Exactly What Packaging BOM Data Your Clients Need — and the Format They Expect

The email says "we need your packaging data for our EPR declaration." It does not say which fields, in which format, or how granular the information needs to be. Most suppliers end up sending whatever they have — a product spec sheet, a purchase order, a supplier certificate — and waiting to see if it is enough.

It usually is not. Clients come back asking for the weight of the corrugated outer separately from the inner box. Or they want polymer type, not just "plastic." Or they need it per unit, not per pallet.

This article defines exactly what a compliant packaging BOM contains, why each field is needed, and how to structure it so that every client can use it without asking follow-up questions.

Why the data format matters

Your clients are feeding your data directly into a calculation. They take the weight of each packaging component you provide, multiply it by the number of units sold to each EU country, aggregate by material type, and submit the totals to the national Producer Responsibility Organization (PRO). Their declaration is only correct if your data is correct and structured in a way their system can ingest.

Data that is too vague ("packaging: 200g, mixed materials") cannot be split by material type, which means the declaration is incomplete. Data provided at the wrong unit level (per pallet instead of per unit) produces wrong totals. Data missing the packaging level classification (primary / secondary / tertiary) cannot be assigned to the right fee category.

One well-structured BOM per product eliminates all of these issues and can be reused for every client who asks — regardless of which EU countries they sell to.

The required fields, explained

A packaging BOM is a list of components. Each component entry needs the following fields:

1. Component name

A plain-language description of the packaging component. This is for human readability — it helps your client match your data to their physical packaging and verify they have accounted for everything.

Good examples: "Outer shipping carton", "Inner folding box", "Tissue paper wrap", "Polybag liner", "Kraft paper void fill", "Adhesive label".

Avoid: "Box 1", "Packaging A", "Misc". Non-descriptive names create questions.

2. Material type

The material classification that matches EU EPR reporting categories. This is the most important field for fee calculation — different materials attract different EPR fee rates, and misclassification directly affects your client's declaration accuracy.

Use specific material categories rather than generic descriptions. See the full classification guide in how to classify packaging materials for EU EPR. In brief:

• Paper/cardboard: distinguish between corrugated cardboard, folding boxboard, kraft paper, tissue paper
• Plastics: specify polymer type — PET, HDPE, LDPE, PP, PS, PVC — not just "plastic"
• Glass: clear, coloured, or other
• Metal: aluminium or steel
• Wood: solid wood or engineered wood
• Composite: packaging made of multiple inseparable materials (e.g., laminated Tetra Pak-style cartons)

3. Weight per unit (grams)

The weight of the packaging component as it leaves your facility, per finished unit. Always per unit — not per case pack, not per pallet, not per master carton.

If the component is shared across multiple units (e.g., a corrugated shipper that holds 6 units), divide the component weight by the number of units it contains to arrive at the per-unit weight. A 240g shipper that holds 6 units contributes 40g per unit.

Use grams, not kilograms. Packaging components are typically in the range of single-digit to a few hundred grams per unit. Kilogram values invite decimal errors.

4. Packaging level

The packaging level determines which fee category applies in EPR declarations and how the component is treated under the PPWR.

• Primary packaging — directly contains or is in contact with the product. The packaging the end consumer holds in their hands: the product box, the bottle, the wrapper, the bag the product is sealed in.
• Secondary packaging — groups multiple primary units together. The outer carton that contains 6 individually boxed products. The gift box. The shrink wrap around a multipacks.
• Tertiary (transport) packaging — used for logistics and transport. Pallets, stretch wrap, pallet collars. Generally not relevant for most e-commerce product BOMs since transport packaging is shared across many orders and handled separately.

E-commerce shipping packaging (the mailer box or shipper sent directly to the consumer) is classified differently across national EPR systems — some treat it as primary, others as secondary. The PPWR introduces a harmonized "e-commerce packaging" category. For now, classify it as secondary unless your client specifies otherwise.

5. Recycled content percentage

The percentage of the component's weight that comes from recycled material. Currently required in France (for eco-modulation fee calculation through CITEO) and increasingly required across all EU markets under the PPWR.

If you do not have this information, record 0% rather than leaving it blank. A blank field is ambiguous. 0% is a definite statement your client can work with, and it is the conservative assumption if you genuinely do not know.

For more detail on how recycled content is defined and documented, see recycled content in packaging: how to document and declare it.

What a complete BOM looks like

Here is an example BOM for a cosmetics product: a 50ml face cream that ships in branded packaging inside an e-commerce mailer.

This BOM gives your client everything they need to calculate their EPR declaration for this product in any EU country. Total primary packaging: 118g (glass + aluminium + boxboard). Total secondary: 216g (tissue + mailer + kraft + label). Recycled content documented for each component.

Handling multi-SKU portfolios

If you supply multiple products to a client, each needs its own BOM. But many products share packaging components. A product line that uses the same mailer box across 20 SKUs — only the inner carton changes — does not require 20 separate component entries for the mailer box.

The practical approach is to maintain a component library with reusable entries, and build each BOM by assembling the relevant components. This means:

• Update once when a shared component changes (e.g., switching to a recycled-content mailer), and the change propagates to every product BOM that uses it
• New products are added by selecting existing components and specifying which are new
• Changes are version-controlled so clients can match the correct BOM version to their reporting period

What to do when you do not have all the data

Two common scenarios:

You do not know the exact weight

Weigh it. A simple kitchen scale accurate to 1 gram is sufficient. Weigh 5 units and average. For components supplied to you (e.g., a glass bottle you fill), request the weight specification from your packaging supplier — they should have it on the technical datasheet.

You do not know the material composition

For components you manufacture: you know what material you use. "Plastic" is not sufficient — identify the polymer. The recycling symbol number on the packaging tells you (1 = PET, 2 = HDPE, 3 = PVC, 4 = LDPE, 5 = PP, 6 = PS). For composites or laminates, list the dominant material and flag it as composite.

For components supplied to you: request a material datasheet from your supplier. This is the same due diligence required for substance restriction compliance (PFAS ban, REACH) — your suppliers should be able to provide it.

Versioning: when packaging changes

Packaging changes happen. New supplier, lighter box design, recycled content certification obtained. When they do, your BOM needs to reflect it — but previous clients cannot simply receive an updated file that silently replaces historical data.

The correct approach is to version the BOM with an effective date:

• Version 1: effective January 2025 – December 2025 (old packaging)
• Version 2: effective January 2026 – present (new packaging)

Clients filing a declaration for Q4 2025 need Version 1. Clients filing for Q1 2026 need Version 2. Both need to be available and clearly dated.

The Pack Declare supplier portal handles this with built-in version control — you add a new version, old shares keep pointing to the correct historical version automatically.

The one-time investment that saves recurring work

Filling out a complete BOM for each product in your range takes time upfront. For a portfolio of 50 SKUs with 5–8 components each, expect a half-day of structured data entry.

Once done: every client data request is answered by sharing a link. Every packaging change is updated once. Every new client starts with the same verified data. The same investment that used to generate one spreadsheet per client now covers an unlimited number of clients — this quarter and every quarter after.