Regulation and sustainability
Extended producer responsibility
What information has to be declared and where it comes from, without judging what applies to you.
Whoever places a product on the market is also responsible for what happens to it when it stops being used. In practice that means periodically declaring quantities and materials — and that declaration depends on data your suppliers hold.
Where each item in a declaration comes from
| Data | Who holds it | How to get it |
|---|---|---|
| Quantity placed on the market | You | From your sales system |
| Weight per packaging unit | Your supplier | Technical sheet, and it changes if packaging changes |
| Material and composition | Your supplier | Declaration, with its date |
| Recycled content, where applicable | Your supplier, sometimes with testing | Certificate |
Important
The last three rows are not yours, and they decide whether a declaration comes out right. Requesting them when the declaration is due is late: that is the moment you discover the supplier changed material eight months ago and nobody noted it.
What breaks a declaration
Watch out
Declaring with estimates presented as real figures is the costliest error, because it goes on record with your signature. If you do not hold a figure, the conversation is with your supplier and your adviser, not with the spreadsheet.
Frameworks cited
Extended producer responsibility and its reporting duties, collective compliance schemes and their declaration requirements, and packaging and waste rules. What you must declare, how often and to whom depends on your product and country: confirm with your adviser or your compliance scheme.
Worth knowing
Marking packaging data sheets for annual review and re-requesting them on supplier change is the only thing that stops next year's declaration being an investigation.
›What if the supplier will not give me the exact weight?
It is their technical sheet; if they lack it, that says something about that supplier.
›How often is it declared?
It depends on the regime applying to you; check.
›Is last year's sheet enough?
Only if the packaging has not changed, and you must be able to assert that.
A real case
The situation
A company prepares its annual declaration and finds two packaging items changed material.
What you do
- Requests the new sheets and marks all of them for annual review
What you get
Next year's declaration takes an afternoon instead of a three-week investigation.
The situation
The figure to declare sits in three different systems.
What you do
- Gathers it into one file through the year
What you get
The declaration is prepared without a campaign.
The situation
A supplier's figure is missing at the last moment.
What you do
- Requests it as it is generated
What you get
The deadline does not depend on somebody else's diary.
The situation
A figure is declared and no supporting evidence is kept.
What you do
- Stores the evidence with what was declared
What you get
The later review has something to answer with.
The situation
Nobody knows how last year's figure was calculated.
What you do
- Records the basis alongside the calculation
What you get
The figure is explicable years later.
The situation
Part of it is estimated without saying so.
What you do
- Declares which part is an estimate and on what basis
What you get
What is declared is defensible.
This article answers
- extended producer responsibility documentation
- declaring packaging placed on the market
- collective compliance scheme data
- epr what do i have to declare