The EAS EPR onboarding form asks you to state which packaging materials you use and how much each one weighs in an average EU order. This article explains what each material option covers, what counts as packaging, and how to work out the weights. Have it open alongside the form.
The material list in the form follows Annex II, Table 1 of Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation (PPWR). There are 22 categories in total. The form shows the six most common ones first, then the remaining sixteen in a second question, so most sellers only need the first list.
Product packaging and delivery packaging
The form asks about these separately, and asks for a weight for each material in both. The split matters, so work out which is which before you start weighing.
| Type | What it is | Examples |
|---|---|---|
|
Product packaging (sales or primary packaging) |
Everything that forms part of the product as the customer buys it, but is not the product itself. It stays with the item on the shelf or in the cupboard. | The glass bottle and its cap and pump, the carton the bottle sits in, the insert holding it in place, the plastic wrap around the carton, the label |
|
Delivery packaging (transport or e-commerce packaging) |
Everything you add in order to ship the order, and which the customer throws away on opening the parcel. | The shipping box or mailer bag, bubble wrap, air cushions, paper filling, tissue paper, tape, dividers, the shipping label |
If your warehouse, 3PL or manufacturer chooses and supplies the delivery packaging rather than you, say so in the form. We will help you work out who reports what.
What counts as packaging
Include the product's own container, not only the box it ships in. Nothing is too small to count: labels, tape, tissue paper, sachets, protective film, padding and dividers all count. If it reaches the customer and it is not the product itself, it is packaging.
Two rules to keep the numbers clean:
- Weigh everything empty. The weight of the product itself is never included.
- Weigh each material separately. A boxed candle in a glass jar with a cardboard sleeve gives you a glass weight and a paper or cardboard weight, not one combined figure.
How to work out the average weight
The form asks for grams per average EU order, so you need an average rather than a one-off measurement.
- Choose a long period. A full year is best, six months is the minimum. Shorter periods are distorted by seasonal peaks or a single bulk purchase.
- Count the orders you shipped in that period, to the EU and to other countries.
- For each material, work out how much of it you used in that period, for example from purchase invoices or stock records.
- Divide the total weight of that material by the total number of orders.
Packaging is normally bought for all markets at once, so divide by all of your orders, not only the EU ones. If your EU orders are packed differently from the rest, estimate the EU share separately.
If you do not have usage records, weigh a typical packed order on a kitchen scale that reads to one gram, dismantling it and weighing each material on its own. Your packaging supplier's specification sheets are another good source, as they usually state the weight per unit.
The six most common materials
These are the options in the first material question, for both product and delivery packaging. Most e-commerce sellers can answer the whole form from this list alone.
| Material option in the form | What it covers | Typical items in an order |
|---|---|---|
| Paper and cardboard | Plain paper and cardboard packaging: boxes, trays, grouped packaging and flexible paper such as sheets, pouches, wrappers, cones and lidding | Shipping cartons, product boxes, paper mailers, kraft paper filling, tissue paper, honeycomb wrap, paper tape, paper labels, cardboard dividers, care cards and leaflets |
| Composite packaging, mostly paper or cardboard | Paper or cardboard bonded to another material that cannot be pulled apart by hand, where paper is still the majority by weight | Paper mailers with a bubble or plastic lining, laminated or metallised gift boxes, window boxes with a plastic film, liquid packaging board, paper cups |
| PE flexible | Flexible polyethylene film, including multilayer film | Poly mailer bags, LDPE garment bags, clear product bags, air cushions and bubble wrap, pallet stretch film |
| Other flexible plastics, including multi-materials | Flexible plastic that is not plain PE, PP or PET film, including laminated multi-material film | Laminated pouches and sachets, blisters, thermoformed and vacuum packaging, plastic tape, plastic shipping labels and document wallets |
| PET rigid, bottles and flasks | Rigid PET in bottle or flask form only | Plastic drinks bottles, cosmetic and supplement bottles, refill flasks |
| Glass | Glass packaging, and composite packaging that is mostly glass | Bottles, jars, flacons, cosmetics pots, candle jars, ampoules, vials |
Not sure what something is made of? Ask your packaging supplier. Specification sheets, product pages and invoices normally name the material, for example PE, PP, PET or kraft board, and often give the weight per unit as well. Rigid plastic items usually carry a recycling triangle with the polymer code moulded into the base. If you still cannot work it out, contact us at support@easproject.com and we will go through it with you.
