Before you can report your EPR data, you need to know what to count. The EU's legal definition of packaging is broader than most brands expect. Get it wrong and you'll under-report — which creates retroactive liability if you're ever audited.
Here's the definitive breakdown based on Regulation (EU) 2025/40 (PPWR), which applies from August 2026.
Under Article 3 of the PPWR, packaging is any item — regardless of material — used to contain, protect, handle, deliver, or present a product to a consumer or another business.
That covers three categories:
Sales packaging (primary): The packaging the consumer receives the product in — a cosmetics jar, a supplement bottle, the box a phone comes in, a bag of coffee.
Grouped packaging (secondary): Packaging used to group multiple sales units together — a cardboard tray holding 6 bottles, a shrink-wrap bundle, a multipacks box. This counts even if the consumer removes it at home or in the store.
Transport packaging (tertiary / e-commerce): Packaging used to protect products during shipping — your outer mailer box, polybag mailer, corrugated shipping carton. For e-commerce, this is called "e-commerce packaging" specifically in the PPWR.
All three types are in scope. All three generate EPR obligations.
Work through every item you use:
Outer e-commerce packaging
Filler and protective material
Product packaging
Sealing and identification
Inserts and extras
The PPWR is explicit about several exclusions:
Items integral to the product: A pump mechanism that is permanently fixed to a bottle and cannot be separated without destroying the product is not packaging — it's part of the product. However, a pump head that screws on and off counts as packaging (it could be removed and disposed of separately).
Non-packaging printed materials: Brochures, catalogues, receipts, instruction manuals, certificates of authenticity — none of these are packaging.
Paints, inks, and adhesives applied directly to a product: A brand's logo printed directly onto a glass bottle (not via a label) is not separate packaging.
Items weighing less than 5% of a composite packaging unit: If a small element (e.g. a tiny metal clasp on a gift box) represents under 5% of the total packaging unit's weight, it doesn't need to be reported separately.
This one catches food and beverage brands. Under PPWR Article 3, tea bags, coffee bags, and single-serve pods are treated as packaging — even though they're technically part of the product and get disposed of together with it.
This was a deliberate legislative choice. The Commission's logic: these items end up in compostable or recycling waste streams and contaminate them. So they're regulated as packaging even though they feel more like part of the food product.
If you sell single-serve coffee pods, tea bags, or similar beverage sachets, include them in your EPR reporting.
If you fill packaging at the point of sale — think subscription boxes assembled in your warehouse, gift sets put together per order, or food boxes packed to order — this is called "service packaging" under PPWR Article 3(1)(d).
It's in scope. The person filling the packaging at the point of assembly is the producer for EPR purposes.
EPR reporting is almost always weight-based — you report kilograms of each material type placed on the market, not units.
For each SKU, you need:
Weight × units sold = total kg of that packaging material placed on the market.
For your outer e-commerce box, don't forget that the customer only receives one, but the box contains the product. The full weight of every packaging component in that shipment counts.
Most EPR systems use these material categories for fee calculation:
If a packaging item is made of multiple materials (a cardboard box with a plastic window), you report each material fraction separately, weighted by its share of the total packaging weight.
Weigh everything. Get a postal scale and weigh every packaging component per SKU. Do it once, record it properly, update when you change suppliers or packaging specs.
Don't guess on composites. A cardboard mailer with a bubble lining is composite packaging. Estimate the cardboard weight and bubble wrap weight separately, or ask your supplier for a material breakdown.
Keep records. Most EU countries require you to retain packaging data for 3–5 years in case of audit. A spreadsheet with SKU, component, material, weight per unit, and units sold per country is sufficient.
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