Germany's Packaging Act Implementation Act, which puts the European packaging regulation into national law, has applied since 12 August 2026. For wholesalers, for manufacturers and for every company that ships goods in its own cartons, this is not primarily a legal task but a data task. Material type and mass of every packaging belong on the item as an attribute. The annual volume has to come out of the sales data rather than out of an estimate. The data filing and the completeness declaration then draw on the same data set. Build that chain once and both filings come out of a single report. Skip it and every spring starts with a spreadsheet and a set of weights recalled from memory.
Key takeaways
- Reporting duties rarely fail on willingness and almost always on a missing field. As long as material type and packaging mass are not held on the item, every annual volume remains an estimate that nobody can recalculate.
- A packaging is rarely one number. Sales packaging, outer carton, pallet film and label are four separate masses that arise in different places - on the item, on the outer unit and on the shipment.
- The reported volume is a product of mass and quantity. Taking the quantities from delivery notes and credit notes rather than from a sales report deducts returns and cancellations automatically and correctly.
- The data filing and the completeness declaration are two routes out of the same data set. They differ in deadline, recipient and depth of review, not in where the data comes from - which is exactly why one report beats two spreadsheets.
- The most valuable part of the work is traceability. A reported volume that can be traced back to the individual document survives any follow-up question a year later, even once the person in charge has changed.
What the new rules ask of the item master
The provisions themselves are shorter than their reputation suggests. Anyone who makes packaging available on the German market for the first time has to register, join a scheme and state which material type is involved and what mass sits behind it. That is precisely where the text jumps from the legal into the operational: material type and mass are not opinions but two values per packaging. The statute mentions them in passing; companies notice only at the first attempt to file that neither value is maintained in any system. Ordering happens in units, costing happens in prices, but reporting happens in kilograms per material type.
There are two reporting routes and they hang on a volume threshold. If the mass of packaging subject to system participation in the previous calendar year is below 10 tonnes (German Packaging Act Implementation Act, Section 9 (2)), the ongoing filing falls away; instead the figures for a calendar year are submitted in one go by 1 June of the following year to the central packaging register agency. Above the threshold, filing is continuous. The threshold is therefore itself a number you have to know - and you only know it if you can calculate the annual mass at all. A company that does not know its mass does not even know which of the two duties applies to it.
On top of that comes the completeness declaration. It has to be lodged annually by 15 May (German Packaging Act Implementation Act, Section 10 (1)), and it is audited before it is lodged. For the data work that is the real distinction: a data filing is received, a completeness declaration is confirmed. If you need a confirmation in May, you have to know in January where every figure comes from. There is also a transitional deadline that falls due this year: changes to registration data have to be made by 12 November 2026 (German Packaging Act Implementation Act, Section 68 (2)). That is not a filing date, but it is the date on which many companies look at their own master data for the first time.
Two deadlines, one data set
Which field is missing on the item
Almost every item master holds a number, a description, a unit, a price, a tax key and a weight. That weight is usually the shipping weight, goods plus packaging, and it is often estimated because it was only ever needed for a freight bracket. For reporting purposes the field is unusable. What is needed is the mass of the packaging without its contents, split by material type, per sales unit. As long as both values sit in a single field, no material volume can be derived from the sales figures. This is the point at which a legal topic turns into a master data topic - and master data is the foundation everything else rests on, as we set out in getting master data in order.
In practice three things are missing. First, a field for the material type with a fixed list rather than free text, because filing happens per material type and not per description. Second, a field for the packaging mass in grams, kept separate from the shipping weight. Third, an assignment of which packaging actually belongs to this item - a bottle has glass, a label and a closure, and that is three material types on a single item. As soon as that multiple assignment is needed, one field on the item is no longer enough and a small table appears: item, packaging component, material type, mass.
Item Component Material type Mass Qty per SU
-------------+------------------+-----------------------+-------+-----------
A-10042 | Bottle | Glass | 380 g | 1
A-10042 | Label | Paper and board | 2 g | 1
A-10042 | Screw cap | Metals | 4 g | 1
A-10042 | Outer carton (6) | Paper and board | 210 g | 1 per 6 SU
SHIP-K2 | Shipping carton | Paper and board | 340 g | per shipment
SHIP-F1 | Protective film | Plastics | 18 g | per shipment
Reported volume per material type = sum (mass x quantity) over all documents
Returns and credit notes enter the same sum with a negative sign.The layout looks unspectacular, and that is exactly its strength. It separates what daily work tends to mix: the packaging that sits on the item, the outer unit that bundles several items, and the shipping material that only comes into existence at the packing bench. These three levels have different reference quantities. The first hangs on the sales unit, the second on the outer unit size, the third on the shipment. Hang everything on the item and you count the shipping carton once per line on the delivery note - and systematically report too much.
From delivery note quantity to reported volume
Once the attributes are in place, the reported volume is a multiplication. For every document in the calendar year the quantity is multiplied by the stored mass per material type and summed up. What matters is the choice of document type. The sales report is tempting because it is close at hand, but in many systems it knows nothing about returns, cancellations, samples or warranty shipments. The delivery note does know about them, because it describes what actually left the building. And that is what counts for the filing: first-time making available on the German market, not revenue.