The other materials
The second material question covers the remaining sixteen categories. Use it if you sell in glass jars with metal lids, in tins, in aluminium tubes, in wooden boxes, or if you ship with polystyrene or foam protection.
| Material option in the form | What it covers | Typical items |
|---|---|---|
| Steel, including composite that is mostly steel | Rigid steel formats, including tinplate and stainless steel | Tins, aerosol cans, paint tins, biscuit and tea tins, steel lids and closures, drums, tubes, strapping |
| Aluminium rigid | Rigid aluminium formats | Drinks and food cans, aluminium bottles, aerosols, jars, screw caps, boxes and trays |
| Aluminium semi-rigid and flexible | Aluminium that bends or crushes | Squeezable tubes, foil trays and containers, foil lidding, foil wrap |
| PET rigid, other than bottles and flasks | Rigid PET in any other shape, single or multilayer | Pots, tubs, jars, cups, clamshells, trays, rigid containers, aerosol cans |
| PET flexible | PET film | Clear film windows, film wraps and sleeves |
| PE rigid | Rigid polyethylene, usually HDPE | Shampoo and detergent bottles, milk-style bottles, pots, tubes, trays, caps and closures |
| PP rigid | Rigid polypropylene | Cosmetic jars and pots, screw caps and flip tops, tubs, trays, tubes |
| PP flexible | Polypropylene film, including multilayer and multi-material | Crisp and snack film, clear BOPP bags and sleeves, film overwrap |
| HDPE and PP rigid, crates and pallets | Heavy-duty reusable transport items | Plastic crates, plastic pallets, corrugated plastic board |
| PS and XPS rigid | Polystyrene and extruded polystyrene, rigid | Yoghurt and dairy pots, trays, cups, rigid food containers |
| EPS rigid | Expanded polystyrene, the white foam type | Moulded foam inserts and end caps, fish boxes, protective corners, loose fill |
| Other rigid plastics, including multi-materials | Rigid plastics that are not PET, PE, PP, PS or EPS, for example PVC and PC | Rigid PVC cases and boxes, acrylic display packaging, intermediate bulk containers, drums |
| Biodegradable plastics | Rigid and flexible bioplastics such as PLA and PHB | Compostable mailer bags, PLA cups, trays and windows, starch-based loose fill |
| Wood and cork | Wooden packaging, including cork | Wooden gift boxes and crates, wood wool filling, pallets, cork stoppers and lids |
| Textile fibres, natural and synthetic | Textile used as packaging rather than as the product | Cotton dust bags, drawstring pouches, jute and canvas bags supplied with the item |
| Ceramics, porcelain stoneware, clay and stone | Fired or stone containers used as packaging | Stoneware pots, ceramic jars, bottles and containers |
Items made of more than one material
If the materials come apart by hand, split them and report each under its own category. A glass jar with a steel lid and a paper label is three entries: glass, steel, paper and cardboard.
If they cannot be separated by hand, the item is composite packaging and goes in one category, the one matching the material that makes up most of its weight. A paper mailer with a bonded bubble lining is composite paper or cardboard. A laminated foil and plastic pouch is other flexible plastics.
Anything that makes up no more than 5% of the item's weight is ignored, as are labels, varnishes, paints, inks, adhesives and lacquers. You do not need to account for the ink on a printed box or the glue on a label.
Frequently asked
- Does tape count? Yes. Paper tape goes under paper and cardboard, plastic tape under other flexible plastics.
- Do leaflets, cards and stickers count? Marketing inserts and thank-you cards are not packaging, but anything performing a packaging function, such as a label or a wrap band, is.
- What about a pallet on a wholesale shipment? Report it if you ship B2B or bulk into the EU. The form asks about wholesale shipments separately.
- What if a material varies between orders? Give the average across the period you chose. A material used in only one order in ten still contributes a tenth of its weight to the average.
- How exact do the weights have to be? The form asks how you arrived at them, from exact specifications through to reasonable estimates. Honest estimates are acceptable, and you can tell us you need help confirming them.
Related articles
- How to comply with packaging regulation (EPR) in Germany
- How to comply with packaging regulation (EPR) in France
- How to comply with packaging regulation (EPR) in Italy
- How to comply with packaging regulation (EPR) in Spain
The material categories come from Annex II, Table 1 of Regulation (EU) 2025/40, and the packaging definitions from Article 3 of the same regulation. The official text is on EUR-Lex. This article is practical guidance for completing the onboarding form, not legal advice.
If you are unsure how to categorise or weigh your packaging, contact us at support@easproject.com and we will go through it with you.