The 5 numbers to get from your packaging supplier before your next EPR filing

To submit accurate filings and prepare for EU Regulation 2025/40, you must obtain 5 specific numbers from your packaging supplier: weight per unit, material composition, recyclability grade, recycled content, and substance concentrations. Most critically, the total concentration of heavy metals must remain below 100 mg/kg under European Union product rules.

Key takeaways for e-commerce sellers

• Weight per unit: Grams per component to calculate weight-based fees.
• Material composition: Percentages of plastic, paper, metal, or glass.
• Recyclability grade: Classifications from Grade A to Grade C to verify market access.
• Recycled plastic content: Proof of post-consumer recycled plastic to meet statutory targets.
• Chemical concentrations: Verified concentration levels of heavy metals and per- and polyfluoroalkyl substances (PFAS).

Why your supplier holds the key to compliance

Under the new regulatory framework, compliance is moving upstream. The Packaging and Packaging Waste Regulation (PPWR), or EU Regulation 2025/40 on packaging and packaging waste, establishes direct legal duties for manufacturers, importers, and distributors who place packaging on the European market. If you are a brand owner or direct-to-consumer online seller, you may carry the legal obligations of a manufacturer. This means you must perform a conformity assessment, draw up technical documentation, and sign an EU Declaration of Conformity.

Because you cannot compile this technical file in isolation, you must collect packaging data for epr from your suppliers. Article 16 of the regulation establishes a clear legal obligation for packaging suppliers to provide you with all necessary information to demonstrate compliance. If you do not have these 5 numbers, you cannot file accurate Extended Producer Responsibility (EPR) reports, which directly affects how epr fees are calculated for your business.

Number 1: Weight per packaging unit

The net weight of each separate component of your packaging unit is the foundation of your compliance filings. EPR systems are built entirely on weight-based reporting. To submit an accurate declaration, you need the weight in grams of the main packaging body and any associated elements, such as caps, labels, and seals.

Furthermore, the weight of your packaging is essential for calculating your empty space ratio. Under the regulation, transport, grouped, and e-commerce packaging must limit empty space to a maximum of 50% from 1 January 2030, or three years after the Article 24(2) methodology act if that is later (reusable packaging is exempt). Gathering exact component weights from your supplier is the only way to prove you have minimised packaging weight and volume.

Number 2: Material composition and polymer type

You must know the exact material breakdown of your packaging. This means knowing the percentage of glass, paper, metal, or plastic in each component. Under the general classification rules in the European Commission's PPWR guidance, a packaging item belongs to a specific material family if it consists of at least 50% of that material by weight.

If your packaging contains plastic, you must identify the exact polymer type, such as polyethylene terephthalate (PET), polyethylene (PE), or polypropylene (PP). Different resins are sorted into distinct recycling streams. Knowing these percentages ensures you report under the correct categories of Table 1 of Annex II of the regulation.

Number 3: Recyclability grade

The regulation requires all packaging to be recyclable from 1 January 2030, or 24 months after the design-for-recycling delegated acts if that is later. Recyclability is not a binary yes or no statement. It is a spectrum defined by recyclability performance grades:

• Grade A: Recyclability rate of 95% or higher.
• Grade B: Recyclability rate of 80% or higher.
• Grade C: Recyclability rate of 70% or higher.

Any packaging with a recyclability rate below 70% is classified as technically non-recyclable and will be banned from the market. Furthermore, by 1 January 2038, only packaging with Grade A or Grade B will be permitted on the market. Asking your supplier for their verified recyclability rate or design certificate is the only way to guarantee your products remain compliant.

Number 4: Recycled plastic content percentage

If your packaging contains plastic, you must obtain the percentage of post-consumer recycled plastic content. The regulation sets binding targets for 2030, requiring plastic packaging to contain minimum percentages of recycled materials depending on contact-sensitivity. For example, contact-sensitive PET packaging must contain at least 30% recycled content by 2030 (rising to 50% by 2040), while other plastic packaging must reach at least 35% by 2030.

Holding these certificates also helps you navigate regional tax systems. For instance, the UK Plastic Packaging Tax applies to plastic packaging that does not contain at least 30% recycled content at £228.82 per tonne (from 1 April 2026); the rate is uprated annually, so check the current figure in HMRC's Plastic Packaging Tax guidance before you budget.

Number 5: Heavy metal and chemical concentrations

You must obtain written verification that your packaging complies with strict chemical limits. The sum of the concentrations of lead, cadmium, mercury, and hexavalent chromium in packaging components must not exceed 100 mg/kg under both EU Regulation 2025/40 (Article 5(4)) and the UK Packaging (Essential Requirements) Regulations 2015.

For food-contact packaging, the supplier must confirm compliance with the PFAS limits under Article 5(5) that have applied since 12 August 2026: below 25 ppb for any individual PFAS and below 250 ppb for the sum of targeted PFAS (polymeric PFAS excluded from both), and below 50 ppm for all PFAS including polymeric PFAS (total fluorine above 50 mg/kg is the screening trigger).

Under Article 15 of EU Regulation 2025/40, manufacturers are legally required to keep their technical documentation and EU Declaration of Conformity for at least 5 years for single-use packaging, and for at least 10 years for reusable packaging.

Avoid spreadsheet chaos. Rather than chasing suppliers manually and trying to decipher complex polymer codes, you can capture each packaging spec once. Get started with Gramta today to pair that packaging profile with your real sales volumes and turn it into clean, country-ready reports.

Sources:

• Regulation (EU) 2025/40 (PPWR) — recycled-content targets (Art. 7), substances of concern (Art. 5) and supplier information (Art. 16)
• European Commission guidance on the Packaging and Packaging Waste Regulation
• UK Packaging (Essential Requirements) Regulations 2015, reg. 5 — 100 ppm heavy-metal limit
• HMRC guidance on the UK Plastic Packaging Tax rate and 30% recycled-content threshold