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.

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.

1. 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.
2. 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.
3. 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.
4. 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.
5. 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.
6. 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.

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

Related reading

• You or your supplier: who registers for EPR when you import from India
• Packaging EPR in Germany: LUCID, ZSVR and the steps before your first shipment
• Packaging EPR in the Netherlands: Afvalfonds registration and the reporting cycle
• The EU-specific documents a European buyer adds to a standard vendor pack

References