EPR Packaging Report: Report Quantities on Time and with Supporting Documentation

The EPR report on packaging aggregates all quantities that a manufacturer places on the market for the first time in a member state, broken down by material type and reporting period. For purchasing, product management, and the supply chain, it is therefore less of a form-filling task and more of a data process: Accurate reporting is only possible for those who understand the packaging structure, mass, market, and the manufacturer’s responsibilities at the packaging level.

The EU Packaging Regulation (PPWR) has been in effect since August 12, 2026. However, the harmonized national manufacturer registries provided for in the regulation are not yet available. Until they are established, the national registration, system participation, and reporting procedures will continue to apply. This article explains how companies can systematically collect their packaging data, evaluate it on a country-by-country basis, and document it in a manner that stands up to audit scrutiny.

As of September 2026. This is based on Regulation (EU) 2025/40 on packaging and packaging waste, effective as of August 12, 2026, as well as the Packaging Law Implementation Act (VerpackDG), which the Bundestag passed on June 11, 2026 (Bundestag Printed Paper 21/5346).

EPR Reporting for Packaging: National Requirements, Common Data Set

Companies currently need to reconcile two levels: The PPWR defines the future European framework, while registration and reporting of quantities continue to be handled through the existing national systems. In operational terms, this means that data should be managed centrally but be able to be analyzed separately by member state, material type, packaging level, and time period.

Article 44 of Regulation (EU) 2025/40 requires Member States to establish national manufacturer registries in accordance with harmonized requirements. The 18-month implementation period does not begin until the European Commission’s implementing act for this purpose enters into force. Since this implementing act has not yet been adopted, the second set of PWPR FAQs sets June 1, 2030, as the operational start date for the national EPR registries in accordance with the harmonized rules.

In Germany, therefore, the Central Packaging Register remains the designated recipient. According to Section 9 of the Packaging Act (VerpackDG), the information to be submitted includes, among other things, the registration number, material type, weight of packaging subject to system participation, participation period, and system name. Consequently, companies do not need a separate dataset for each report, but rather a centralized packaging inventory with country-specific analyses.

IMPORTANT CLARIFICATION: The PPWR does not postpone the reporting obligation; it standardizes it. Until the registry is established in accordance with Article 44 of Regulation (EU) 2025/40, the national reporting and system participation obligations remain fully in effect. There is no interruption in the reporting cycle. Anyone who fails to report for 2026 cannot cite the pending harmonization as a justification.

Step 1: Enter packaging data at the product level

Reliable EPR quantity reporting begins with the product master. Purchasing, master data management, and packaging development record each packaging component, including material, weight, and packaging level. This creates a packaging inventory that also serves as the basis for quantity reports, license billing, and technical PPWR documentation. Flat-rate average values should only be used as a clearly identified interim solution.

• Material type by component: Glass, paper, cardboard, plastic, metals, wood, and composite materials are tracked separately. This is the only way to correctly assign them to national reporting categories and participation fees.
• Mass per component: The weight of each individual packaging component per sales unit is recorded. The reported total mass is then calculated based on the packaging weight and the actual number of units provided.
• Packaging level: Retail, secondary, and transport packaging are labeled separately, as take-back, system participation, and reporting requirements may vary.
• Country of first placing on the market: For each product, it must be possible to determine in which Member State the packaging or the packaged product is first placed on the market.
• Provision Period: Quantities must be assigned to a unique reporting and system participation period. This facilitates correction reports and reconciliation with billing data.
• EPR Role: For each market and distribution structure, documentation is provided specifying which company is considered the manufacturer for the purposes of extended producer responsibility.

These six data fields form the core of EPR compliance. If they are fully maintained, the volume report becomes a tool for controlled analysis rather than a recurring data search. The PPWR role check helps classify the manufacturer’s role for each distribution scenario.

Step 2: Clarify the role and registration requirements for each member state

Before submitting any volume report, it is necessary to determine which company in the respective member state is subject to registration. The decisive factor is the definition of the manufacturer under the PPWR, which depends on the specific supply chain and the country where the packaging or packaged product is first made available. The Legal, Sales, and Purchasing departments, along with the relevant local subsidiary, should jointly document this classification.

In general, the determination of the manufacturer’s role depends on whether the packaging is first made available in an EU member state. However, there is a distinction here: for the market where the company is headquartered, the initial supply is generally decisive, whereas in other EU member states, only the initial supply to end users is decisive. In addition, a company has producer responsibilities if it unpacks packaged products without being the end user. In Germany, registration with the Central Packaging Register is required prior to the first supply. For other member states, the respective local registries and procedures apply. If there is no branch office in the destination country, a written designation of an authorized representative may also be required for extended producer responsibility. Without valid registration, the relevant quantity may not be properly reported or made available.

Step 3: Report quantities to the system and registry by the deadline

In Germany, relevant quantities are reported both to the participating system and to the Central Packaging Register. The content of both reports must match. Therefore, personnel responsible for master data management and finance should use the same approved report and document each submission with a timestamp, data status, and the person responsible.

