It starts with one email. Then another from a different client six months later. Then three in the same week at the end of a quarter. The message is always roughly the same: "We need your packaging data for our EPR declaration — material type, weight per component, packaging level."
If you manufacture physical products or supply packaging materials to brands that sell in Europe, you have almost certainly received these requests. And if you have not yet, you will.
This article explains exactly where these requests come from, why the frequency is increasing, and what the pattern will look like over the next two years.
The short answer: EU law requires it
Your clients are not asking out of curiosity. They are legally obligated to declare the weight and material of every packaging component they put on the EU market — and that data ultimately comes from you.
Under EU packaging regulations (currently enforced through national Extended Producer Responsibility laws, and from August 2026 under the harmonized PPWR), any company that sells packaged goods in Europe must:
- Register with the Producer Responsibility Organization (PRO) in each EU country where they sell
- Declare the total weight of packaging they placed on the market, broken down by material: cardboard, plastic, glass, metal, etc.
- Pay fees to fund end-of-life recycling based on those quantities
To calculate their declaration, your clients need to know exactly what materials are in your packaging and how much each component weighs. If you manufacture the product or supply the packaging, that information lives with you. They cannot file accurately without it.
What data they actually need from you
The requests can feel vague — "packaging data" or "BOM information" — but the underlying requirements are quite specific. For each packaging component (the product box, inner packaging, outer carton, bags, labels, inserts), your clients need:
- Material type — cardboard, PET plastic, HDPE, glass, aluminium, etc. Not just "plastic" — polymer type matters for EPR fee calculation in most countries
- Weight in grams — the actual weight of the component as it leaves your facility
- Packaging level — primary (directly contains the product), secondary (groups multiple units), or tertiary (transport and logistics)
- Recycled content percentage — increasingly required under the PPWR and in countries like France where eco-modulation fees apply
This is what is commonly called a packaging Bill of Materials, or packaging BOM. One BOM per product. Each BOM lists all components with their material and weight.
Why the requests are coming more often
Three years ago, EPR compliance was mainly a German issue — LUCID registration was strict and well-enforced. Today, every major EU market has active enforcement. Here is what changed:
More countries are enforcing seriously
Germany (VerpackG / LUCID), France (CITEO), Spain (ECOEMBES), Austria (ARA), Belgium (Fost Plus), Italy (CONAI), the Netherlands (Afvalfonds), Portugal (SPV), and others all now have active EPR systems. Brands selling to EU customers have grown from managing one or two country registrations to five, six, or more.
Each additional country means another declaration, which means another request for your packaging data.
Marketplaces are requiring compliance documentation
Amazon already requires valid EPR registration numbers for sellers in Germany, France, Spain, and Austria. If your clients sell on Amazon without a valid registration, their listings get suppressed. This created a wave of EPR registrations — and registrations require packaging declarations — which require your data.
The PPWR harmonizes everything from August 2026
In August 2026, the EU's new Packaging and Packaging Waste Regulation (PPWR, EU 2025/40) enters into force. It replaces the patchwork of national directives with a single harmonized regulation that applies directly in all 27 member states.
This means any brand that was previously non-compliant in smaller markets (Poland, Czech Republic, Romania, Sweden) will suddenly face direct enforcement. More brands getting compliant means more brands needing packaging data — from you.
The number of packaging data requests you receive from clients will roughly double between now and mid-2027 as PPWR compliance rolls out across all 27 EU member states.
Why email and spreadsheets do not scale
Most suppliers currently handle these requests manually: search for the right spec sheet, copy the values into the client's template, send by email. Repeat each quarter. Repeat for each new client.
This creates several problems:
- Inconsistent data. Different clients receive slightly different numbers depending on which spec sheet you pulled that day. When packaging weights change, old clients have stale data.
- No audit trail. You have no record of what you sent, when, and to whom. If a client gets audited and traces the data back to you, you have no version-controlled history to refer to.
- Repeated work. The same data gets re-entered multiple times for multiple clients. Any change to packaging requires finding and updating every spreadsheet sent to every client.
- Growing volume. As outlined above, the number of clients asking for this data will increase significantly over the next 18 months.
What a better system looks like
The logical solution is to maintain your packaging BOMs in one place and share them on demand — rather than recreating data per client per request.
The basic model is:
- Enter each product's packaging once: components, materials, weights, recycled content
- When a client asks for data, send them a share link — they see a clean view of the BOM and can import it into their compliance tool directly
- When packaging changes, update the BOM with a new version. Previous shares stay linked to the correct historical version.
- Track which clients have received which data and whether they have imported it
This is exactly what the Pack Declare supplier portal provides — free for suppliers, designed specifically for this use case.
What to tell clients in the meantime
If you are currently receiving these requests and do not have a structured system yet, the most useful thing you can do is respond with a consistent data format. A simple spreadsheet with these columns covers what every EU country requires:
| Field | Example value | Notes |
|---|---|---|
| Component name | Outer carton | Plain description |
| Material type | Corrugated cardboard | Be specific — not just "paper" |
| Weight (g) | 185 | Per unit, not per pallet |
| Packaging level | Secondary | Primary / Secondary / Tertiary |
| Recycled content (%) | 30 | Required in FR, increasingly in others |
Send this for each product your client sells. Use a consistent format across all clients so the data work you do once benefits everyone.
The bottom line
These requests are not going away. The EU regulatory framework has reached the point where packaging data exchange between manufacturers and brand clients is a routine part of the supply chain relationship — the same way safety data sheets or quality certificates already are.
The brands that handle it poorly treat it as an interruption. The brands that handle it well have structured it like any other compliance data flow: once entered, always available, never re-entered.
For a deeper look at why this matters from the regulatory side, read EPR explained for manufacturers. For what the 2026 regulation specifically changes, see PPWR 2026: what manufacturers need to know.