The second decision concerns the destination. Packaging that goes abroad does not belong in the same sum as domestic deliveries, and deliveries to commercial waste points differ from deliveries to private households. Both distinctions already sit in the document data - country code and customer group - and both are routinely overlooked because they play no part in revenue. Build them into the report once and the split is permanent. Patch them in by hand each spring and the work repeats every year, with a different judgement call each time.
The third decision is the least conspicuous and causes the largest discrepancies: what happens to shipping material? Cartons, tape, padding and pallets do not run through the item master but through purchasing. Here the purchase document is a better source than an extrapolation from shipment counts, because warehouse stocks shift over the year. The workable approach combines the two: purchased quantity for the year, corrected by the stock difference at the cut-off date. That requires a stocktake that also covers packaging material - a point rarely considered in preparing the stocktake.
One leading system per value
Material type and mass live in the item master, quantities come from documents, shipping material from purchasing. Every value has exactly one home, otherwise a copy quietly ages.
Keep the three levels apart
Sales packaging, outer unit and shipping material have different reference quantities. Mix them and the carton is counted once per line on the delivery note.
Material type as a picklist
A fixed list instead of free text. Otherwise 'card', 'carton' and 'corrugated' become three values for the same material type and cannot be summed cleanly.
Returns with a sign
Credit notes and returns go into the same sum, just negative. That is simpler and more auditable than estimating a correction line at year end.
Record the cut-off
Every report carries the time it was produced and the data status it used. Without that note a later discrepancy can no longer be explained.
Back to the document
Every sum comes with the list of documents it was built from. That list is the difference between a number and an evidenced number.
Maintaining weights without weighing every variant
The most common objection is that several thousand items cannot possibly be weighed. That is true, and it is also unnecessary. Packaging repeats itself far more than items do. A range with four thousand positions often gets by with thirty to fifty packaging formats, because the same bottle, the same can and the same pouch are used across many items. The effort therefore depends on the number of distinct packagings, not on the number of items. Draw up that list first and the task shrinks by an order of magnitude before anyone touches a scale.
For traded goods there is a second route. Suppliers know the packaging data of their own products because they carry the same duty. A request through purchasing often delivers a large share of the values, and at a quality an in-house scale will not reach. What matters is recording the provenance of each value: weighed in house, taken from the supplier, or derived from a packaging format. That provenance note costs one field and saves an hour during an audit, because it answers the question before it is asked.
Step 1: Count packaging formats, not items
Pull a list of the packaging formats actually in use from the item master - 0.7 l bottle, 425 ml can, folding box size 2. That list is usually two orders of magnitude shorter than the item master and is what makes the task plannable at all.
Step 2: Weigh and break down each format once
One empty packaging per format is weighed and broken down into its material types: container, closure, label, leaflet. A kitchen scale with gram resolution is enough; what matters is that each component is captured on its own rather than as a total.
Step 3: Collect supplier figures
For traded goods the values are requested from the supplier, ideally as a list across all items sourced. Every adopted value is flagged as adopted so that it stays visible later which figure originated in your own house.
Step 4: Assign formats to items
The assignment happens once per item and then automatically for every new item of the same format. Without this step the maintenance drifts into the future and the data gap grows with every item created.
Step 5: Block item creation without packaging data
A mandatory field at item creation keeps the master data clean permanently. It is inconvenient and effective: without that block the master will be as patchy in two years as it was before, only with more items.
Pull a list of the packaging formats actually in use from the item master - 0.7 l bottle, 425 ml can, folding box size 2. That list is usually two orders of magnitude shorter than the item master and is what makes the task plannable at all.
One empty packaging per format is weighed and broken down into its material types: container, closure, label, leaflet. A kitchen scale with gram resolution is enough; what matters is that each component is captured on its own rather than as a total.
For traded goods the values are requested from the supplier, ideally as a list across all items sourced. Every adopted value is flagged as adopted so that it stays visible later which figure originated in your own house.
The assignment happens once per item and then automatically for every new item of the same format. Without this step the maintenance drifts into the future and the data gap grows with every item created.
A mandatory field at item creation keeps the master data clean permanently. It is inconvenient and effective: without that block the master will be as patchy in two years as it was before, only with more items.
Anyone who completes these five steps owns more than a reporting basis. Packaging masses per item are also the basis for defensible freight costs, for calculating pallet quantities and for judging whether switching to a different material achieves anything at all. That is the pleasant side effect of a compliance task: the data an authority asks for is almost always the data the business was missing anyway. We describe similar double benefits for stock and routes in streamlining warehouse processes.
