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Collecting EPR and PPWR data: how the data models work

Which packaging data you need to collect from suppliers depends on your role as distributor, importer/manufacturer or private label.

Written by Andreas Stensig

Recommendation: We recommend using the PPWR module to create and map the fields. That way you can use many of the standard fields directly.

Your role determines the data model

Which packaging data you need to collect from your suppliers depends on your role – and therefore on who must issue the Declaration of Conformity (DoC). The more of the responsibility you carry yourself, the more documentation you need to collect.

Role

Who issues the DoC?

What is collected?

Distributor

Your supplier

Basic data + the supplier's DoC

Importer / manufacturer

You

Basic data + all documentation behind a DoC

Private label

Often the supplier

Basic data + the supplier's DoC

Regardless of role, you always collect material (per packaging material), weight and a supplier ID on the packaging.

Data model for distributors

As a distributor, there is a party before you in the chain who issues the DoC. That is why this model is simple.

Field

What the supplier provides

Note

Material

The material of the packaging

Per packaging material

Weight

The weight of the packaging

Supplier ID

ID of the packaging supplier

DoC from the supplier

The supplier's Declaration of Conformity

The core document for distributors

PFAS / Chemical Statement

PFAS declaration

Optional – may be included in or referenced by the DoC

Supplier note

Additional evidence supporting the DoC

Optional

Data model for importers and manufacturers

As an importer or manufacturer, you issue the DoC yourself, so you need to collect the documentation behind it.

Field

What the supplier provides

Note

Material

The material of each packaging component

Weight

The weight of the packaging

Supplier ID

ID of the packaging supplier

Control production

Information on production control

Material Declaration

Declaration of composition

May also cover PFAS

PFAS / Chemicals Compliance Statement

PFAS declaration

If not included in the Material Declaration

Substance Test Report

Test report for substances

Supports the declarations

Test report

Other test reports

Supplier note

Additional evidence

Optional

Resin identification code

The polymer type

Plastic packaging only

DoC from the supplier

The supplier's own DoC

Only if the supplier takes responsibility (see next section)

Each of the four document fields is optional on its own: some suppliers combine everything in one document, others split it up. What matters is that the documentation as a whole is sufficient.

Private label: when the supplier takes responsibility

If you sell packaging under your own brand, you are the manufacturer – but the supplier may well have taken on the responsibility. Many suppliers produce the same item for many companies, each with their own logo. Instead of sending a technical file to every customer, they issue one DoC and vouch for the item's compliance.

In that case, the supplier's DoC is sufficient, and you do not need to collect the full technical documentation.

Setup

Suits

Data models

Combined

Supplier responsibility is roughly the same across suppliers

Distributor + Importer/manufacturer

Split

Supplier responsibility varies a lot

Distributor + Importer/manufacturer + Private label

We can help you choose the setup that fits your supplier base.

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