for quotation. What follows is the dataset, the measurement method, and the wording.

The dataset, field by field

The table lists every field a European scheme is likely to want, what unit it is in, and who can actually answer it. The last column matters: four of these fields are yours to decide, not your supplier’s, and asking a factory for them wastes a week.

Field	Unit or format	Why a scheme needs it	Who answers
Component list	Named items: carton blank, inner bag or liner, tape, label, stretch film, corner board, top sheet, pallet	Every scheme reports by component, not by pack	Supplier
Material per component	One of: paper or card, plastic, aluminium, steel, glass, wood, fibre-based composite, other	Contribution rates are set by material	Supplier
Weight per component	Kilogrammes. Germany’s LUCID register takes volumes in kilogrammes to three decimal places	The basis of every contribution calculation	Supplier, measured not estimated
Plastic sub-type	Rigid or flexible	Required by the UK scheme and useful for eco-modulation elsewhere	Supplier
Fibre-based composite test	Does the component combine paper or board with one or more plastic layers in a single unit that cannot be separated by hand, and do the plastic layers exceed 5 percent of the material by mass?	Above 5 percent it is a fibre-based composite; at 5 percent or below it is classed as paper or card	Supplier, from the board specification
Integrated components	Which material is predominant by weight	A component of mixed materials is reported under the predominant material	Supplier
Pieces per carton	Count	Converts your unit forecast into carton and pallet counts	Supplier
Cartons per pallet, pallet type	Count, and pallet standard and treatment	The pallet and its wrap are packaging and are frequently the larger share for a light product	Supplier
Brand names on the packaging	Exact text as printed	Germany’s LUCID registration has a brand name field; UK reporting turns on whose brand appears	Supplier confirms what is printed, you decide what it says
Supplier’s own EPR identification number	Where the supplier is itself a producer in that market	French law requires a seller to provide its unique EPR identification numbers on request, and a seller that is not a producer to obtain them from its supplier	Supplier, where applicable
Packaging class	Primary, secondary, tertiary or shipment	Determines how the packaging is categorised in reporting	You, because it depends on how you sell
Household or non-household	Classification	Drives the disposal cost in several schemes	You, because it depends on your channel
Recyclability assessment	Scheme-specific methodology	Feeds eco-modulation and design for recycling requirements	You or a specialist, not the factory
Destination market split	Kilogrammes by country	Each market has its own producer and its own return	You

That division is the point of the table. A supplier can tell you what the packaging is and what it weighs. A supplier cannot tell you how you sell it, and it should not be asked to.

How to ask for the weights so the numbers hold up

Send a method, not a request for a number. This one takes a factory about an hour and produces figures that survive a check.

Weigh empty, flat components. Ten carton blanks flat and unassembled, weighed together on a calibrated scale, divided by ten. The same for ten liners, ten labels and a measured length of tape and of stretch film.
Keep the components separate. The single most common error is one “carton weight” that silently includes or excludes the liner. Ask for one line per component.
State the board specification alongside the measured weight. Board grammage varies with humidity and between mill lots, so ask for the specified grammage and flute as well as the measured mass. If the two diverge materially, you want to know before an auditor does.
Ask for the pallet by type and measured weight. A heat treated timber pallet, a presswood pallet and a plastic pallet are three different materials and three different masses, and the choice sometimes changes between shipments.
Ask for a tolerance. A supplier who says a blank weighs a stated mass plus or minus a stated percentage is giving you something you can defend. One who gives a figure to three decimal places with no tolerance is guessing.
Re-request on any specification change. New board grade, new liner, new pallet supplier, new carton size: all of them change the return.

The same request also feeds your volumetrics, so send it once. Container level figures and how to read the answer are covered in asking a supplier for container loading data, and the structure that gets comparable answers from three suppliers at once is in the RFI to send three suppliers.

Put it in the RFQ, not in a chase email

Wording that works, adapted to your own template:

For each packaging component supplied with this product, state the component name, the material, and the weight of the empty component in kilogrammes, measured as the average of ten samples. List the carton blank, any inner bag or liner, tape, label, stretch film, corner boards, top sheet and pallet separately. State the pallet type and its weight. State pieces per carton and cartons per pallet. Where any component combines paper or board with plastic layers, state whether the plastic exceeds 5 percent of that component by mass. Notify us in writing of any change to these values before the affected shipment.

Asking at quotation stage rather than at order stage does two useful things. It tells you something about the supplier before you commit, because a manufacturer who can produce this within a few days has a specification discipline that shows up elsewhere. And it gives you the numbers while there is still time to change the packaging if a component is carrying an avoidable contribution.

The calendar you are feeding

The reason this is urgent rather than tidy is that the deadlines are fixed and they are earlier than most buyers expect.

