EPR fees are not charged by weight alone — they are charged by weight and material type. A kilogram of aluminium packaging attracts a different fee than a kilogram of corrugated cardboard, which attracts a different fee than a kilogram of PET plastic. The fee rates vary by material and by country, but the material classification itself is the input that determines which fee category applies.
When you provide packaging BOM data to your clients, the material field is the most important one you fill in. A component classified as "plastic" instead of "PET" forces your client to guess — and any guess they make is potentially wrong, which makes their declaration inaccurate.
This guide covers the classification structure used across EU EPR systems, material by material, with the level of specificity each category requires.
How EU EPR systems categorize materials
All EU national EPR systems classify packaging materials into the same broad families, derived from the 1994 Packaging Directive and maintained under the PPWR:
- Paper and cardboard
- Plastics
- Glass
- Metals (aluminium and steel separately)
- Wood
- Other / Composite
Within each family, some countries require more granular subcategory data. Plastics require polymer type in most major markets. Paper and cardboard distinguish between corrugated board, folding boxboard, and flexible paper. The PPWR standardizes these subcategories EU-wide from August 2026.
Paper and cardboard
Paper and cardboard is the most common packaging material family and also the one with the most subcategory variation. The key distinction is between rigid/structural board and flexible/thin papers.
| Material | Common uses | Notes |
|---|---|---|
| Corrugated cardboard | Shipping boxes, e-commerce mailers, outer shippers | Single-wall, double-wall, or triple-wall — all classified as corrugated cardboard regardless of wall count |
| Folding boxboard (FBB) | Retail product boxes, cartons, pharmaceutical packaging | Solid bleached board (SBS), coated unbleached kraft (CUK), and folding boxboard are all in this category |
| Kraft paper | Bags, wrapping paper, void fill (crumpled kraft), envelopes | Uncoated kraft and recycled kraft are both classified here; clay-coated or PE-coated kraft may be classified as composite |
| Tissue paper | Wrapping tissue inside boxes, product protection | Lower grammage than kraft; some systems treat it separately from heavier paper grades |
| Moulded pulp / moulded fibre | Egg-carton style trays, protective inserts, wine glass separators | Classified as paper/cardboard despite three-dimensional form; material is cellulose fibre |
Common mistake: classifying corrugated shippers as "cardboard" without specifying corrugated. In countries like France, corrugated and non-corrugated board have different CITEO fee rates. Use the specific subcategory.
Plastics
Plastics require the most specificity of any material family. EPR fee rates vary by polymer type — and the PPWR's recyclability grades and recycled content targets are defined at the polymer level.
The standard classification is by resin identification code (the recycling triangle number you see on packaging):
| Resin code | Polymer | Common packaging uses |
|---|---|---|
| 1 — PET | Polyethylene terephthalate | Bottles (water, beverages, condiments), trays, clamshell containers |
| 2 — HDPE | High-density polyethylene | Rigid bottles (shampoo, cleaning products), drums, pipes |
| 3 — PVC | Polyvinyl chloride | Blister packs, clamshells, shrink labels; note: PVC is banned or restricted in some contexts under the PPWR |
| 4 — LDPE | Low-density polyethylene | Polybags, shrink wrap, bread bags, flexible film packaging |
| 5 — PP | Polypropylene | Caps and closures, yoghurt pots, deli containers, woven bags |
| 6 — PS | Polystyrene | Expanded (EPS) foam void fill, rigid clear windows in boxes (HIPS), compact disc cases |
| 7 — Other | Mixed or unlisted polymers (ABS, PC, nylon, etc.) | Use this only if genuinely unclassifiable; specify the actual polymer in a notes field where possible |
Critical detail — expanded polystyrene (EPS): EPS foam used as void fill or protective inserts is classified as plastic (PS), not as a separate material category. Its EPR fee rate is typically the same as other polystyrene.
Flexible film: LDPE polybags, PE shrink film, and PP overwrap are all plastics despite being flexible. They are not classified separately from rigid plastics for EPR purposes — the polymer type is what matters, not the rigidity.
Glass
Glass classification is straightforward. Most EPR systems treat glass as a single category, though some distinguish by colour (clear glass attracts lower fees in some systems because it has higher recycling value):
- Clear (colourless) glass — jars, bottles, vials
- Coloured glass — green, amber, or other coloured bottles and jars
Glass lids, stoppers, and decorative glass elements on packaging are included in the glass category.
Note on glass weight: Glass is significantly heavier than other packaging materials per unit. A 50ml perfume bottle can easily weigh 80–150g. Weigh actual samples — do not estimate.
Metals
Metal packaging is split between aluminium and steel (ferrous metal), because they have different recycling streams and different fee rates. Always specify which metal:
- Aluminium: cans (beverage, food), foil packaging, foil lidding, aluminium tubes (cosmetics, pharmaceuticals), aerosol cans (check — some are steel)
- Steel (tinplate, tin-free steel): food tins, paint cans, aerosol cans, steel drums, metal lids on glass jars
A quick test: aluminium is non-magnetic and lighter; steel is magnetic and heavier. The magnet test works reliably for most common packaging.
Wood
Wood packaging is primarily relevant for transport and tertiary packaging — pallets, wooden crates, fruit boxes. For product-level packaging, wood appears in:
- Wooden gift boxes or presentation boxes (solid wood or MDF/engineered wood)
- Wine crates, premium product boxes with wood elements
- Cork closures (typically classified with wood)
Wood is generally the lowest-fee category in most national EPR systems, but it still must be declared. MDF and engineered wood products are classified as wood.
Composite packaging
Composite packaging is made from two or more materials that cannot be separated by hand — meaning it cannot be fully recycled through a single stream. This is the most complex category.
Common composite packaging types:
- Aseptic cartons (Tetra Pak-style): typically 75% paperboard, 20% polyethylene, 5% aluminium foil — classified as composite with the dominant material noted
- Metallized films: plastic film with a thin aluminium layer (crisp bags, coffee pouches, mylar-type bags) — usually classified as plastic composite or as the dominant film material
- Laminated pouches: multiple plastic layers bonded together (stand-up pouches, retort pouches) — classified as plastic composite
- PE-coated cardboard: food-contact paperboard with a polyethylene coating — if the PE coating is inseparable from the board, this may be composite. Some systems classify it as cardboard if the PE is thin; others require composite.
How to classify composites: identify the dominant material by weight (the material that makes up the largest share), then flag the component as composite and list the secondary material. In your BOM, it is better to note "cardboard composite (PE coating)" than just "cardboard" — this avoids misclassification and gives your client the information they need to decide.
Materials that are not packaging
A few items commonly included in BOMs that should not be, or need clarification:
- Pallet stretch wrap: tertiary packaging. Include it if you supply it; your client should only count it once per shipment, not per unit.
- Cardboard printing inks: not declared separately. Standard inks on corrugated board or folding boxboard are not classified as a separate material.
- Adhesive tape: technically packaging material but typically negligible in weight. Some PROs include it in the main material (corrugated board + tape = all corrugated); others want it listed. If in doubt, include it with approximate weight.
- Rubber bands and twist ties: small quantities often ignored. Include if you can quantify them.
Putting it together in a BOM
For each product you supply, each packaging component gets one BOM row with:
- Component name (descriptive)
- Material type (from the categories above, as specific as possible)
- Weight in grams per unit
- Packaging level (primary / secondary / tertiary)
- Recycled content percentage
See exactly what packaging BOM data your clients need for the full field guide with examples. For recycled content specifically, see how to document recycled content for EPR declarations.