Announcement	Deadline	Basis
Data Submission to the Central Packaging Registry	immediately upon joining the system and whenever there is a change	§ 9 of the Packaging Act
Reporting for amounts less than 10 metric tons per calendar year	through June 1 of the following year	§ 9 of the Packaging Act
Declaration of Completeness	through May 15 of the following year	§ 10 of the Packaging Act
Notification to the Future EU Manufacturer Registry	through June 1 of the following year	Article 44 of Regulation (EU) 2025/40

The declaration of completeness is required only if at least one of the material-specific thresholds specified in § 10 of the Packaging Act (VerpackDG) is exceeded. The determining factor is not the total amount of all packaging, but rather the respective mass per material type in the preceding calendar year.

Material Type	Threshold per calendar year
Glass	≥ 80 metric tons
Paper, Cardboard, and Paperboard	≥ 50 metric tons
Other Types of Materials	≥ 30 metric tons

The 10-metric-ton threshold in Article 44 of Regulation (EU) 2025/40 serves a different purpose. It affects the scope of the information that must be submitted to the PPWR manufacturer registry in the future. It does not generally eliminate national registration and reporting requirements.

Step 4: Document the audit trail and supporting evidence

A reliable report must be traceable from the reported total amount down to each individual packaging component. Quality management and finance should therefore link supplier documentation, weighing logs, master data changes, sales volumes, and submitted reporting files. The result is a consistent audit trail rather than an unstructured collection of files.

If a declaration of completeness is required, registered experts, auditors, tax advisors, or certified public accountants review not only the final total but, above all, how it was derived. Versioned master data, documented conversion logic, and approved corrections reduce the need for follow-up inquiries and prevent discrepancies between the system contract and the registry filing.

The technical documentation and the PPWR Declaration of Conformity pertain to the same articles but follow a different verification logic. Companies should therefore use shared basic data but manage the regulatory verification processes separately. This ensures that material and weight data are collected only once, without mixing reporting and conformity processes.

Automating EPR Quantity Reports Effectively

Recurring processing steps are particularly suitable for automation: linking sales volumes to package weights, aggregating quantities by country and material, monitoring thresholds, triggering deadlines, and detecting discrepancies between system and register reports. A prerequisite is a well-maintained product master with unique units, versions, and validity periods.

Expert judgment is still required. This includes determining the EPR role in complex supply chains, classifying individual packaging levels, and providing final approval of the report. Software can parse documents, apply validation rules, and flag anomalies. However, it does not replace the legal assessment of contracts and distribution models.

The Most Common Errors in EPR Volume Reporting

Most errors occur because companies treat the report as an annual form rather than an ongoing data process. The following points should therefore be checked before each submission:

• Packaging weights are estimated based on purchase or invoice values. As a result, changes to packaging components go unnoticed, and the reported weight differs from the actual packaging volume.
• Information on materials and weight is stored exclusively with the supplier. In the event of a change in supplier, multiple sources of supply, or a change in specifications, the correct packaging can no longer be unambiguously assigned to the item.
• Cross-border shipments are only taken into account in the German report. In fact, the destination country may have its own registration, authorization, and reporting requirements.
• A required authorized representative is appointed only after market entry. Consequently, the necessary representation in the respective member state is lacking at the time of initial provision.
• Transport packaging is generally excluded. Its legal treatment depends on the specific distribution channel, the function of the packaging, and the national take-back or reporting system.

Changes are compiled until the annual report is submitted. In Germany, Section 9 of the Packaging Act (VerpackDG) requires immediate data reporting upon joining the system and in the event of changes. A subsequent annual analysis does not replace this obligation.

Frequently Asked Questions About EPR Reporting for Packaging

The following answers address the most important practical questions regarding volume thresholds, foreign registration, the PPWR registry, and audits.

At what quantity do I need to report packaging?

The reporting requirement generally takes effect with the first relevant quantity of packaging. Quantity thresholds may affect the scope of the information required or trigger an additional verification requirement, but they do not replace the verification of registration and participation in the system in the respective Member State.

Do I need to register separately in every EU country?

In general, registration must be verified in every Member State where a company first makes packaging or packaged products available. Until the harmonized PPWR registers are established, the respective national registers, definitions, and procedures apply. A German LUCID registration does not cover other Member States.

Does the PPWR replace the report to the central office?

No. Until the harmonized registration system under Article 44 of Regulation (EU) 2025/40 is fully operational, the national reporting channels will remain in effect. In Germany, registration and data reporting will continue to be handled by the Central Packaging Register.

Does the reported quantity need to be verified?

In Germany, an external audit is required if the material-related thresholds for the declaration of completeness under Section 10 of the Packaging Act (VerpackDG) are exceeded. Below these thresholds, the regular data reporting requirement remains in effect. Regardless of this, every report should be subject to an internal plausibility check and fully documented.

Centrally Manage Packaging Quantities with CONSUST

Reliable EPR reporting for packaging starts with consistent packaging data. CONSUST’s PPWR software consolidates packaging components, materials, weights, countries, and roles into a central database. Decision logic supports role clarification, tasks and deadlines are managed in a traceable manner, and supplier documents can be analyzed using AI. For more advanced EPR functions, such as country-specific analyses or pre-prepared volume reports, please feel free to contact us directly.

The PPWR Guide describes the process from defining roles through data collection to market approval. In a demo, we’ll show you how to apply the process to your own product line and relevant sales markets.

This article presents a professional assessment based on the cited sources as of the date indicated and is not a substitute for a legal review in individual cases.