What auditors look for is not “more rows” in a spreadsheet. They look for a dataset that can explain itself under pressure.
If you sell packaged goods across Europe, your reporting will eventually be challenged in one of three ways:
– A PRO requests evidence because your reported volumes look unusual versus peers.
– An authority audit asks you to justify a country total.
– An internal finance or sustainability review asks why fees moved year on year.
When that happens, the discussion stops being about “did you submit” and becomes:
– Show me the trail from the reported kilogram back to the physical packaging.
– Show me the method, not just the output.
– Show me that the method still holds after packaging changes and supplier changes.
That is exactly why a per-SKU packaging dataset needs a minimum set of fields that create traceability and repeatability.
Below is the expert view of the seven fields that make packaging data audit-grade, with an explanation of what each field solves, what can go wrong, and how to operationalise it.
Before the 7 fields: the mental model you need
A good packaging dataset separates three things that companies often mix up:
– What the product is (SKU master data).
– What packaging exists for that product (packaging BOM).
– Where that packaging becomes waste and who is responsible (country attribution logic).
If you try to solve all three in a single “country totals” sheet, you lose the ability to prove your numbers.
The seven fields below sit in the packaging BOM layer, but they also connect cleanly into country attribution and reporting.
1. SKU plus Packaging Configuration ID
Most teams store packaging against a SKU only. That works only in a perfect world where one SKU always ships the same way.
Real life is different:
– A SKU shipped B2C is usually packed differently than the same SKU shipped to a distributor.
– A 3PL may use different cartons, void fill, and tape than your own warehouse.
– Marketplaces can introduce additional packaging layers.
– Even within your own network, different fulfilment centres use different packaging standards.
This is why audits often uncover inconsistencies. The reported weight per unit looks too high or too low because someone assumed one “default packaging” for every shipment.
So the field you actually need is:
– SKU identifier.
– Packaging Configuration ID.
– A trigger rule for when that configuration applies.
A practical configuration ID is not fancy. It can simply encode the packaging reality, such as:
– SKU A123 – B2C – FC1.
– SKU A123 – B2B – case pack 12.
– SKU A123 – Marketplace – Amazon FBA.
– SKU A123 – 3PL – DE hub.
What does this enable in an audit?
When someone asks, “Why is packaging weight in Germany higher than France for the same SKU?”, you can answer: because Germany shipments use a different configuration due to a different fulfilment route or case pack.
Common failure mode.
Companies build one BOM per SKU and then try to patch exceptions later. That creates hidden underreporting and inconsistent year-on-year results.
2. Component list and packaging level
A “packaging type total” is not defensible. Auditors want to see that you understand what physically exists.
The only credible structure is component-level packaging. That means you explicitly list the parts of packaging that actually become waste:
– Outer shipping carton.
– Inner retail box.
– Inserts or dividers.
– Void fill.
– Wrapping film.
– Labels and leaflets.
– Tape.
– Strapping.
– Pallet and corner boards (when relevant).
And you tag each component with packaging level:
– Primary (consumer unit packaging).
– Secondary (grouping or shelf-ready).
– Tertiary (transport packaging).
Why does the packaging level matter?
Even where countries report simply by material, audits still test your understanding. Packaging levels correlate strongly with typical material compositions and weight ranges.
In practice, packaging level is also essential for:
– Designing a data request to suppliers and 3PLs.
– Separating “product packaging” from “distribution packaging.”
– Modelling reuse and circulation items correctly.
What does this enable in an audit?
If asked, “Where does your plastic come from?”, you can show it is mainly film and tape, not the consumer box. That kind of clarity quickly builds credibility.
Common failure mode.
Companies track only obvious pieces like cartons and ignore tape, labels, protective films, and inserts. Individually small, but collectively meaningful—and frequently challenged when totals look low.
3. Standardised material classification aligned to EPR taxonomies
Packaging descriptions are unreliable. Procurement text is inconsistent. Supplier naming conventions vary widely.
