Primary, Secondary, Tertiary: Why Packaging Levels Matter for EPR

When you fill out your first EPR declaration, the form doesn't just ask "how much plastic did you use?" It asks: how much primary plastic, how much secondary plastic, how much tertiary plastic. The same breakdown for cardboard, metals, wood, and every other material category. If you've never thought about packaging in these terms, you're not alone. But getting the classification wrong means your declaration is inaccurate — and an inaccurate declaration is a compliance failure.

The three-level framework is not some arcane regulatory concept. It's the backbone of how every EU country structures its packaging reporting. Once you understand it, your declarations become straightforward. Misunderstand it, and you'll be correcting filings and answering auditor questions for months.

The three-level framework

EU packaging regulation — both the existing Packaging Directive (94/62/EC) and the new PPWR — classifies all packaging into three levels based on its function and where it ends up.

Primary packaging (sales packaging)

Primary packaging is the packaging in direct contact with the product. It's what the end consumer opens to access the product itself.

Examples:

• The glass jar that holds a candle
• The plastic bottle containing shampoo
• The foil pouch wrapping coffee beans
• The blister pack enclosing a phone case
• The polybag a t-shirt ships in
• The pump, cap, or lid on a bottle
• The label affixed directly to the product container

The defining test: does removing this packaging give you direct access to the product? If yes, it's primary. A pump cap on a lotion bottle is primary. A shrink sleeve label on a jar is primary. The desiccant packet inside a vitamin bottle is primary.

Secondary packaging (grouped packaging)

Secondary packaging groups multiple primary packages together or provides additional protection and presentation beyond what's strictly necessary to contain the product.

Examples:

• The cardboard box around a perfume bottle
• The six-pack ring around beverage cans
• The tissue paper wrapping a garment inside its polybag
• A cardboard sleeve around a set of soap bars
• The leaflet or product insert inside the box
• A foam insert that cushions a product inside its retail box

Secondary packaging reaches the end consumer but can be removed without affecting the product's integrity. The perfume works fine without the cardboard box. The soap bar doesn't need the sleeve. That's the line between primary and secondary.

Tertiary packaging (transport packaging)

Tertiary packaging is used exclusively for transport and logistics. It never reaches the end consumer.

Examples:

• Wooden or plastic pallets
• Stretch wrap securing boxes to a pallet
• Pallet corners and edge protectors
• Bulk shipping containers
• Strapping tape on a master carton

The key characteristic: tertiary packaging is removed and discarded in the supply chain — at the warehouse, the distribution center, or the retail backroom. It never enters a household.

The e-commerce exception: shipping packaging

Here's where it gets genuinely confusing for online sellers.

The corrugated mailer you ship to your customer's doorstep doesn't fit neatly into the classic three-level framework designed for retail. It's not primary — it doesn't touch the product directly. It's not tertiary — it goes straight to the consumer's home, not a warehouse loading dock.

Most PROs classify B2C shipping packaging as secondary packaging. But the exact treatment varies by country, and the terminology isn't always consistent.

Notice the inconsistency. Germany doesn't use the three-level classification for its declarations at all. The Netherlands skips levels entirely and just wants total weights. France uses "secondary" but adds a specific sub-category for mail-order packaging.

This is exactly why you can't just pick one classification and apply it everywhere. You need to know how each country's PRO expects shipping packaging to be reported. Some compliance tools handle this by letting you assign a "Shipping" level to e-commerce packaging components, then mapping that to each PRO's expected classification when generating declaration exports.

Why the classification matters financially

In some EU countries, EPR fee rates differ by packaging level. In others, the data feeds into national recycling target calculations even if the per-kilogram rate is identical across levels.

But even where the fee rates are the same across levels, accurate classification matters for audit purposes. An auditor reviewing your declaration will immediately question why 100% of your packaging weight is classified as primary with zero secondary. For an e-commerce brand shipping products in mailers, that's a red flag. Every shipment involves at least some secondary or shipping-level packaging.

Getting flagged in an audit doesn't just mean answering questions. It can trigger a full review of your historical declarations, corrections, back-payments, and in some countries penalties. The cost of re-doing two years of declarations far exceeds the effort of classifying correctly from the start.

Common classification mistakes

These are the errors that come up most frequently when e-commerce brands build their packaging data for EPR.

1. Classifying the shipping box as tertiary

This is the single most common mistake. In traditional retail supply chains, transport packaging is tertiary. But if you ship directly to a consumer's home, that box reaches a household. It becomes secondary packaging (or "system packaging" in Germany). Calling it tertiary will under-report your secondary packaging weight and over-report tertiary — an auditor will catch it.

2. Forgetting inner packaging materials

Tissue paper. Foam inserts. Product cards. Stickers. Desiccant packets. All of these are packaging components, and all of them need to be classified and weighed. Tissue paper wrapping a garment inside the shipping box is secondary packaging. A product information card is secondary packaging. If it ships with the product and gets discarded by the consumer, it counts.