Estimate or calculate: what the auditor sees in May
The completeness declaration is audited before it is lodged. In practice that means a sample: one material type is picked, the reported mass is broken down into its components and individual documents are traced. Anyone who estimated finds out at this point, because an estimate cannot be broken down. Anyone who calculated presents the report and the review ends early. The difference between the two routes does not show up in the figure itself but in what sits behind the figure and whether it can be produced on request.
| Aspect | Volume calculated | Volume estimated |
|---|---|---|
| Source of quantity | Documents of the calendar year, returns with a negative sign | Sales report or prior-year rule of thumb |
| Source of mass | Weighed or supplier-provided values per packaging format | Flat rate per item group, often derived from shipping weight |
| Third-party review | A sample can be traced to the individual document | A query can only be answered with a fresh estimate |
| Effort in the following year | Another run of the same report | Full repetition of the estimate with a different result |
| Explaining discrepancies | Volume change and range change are visible separately | The gap stays unexplained because the basis changed |
| Change of personnel | The report is documented and keeps running | The knowledge leaves the company with the person |
The last row is underrated. Reporting duties run for years, responsibilities do not. A report that is stored in a system and makes its own rules visible survives a change of ownership inside the company. A spreadsheet in a personal folder does not. The same reasoning sits behind process documentation for audits: the evidence is not the result but the described route to it. Write down the route and you do not have to reinvent it next year.
Two filing routes out of one report
Technically the task is a join across three sources. The item master supplies material type and mass, the documents supply quantities and period, the purchasing system supplies shipping material. If those sources sit in one system, it is a query. If they sit in three - ERP, shipping software, a spreadsheet in purchasing - it is a question of data integration. The connection itself is rarely the hard part; the hard part is the keys you connect on. Item numbers differ between systems more often than the people involved expect, and a mapping table is then the first genuine piece of work.
The finished report produces two outputs. The first is the data filing in the format of the central agency, either ongoing or as an annual submission. The second is the schedule for the completeness declaration, grouped by material type and supplemented by the derivation. Both draw on the same table, and that is exactly where the value sits: two outputs from one source cannot drift apart. How to anchor such recurring reports instead of rebuilding them every time is described in generating reports automatically.
The spreadsheet is not the enemy, the copy is
A word on retention. The report for a reporting year is evidence and belongs in an archive, not under an overwrite. That includes the report itself, the data status, the packaging masses used and the list of document types included. Put that into an orderly archive rather than a folder on a drive and you will find it again next year - the same logic as with retention periods and with document digitisation. Evidence you cannot find is not evidence.
What to do over the coming weeks
The entry point is smaller than the task looks. To begin with it is not about having all the values but about knowing how many are missing. A count across the item master answers in half an hour how large the gap is, and the effort follows from that. Only then is it worth deciding whether to weigh, ask or derive. The following order has proved robust in projects in wholesale and in manufacturing.
- Measure the gap: how many active items have no packaging weight, no material type or only a shipping weight? Those three numbers are the basis of any effort estimate and can be produced in minutes in any system.
- List packaging formats: which distinct packagings actually occur in the range? That list determines the weighing effort, not the item count.
- Fix the document type: which documents produce the quantity - delivery note, invoice or both, and how are returns handled? Make the decision once and write it down.
- Define the splits: domestic and export, private and commercial waste point, own brand and traded goods. All four distinctions already sit in the document data.
- Build the report and sanity-check it: a first run across the current year immediately shows whether the order of magnitude is plausible. An obviously low total usually points to missing packaging attributes, an obviously high one to double-counted shipping material.
- Anchor the maintenance: mandatory field at item creation, a named owner, an annual refresh of supplier figures. Without that last point the work has to be done again in two years.
What stands out is how often this route answers other questions on the way. The gap measurement in the first step regularly surfaces items that have had no turnover for years and are still being maintained. The list of packaging formats shows how many carton sizes are genuinely in use. And the split between domestic and export is exactly the distinction that tends to be missing from metrics and reporting anyway. A compliance task is rarely only a compliance task once you hang it on the data chain rather than on the form.
The threshold decides the route, not the amount of work
How we approach it
We start with a stocktake, not with a system change. In the process analysis we look at which fields exist in the item master, how documents arise, where shipping material is recorded and which keys connect the systems. The result is a schedule of gaps with an effort estimate per gap, and from that the decision follows about what gets automated and what stays manual. For companies in wholesale the largest item is usually the assignment of packaging formats to traded goods; in manufacturing it is breaking your own packaging down into material types.
- Create fields for material type and packaging mass in the existing system or, where that is impossible, keep them in a connected table that is fed from the master.
- Capture packaging formats, break them down and assign them to items, including a provenance note per value.
- Bring documents from the ERP and the shipping system together through an interface so that quantities and splits come from one source.
- Build the report per material type, with a derivation down to the document and a fixed data status per run.
- Produce two outputs: the data filing and the schedule for the completeness declaration.
- Anchor the maintenance: mandatory field, named owner, annual refresh - so that the data does not drift away again.
Producers under Section 7 (1) first sentence are obliged to lodge a completeness declaration annually by 15 May.
For a sense of the effort: a process analysis starts at 1,900 EUR net, delivery per interface or automation at 4,900 EUR net, ongoing support at 190 EUR net per month. Prices as of September 2026. The ongoing services can be cancelled monthly; there is no minimum term. If you want to know how large the gap in your item master actually is, getting in touch is the shortest route; the commercial terms are on the pricing page. We describe a related data chain in shift rosters that check rest periods upfront, and what data integration looks like technically is set out there in detail.
Sources and legal basis
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