So your BOM must use a controlled material taxonomy that maps to reporting categories. This means you classify components by what they are, not what someone called them.
For example:
– “Poly bag” is not a material category. It must become plastic, and ideally the polymer (e.g., LDPE or HDPE).
– “Paper wrap” may be paper, but if it is coated, it could be composite.
– “Padded envelope” is not “paper” just because the outside is paper.
Why does this matter?
Audits often focus on misclassification, not missing volume, because misclassification affects fees—sometimes drastically.
Practical approach.
Keep two fields:
– Supplier descriptor (raw input).
– Compliance material category (your standard output).
This makes the dataset robust while preserving traceability to source data.
Common failure mode.
Using “mixed packaging” as a dumping ground. That increases fees, reduces control, and triggers scrutiny because it signals weak material discipline.
4. Net weight per component per unit in grams
This is the core of audit defensibility.
The weight must be attached to the component and to the unit basis. Otherwise, your dataset cannot be replayed.
Key rule.
Store weights in grams per component per sales unit, and clearly define the basis:
– Per 1 consumer unit shipped.
– Per 1 case pack of 12.
– Per 1 pallet layer.
– Per shipment package.
Why do auditors care about basis?
Because misinterpreting basis creates massive errors.
Example.
If the carton weight is recorded per “case of 24” but treated as “per unit,” your reported paper weight is inflated by 24 times.
How do you make this robust?
Capture:
– Weight value.
– Unit basis.
– Measurement method.
– Validation date.
Common failure mode.
Using shipping weight, volumetric weight, or invoice weight as a proxy for packaging. Those weights include product and vary with logistics, and are not acceptable as packaging evidence.
5. Composite flag plus material split lines by weight
Composites are where auditors press hardest because companies guess.
Examples that cause trouble:
– Laminated pouches (plastic + aluminium).
– Paper boxes with plastic windows.
– Padded envelopes (paper + plastic).
– Coated papers and barrier films.
– Multi-layer foils.
A composite must be handled as:
– One component.
– With multiple material lines that sum to 100 percent.
– With each line carrying a weight share or explicit grams.
And the dataset must capture the method used to derive the split:
– Supplier declaration.
– Teardown and weighing.
– Lab test.
– Engineering drawing.
– Standard ratio methodology.
Why is “dominant material” risky?
It is a cost-saving shortcut. But if challenged, you have nothing defensible to show. Composites can materially shift plastic totals, which are commonly reviewed.
Common failure mode.
Classifying padded mailers as paper or plastic based on appearance. This is a classic audit finding in e-commerce.
6. Reuse status and return logic evidence
Reusable transport packaging is both an opportunity and a risk.
It is an opportunity because reuse can reduce reported placed-on-market quantities depending on the regime and how reuse is treated. It is a risk because reuse claims without evidence are often rejected.
So you need to capture more than “reusable: yes.”
You must capture the reuse model and proof:
– Is it returnable to you or to a manufacturer?
– Is it pooled (CHEP type)?
– Does it circulate cross-border?
– Who is responsible for losses?
– What is the actual return rate?
– What evidence exists (contracts, SOPs, return records, circulation logs)?
What do auditors test?
They usually do not debate the concept of reuse. They test whether you can show it operates in practice.
Common failure mode.
Excluding pallets or shells from the BOM entirely and still claiming “returnable.” That removes the ability to prove reuse at all.
7. Data provenance and change control metadata
This is what makes a dataset survive a 12-month time gap.
Packaging changes constantly:
– Supplier change.
– Redesign.
– Downgauged films.
– Box resizing.
– Removal of inserts.
– New fulfilment route.
– New 3PL packaging standard.
If you cannot show when a change happened, you cannot explain why totals changed year-on-year. Unexplained drift is exactly what triggers audits.
So your dataset needs governance fields such as:
– Source type (supplier spec, internal measurement, 3PL spec).
– Validated-on date.
– Owner responsible for validation.
– Effective start and end dates for that configuration and weight set.
