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Can I submit the annual packaging report myself?

The annual report is essentially a sum of weights per material type, but as soon as you supply multiple countries, each register comes with different requirements and deadlines. This article shows where doing it yourself works and where outsourcing adds value.

You can file the annual packaging report yourself in many cases, especially if you operate in a single country and carry a straightforward range of products. The report essentially comes down to adding up weights per material type over the past year and entering them into the correct national register. Anyone who keeps their own packaging data will get far without external help.

The question changes once you supply multiple EU countries. Each country has its own register, its own classification of material categories, and its own deadline for submission. What counts as plastic in one country sometimes falls under a separate category for composite materials in another. These differences are exactly where doing it yourself costs time that is not in the packaging itself, but in working out the rules per register.

What an annual report actually requires

An annual report typically consists of two parts: the quantity of packaging material you have placed on the market in a country, broken down by material type, and confirmation that this aligns with your earlier registration in that register. For a company that only sells from a webshop with a handful of product types, this is a matter of extracting data from your own records and transferring it. For a company with dozens of product lines, changing suppliers, and different packaging variants per market, this quickly becomes a research task.

The complexity does not lie in the annual report as a form, but in the underlying data. If you know exactly how many grams of cardboard, plastic, and paper were used per product sold, filling in the report yourself is limited work. If that record is missing, it must first be built up, and that takes more time than the report itself.

Where doing it yourself remains practical

Doing it yourself works well when you supply a single country, use a limited number of packaging types, and your material data is already recorded in your purchasing administration. In that situation, the annual report is a yearly routine task that you can handle yourself with a spreadsheet and the register's instructions. There is then no pressing reason to outsource it, and it is more honest to say so than to sell a service you do not need.

Also, when you want to check once whether your classification of materials is correct, you can often ask the register in question or its guidelines. With a few questions you can see which role you fall under per packaging type and country you also get free an initial indication of what is relevant for your situation, without needing an account for that.

Where it gets more complicated

The line shifts once you have to report in multiple countries at the same time. Then it is not just the content of the report that matters, but also the timing: one register closes the financial year by calendar year, another uses a different submission date. Anyone who tracks this separately per country risks missing a deadline abroad more easily than the familiar Dutch date.

Material classification also differs per register, and an incorrect category in the report does not automatically trigger an error message but can emerge later during an inspection. Supervisors look at the supporting documentation of the reported weights and the categories used, not just the final figure. This is precisely the point where having an overview per country, with the correct categories and deadlines already in place, saves time compared to working out how a specific register organizes things all over again each year.

What you do yourself and what you have guided

Collecting, maintaining and breaking down your own packaging data by product line remains your own work in all cases; no one else can do this for you because only you know what was actually shipped. Where guidance adds value is in translating that data into the correct breakdown per country and not missing a submission deadline when you have to report to multiple registers at the same time. In the knowledge base with explanations by topic and by situation there is an explanation of what each register exactly asks for, and the annual reporting calendar within the subscription keeps track of the deadlines per country for you so you don't have to check each register yourself to find out when the deadline falls. What that costs and what is exactly included is shown clearly on the page with the subscriptions and what goes with it.

If you are unsure whether your situation falls into the category of doing it yourself or having it guided, that can be seen with a few questions. Do the free quick-scan or first read how we substantiate our information and where it comes from to determine what is most convenient for your company.

This article is general information and not legal advice.