Four blocks for each packaging item
Including why each question matters
The PPWR (Packaging and Packaging Waste Regulation) entered into force on 11 February 2025 and has been largely applicable since 12 August 2026; other obligations are being phased in. In practice, you are not expected to know everything, but you must be able to show what your decision was based on. Collecting more data does not achieve that; collecting the right data does.
Block 1 — Product identity
- Item or type number, manufacturer and, where applicable, importer. Without traceability, you cannot later link an assessment to a product.
- Product version and modification date. This is the most underestimated data point: a reformulated product is different from the product you assessed.
- Contact details for technical queries. Not your account manager, but the person responsible for the specification.
Block 2 — Material composition
- Weight and dimensions. The basis for every calculation involving material use and empty space.
- Every layer and component, including its proportion. For board: liners, fluting, coatings, inks and adhesive. For tape: backing, backing thickness, adhesive system, adhesive weight and release coating. For film: polymer, thickness and any multilayer structure. This lets you calculate kilograms — and without kilograms you cannot demonstrate a reduction.
- Anything not made from the main material. This list determines the recycling route.
Block 3 — Functional requirements
- What is this specification intended for? Load, stacking, moisture, temperature, closure method and machine. This explains why a particular grade is necessary — and therefore forms your supporting rationale.
- Performance data where available. For example, strength values or temperature range. Ask whether the figures are measured or indicative.
Block 4 — Claims and evidence
- What is the recycled-content percentage, and is it post-consumer? This is an important distinction that claims often omit.
- Against which unit is it measured? An annual average per site is different from a minimum per roll.
- What is a recyclability claim based on, and for which route? Do not ask: is it recyclable? Ask: on what basis do you say that?
If no answer arrives
That too is an outcome
Some suppliers will respond promptly and in full. Others will not, but that is no reason to stop. Record the question, the date and the absence of a response in the same file. This does three things: it demonstrates that you acted diligently, gives you a specific point for the next purchasing negotiation and reveals a pattern — if the same supplier fails to provide information three times, that tells you something about that supplier.
As regards your own position, the page on roles and responsibilities explains which checks you must carry out as a customer or distributor and which role applies. I do not assume your supplier’s responsibility — I help establish what is missing and which question to ask.
The file and decision log
One folder per packaging item, one line per decision
A file sounds more onerous than it is. In practice, it is one folder or one row per packaging item, containing the answers from the four blocks and the documents you received. It is not an end in itself; it is where you look when someone asks a question or something changes.
What is usually missing, and most valuable, is the decision log: one entry per decision, recording the date, who made it, which alternatives were considered and why this option was selected. Four lines of text. The difference is considerable, because without a log a deliberate decision cannot later be distinguished from chance. In an assessment, the issue is rarely whether you made the best choice, but whether you made a substantiated choice.
Align your categories with those you already use. The board grades used in the box calculator and the backing and adhesive types in the tape calculator provide practical classifications — avoiding the need to translate between two systems later.
When to reassess
Five events, not a fixed interval
An annual review sounds orderly but works poorly because changes do not follow the calendar year. It is better to agree on five events that trigger a reassessment:
- The composition changes. A different adhesive, coating or recycled-content percentage.
- The supplier changes. Even an “equivalent” product is a different product.
- The production site changes. This is relevant to origin, documentation and sometimes the role in the supply chain.
- The design changes. Different dimensions, a different closure or an additional label.
- The claim changes. A new or amended environmental claim requires new evidence.
Agree these five events with your suppliers so that they notify you rather than leaving you to discover the change. It takes one sentence in a purchasing agreement and saves most of the investigative work. The page on roles and responsibilities explains which of these events can also change your role; the timeline shows when each action is due.
Frequently asked questions about supplier data
Brief, specific answers in plain English
Product identity, including version and date; the complete material composition with weights; the functional requirements that explain the specification; and evidence for every claim you pass on. Those four elements are enough to explain a decision.
Record the question, the date and the absence of a response. That is an outcome in itself: it shows that you asked and provides a valid point for the next purchasing negotiation or when considering an alternative.
Not at a fixed interval, but when events occur: a changed composition, a different supplier or production site, an amended design or a new claim. Each of these partly invalidates your previous assessment.
No. I help you establish what information is available, where the gaps are and which questions to ask. The responsible economic operator remains responsible for its own obligations, and the manufacturer for its technical documentation.
Sources and scope
What this guidance is based on
- EUR-Lex — Regulation (EU) 2025/40 — the text of the Regulation. Opens in a new window.
- RVO — EU legislation: packaging requirements (PPWR) — Dutch government information on documentation and roles. Opens in a new window.
- Verpact — About the PPWR — registration and reporting in the Netherlands. Opens in a new window.
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