– Change reason.
This turns your BOM into a living system rather than a one-time spreadsheet.
Common failure mode.
A single BOM used for multiple years “because nothing major changed.” In practice, many small changes add up and become indefensible.
Putting it together: what “audit-grade” looks like in practice
When the seven fields exist, you can answer the hardest audit question quickly:
“How did you build France 1,200 kg plastic?”
You can respond:
– These are the SKUs sold into France.
– These packaging configurations apply to those sales channels.
– These components and weights exist per unit.
– Composites are split using supplier declarations and teardown evidence.
– Reusable items are either excluded with documented logic or included with return evidence.
– Changes mid-year are versioned with effective dates.
That is the difference between a smooth review and a painful corrective exercise.
How RegSurance can help you
RegSurance helps companies move from reporting spreadsheets to audit-grade packaging data management across multiple EU countries.
We support:
– Packaging BOM design at SKU and configuration level, including component libraries.
– Controlled material taxonomy aligned to scheme reporting categories.
– Composite packaging decomposition methodology with evidence templates.
– Reuse and return logic modelling with defensible documentation.
– Data governance setup: ownership, validation cadence, versioning, effective dates, and change logs.
– Operationalisation for multi-country reporting: connecting the BOM to your placing model, Incoterms, and transaction flows.
– Audit pack preparation: assumption register, evidence folder structure, traceability trails, and replayable calculations.
Where this becomes scalable is our cloud-based platform, PaxHub, which is built to solve the same pain points in a repeatable way:
– A single source of truth for SKU-level packaging configurations and component weights.
– A centralised evidence vault for supplier specs, teardown records, and change logs.
– Built-in version control so packaging changes mid-year do not break reporting.
– Automated roll-ups by country, stream, and material, based on your placing-model logic.
– Always audit-ready structure: you can reproduce the “how” behind every number, not just the totals.
– Single-click report generation for country declarations and internal reconciliation packs.
The goal is simple. Every kilogram you report should be explainable, reproducible, and defensible—and with PaxHub, reporting becomes a controlled process instead of a yearly scramble.
FAQ
1. We are early stage. What is the minimum we should implement first?
Start with the basics: SKU plus configuration ID, component list, and component weights. That gives you traceability. Then add composites, reuse logic, and change control once the base is stable.
2. How do we manage this if we have thousands of SKUs?
You do not weigh every SKU manually. You build packaging families—standard boxes, standard mailers, standard fillers, standard tape—then map SKUs to the closest packaging configuration. This is how large retailers manage scale without losing audit defensibility.
3. What is the best way to obtain weights?
A tiered approach works best. Use supplier specs as a baseline, validate top-volume SKUs with teardown weighing, and spot-check periodically after supplier changes.
4. How often should we revalidate weights?
Whenever something changes: a new supplier, new box, new film, new warehouse, new 3PL. At minimum annually, but change-driven revalidation is what prevents audit drift.
5. How do we avoid double counting tertiary packaging like pallets?
Define the reporting unit clearly. If you report per shipped consumer unit, pallets must be allocated appropriately across units. If you report per pallet shipment, you must ensure consistency across markets. Audits usually focus on whether your allocation logic is consistent and documented.
6. Can we exclude very small items like tape and labels?
You can set a documented threshold, but the key is consistency and justification. If excluded, state the rule clearly and apply it across all SKUs. Do not exclude selectively.
7. What documents should we keep as audit evidence?
Keep supplier declarations, internal weighing sheets, photos of teardown components on a scale, engineering drawings (if available), change logs with dates and reasons, and contracts or SOPs supporting reuse claims.
Disclaimer
This article is provided for general informational purposes only and does not constitute legal advice. EPR requirements, reporting categories, and enforcement practices vary by jurisdiction and business model and may change over time. You should obtain jurisdiction-specific legal or regulatory advice before taking compliance decisions. RegSurance provides operational compliance support and data management assistance but does not replace formal legal counsel.