3. Confusion about 3PL and pallet wrap

If your fulfillment provider palletizes your goods and wraps the pallet in stretch film, who declares that tertiary packaging? Typically the entity who first puts the packaging in circulation. If the 3PL uses its own pallet wrap to ship your goods from its warehouse to a carrier hub, that's generally the 3PL's obligation. But if you send pre-palletized goods to the 3PL, that pallet wrap is yours to declare.

Clarify this in your 3PL contract. Many brands simply ignore logistics packaging and nobody complains — until an audit.

4. Gift wrapping

If you offer gift wrapping as an option at checkout, that's additional secondary packaging. The gift wrap paper, the ribbon, the gift box — all of it adds to your declared packaging weight. If 10% of your orders are gift-wrapped and each gift wrap adds 45g of paper, that's material weight you need to capture. Track gift wrap as a separate packaging component and apply it only to orders where it was selected.

5. Multi-material packaging confusion

The classification is about the individual component, not the product. A skincare product might ship with a glass jar (primary), inside a cardboard unit box (secondary), wrapped in plastic shrink (secondary), inside a corrugated mailer (shipping/secondary). That's four separate components at two packaging levels. Each component gets its own material classification and weight. You don't declare "one package weighing 380g" — you declare 200g glass primary, 85g cardboard secondary, 10g plastic secondary, 85g cardboard shipping/secondary.

Practical examples

Here's how packaging level classification works for two typical e-commerce products. These are the kinds of breakdowns you need in your Bills of Materials (BOMs).

Example 1: Skincare product

Total per unit: 138g primary (120g glass, 15g plastic, 3g paper), 263g secondary (258g paper/cardboard, 5g plastic). That distinction matters for every declaration you file.

Example 2: T-shirt

Total per unit: 8g primary (plastic), 71g secondary (49g paper/cardboard, 22g plastic). A seemingly simple product, but six distinct packaging components across two levels and three materials.

Now multiply these by your order volume per country per quarter. If you sold 3,000 t-shirts to France in Q1, you're declaring 24 kg of primary plastic, 147 kg of secondary paper/cardboard, and 66 kg of secondary plastic to CITEO. Every misclassified gram scales up across thousands of orders.

How to handle levels in your compliance process

The most important advice: assign packaging levels when you create your BOMs, not when the declaration is due.

If you wait until declaration time to classify, you'll rush. You'll batch everything as "secondary" because you can't remember which components touch the product directly. You'll skip the tissue paper because it seems negligible. Those shortcuts compound into inaccurate declarations.

Instead, treat the packaging level as a fixed property of each component in your BOM. When you create a BOM for a product, each line item gets three attributes:

• Material type — cardboard, plastic (PET, HDPE, LDPE, PP), glass, metal, paper, wood
• Weight in grams — weighed on a scale, not estimated
• Packaging level — primary, secondary, shipping, or tertiary

Once this is done correctly, the declaration calculation becomes mechanical. Multiply the component weight by the number of units shipped to each country. Aggregate by material and level. Export. Done. No guesswork at filing time.

What about products with variable packaging?

Some products ship in different packaging depending on the order. A single-item order might go in a poly mailer; a multi-item order goes in a box with void fill. Handle this by creating separate BOMs or by using a "shared shipping" BOM that represents your average shipping packaging per order. Neither approach is perfect, but picking one and applying it consistently beats ignoring the problem.

Handling shared shipping packaging across products

If three products ship in one box, the shipping packaging weight needs to be allocated. There are two common approaches: divide equally across all items in the order, or allocate by the number of SKUs. Most PROs accept either method as long as you apply it consistently and the total weight declared for the country is accurate.

Level classification and the PPWR

The new Packaging and Packaging Waste Regulation doesn't eliminate the three-level framework. It reinforces it. The PPWR explicitly defines primary, secondary, and tertiary packaging and adds specific provisions for e-commerce packaging, recognizing that the old definitions didn't account for B2C shipping.

Under the PPWR, e-commerce packaging gets explicit recognition as a packaging category. This should, over time, reduce the inconsistencies in how different PROs classify shipping mailers. But "over time" means national PROs will adapt at different speeds. For the next few years, you still need to know how each country's PRO handles it.

A classification checklist

For every packaging component in your product line, ask yourself:

• Does it directly contain or touch the product? → Primary
• Does it group, protect, or present the product but could be removed without exposing the product? → Secondary
• Is it used only for shipping to the consumer's home? → Shipping / Secondary (check your PRO's classification)
• Is it used only for B2B transport and never reaches a household? → Tertiary

If you're unsure about a component, err on the side of classifying it as secondary. Under-reporting secondary packaging is the most common audit finding. Over-reporting it is rarely questioned.

Pack Declare handles packaging level classification per component in your BOMs and maps each level to the correct PRO format automatically when generating declaration packs. You classify once; the export handles the country-specific mapping.

Start by reading the BOM guide to structure your packaging data correctly. Then review the country-specific guides for Spain, France, and Germany to understand each PRO's expectations for level classification in their declarations.