Market	What is due	When
France	CITEO declaration of packaging placed on the French market in the previous calendar year	By 28 February
Sweden	Report to Naturvårdsverket of the information specified in the Swedish packaging ordinance	By 31 March
Netherlands	Annual aangifte to Verpact, signed and submitted	Before 1 April
Germany	Audited declaration of completeness, where a material threshold was crossed in the previous year	By 15 May
Germany	Year-end volume report in the LUCID register	Up to 1 June, after which it becomes a supplementary report
Denmark	Annual packaging report to Dansk Producentansvar; the register opens on 1 January and closes on 31 May	Window 1 January to 31 May
Ireland	Reporting on Repak’s scheme rules and membership terms	Confirm the current date with Repak

Read the German and French rows together. If your first French declaration is due on 28 February and your German declaration of completeness needs an auditor booked for 15 May, the supplier data request cannot sensibly happen in the same quarter as both. It belongs in the previous year, in the RFQ.

When the supplier cannot give you a number

Sometimes the honest answer from a factory is that a component has never been weighed separately, or that the pallet is bought locally and varies. That is recoverable, and pretending otherwise is what produces a bad return.

Weigh it yourself on receipt. Strip one carton on arrival, weigh each empty component on a calibrated scale, and record it against the shipment reference and the supplier’s specification. Ask the supplier to confirm the figures in writing so the number has a source behind it. Keep the record: Dutch policy requires packaging records to be kept for seven calendar years and organised so an inspection can follow how the administration works, and other schemes take a similar view.

The unhelpful but accurate point: no European scheme accepts “our supplier would not tell us” as a reason for an incomplete return. The obligation sits with whoever first places the packaging on that national market, which is set out in who registers for EPR when you import from India. If a supplier will not measure, either measure it yourself or change supplier, because the exposure does not travel back up the chain.

Frequently asked questions

Does the weight of the plates count toward my EPR return? No. Plates, bowls and cutlery are the product. Only the packaging counts: cartons, liners, tape, labels, film, corner boards, top sheets and pallets. A gross carton weight includes the product and is the wrong number.

How precise do the component weights have to be? Precise enough to survive an audit and consistent with your declared volumes. Germany’s LUCID register accepts volumes in kilogrammes to three decimal places, so the register will take a very precise figure. What matters more is that the figure has a documented measurement behind it and a stated tolerance.

Can I just use the supplier’s packing list weight? Not for an EPR return. A packing list gives gross and net weights for the loaded carton, which tells you the product weight, not the empty packaging weight split by component and material.

My supplier gave me one figure for the carton. Is that enough? No, unless the carton genuinely has no liner, tape or label. Schemes report by component and by material, so a single figure collapses paper and plastic into one line and cannot be split later without going back to the factory.

Who decides whether my packaging is household or non-household? You do. That classification depends on the channel you sell through and where the waste arises, which your supplier has no way of knowing. Do not ask the factory for it, and confirm it with the relevant scheme in writing where the channel is mixed.

Do I need my supplier’s own EPR registration number? In France, yes, if your supplier is itself a producer under a French scheme. Article L. 541-10-10 of the Code de l’environnement requires a seller that is not itself a producer to obtain the unique identification numbers from its supplier, and a buyer can ask for them at any time. Details are in CITEO registration and the Triman mark.

References

Packaging data: what to collect for extended producer responsibility. GOV.UK, on materials, component weights, plastic sub-types, the fibre-based composite test and packaging class.
Data reporting in the LUCID Packaging Register. Zentrale Stelle Verpackungsregister, on kilogrammes to three decimal places and the 1 June year-end volume report.
Packaging law: declaration of completeness. Zentrale Stelle Verpackungsregister, on the 15 May deadline.
My membership. CITEO, on the 28 February declaration deadline and declaration by material type and weight.
Beleid Afvalfonds Verpakkingen 2024, versie 3.1. Afvalfonds Verpakkingen, on the 1 April deadline and seven year record keeping.
Nya nationella bestämmelser till följd av EU-förordningen om förpackningar. Naturvårdsverket, on the 31 March reporting deadline.
Annual reporting 2026. Dansk Producentansvar, on the 1 January to 31 May packaging reporting window.
Everything you need to know about Unique Identification Numbers (UIN) in EPR schemes. ADEME, on articles L. 541-10-10 and L. 541-10-13 of the Code de l’environnement.

Supply into your market

Lane, documentation and destination rules for the markets this article applies to. Each page carries the route, the paperwork set and the quotation route for that destination.

Continue across the Foliware library

Each link below answers the question this article raises next, whether that is the rule behind a decision, the same question in another destination, or the commercial step that follows.

Next step

Send an enquiry naming the product, the annual volume, the destination and the SKU list to be reported: for example, the Reinforced Round Traditional Patravali Meal Plate in two sizes, 60,000 pieces a year, delivered to Rotterdam and Hamburg. Say which markets the return will be filed in, and the quotation comes back with a component level packaging schedule of material and measured weight in kilogrammes alongside the price, in the format the schemes ask for. See Germany , France , the Netherlands , Sweden , Denmark and Ireland , or send the RFQ .

Request a quotation

Start with a Trial Order 📦