Packaging EPR, REACH Article 33 & SCIP — Jurisdiction‑Ready Outputs

Accelerate UK/EU packaging reporting and chemicals transparency with jurisdiction‑ready exports. Interoperates with your spreadsheets and connects to Rosella for change tracking. See also: Packaging compliance for consumer goods, Features, and Rosella AI Compliance Agent.

Downloads

Use these copy‑ready resources to jump‑start submissions and audits. Parakeet also hosts these as templates in your workspace with validations and approval workflows.

• UK EPR sample CSV (single‑file schema)

organisation_id,reporting_period_start,reporting_period_end,producer_role,packaging_activity,packaging_type,packaging_class,material,sub_material,weight_kg,units,nation_of_sale,ram_color,design_features,methodology_reference,drs_applicable,reuse_refill
SAMPLE-ORG-UK,2025-01-01,2025-06-30,brand_owner,own_brand,household,primary,plastic,PP,12.50,600,England,Amber,"wash-off-label","RAM v1.2 – method ref",No,Single-use

• SCIP notification field checklist (IUCLID‑compatible) | Field | Description | Required | |---|---|---| | Article name/identifier | Unique article/component name and internal ID | Yes | | Article category code | TARIC/EuPCS/Other category as required in IUCLID | Yes | | Material category | Base material(s) of the article | Yes | | Candidate List substance | SVHC name from REACH Candidate List | Yes | | Concentration range | Reported range of SVHC in the article | Yes | | Location of SVHC | Where the SVHC is present in the article | Yes | | Safe‑use information | Guidance enabling safe use/handling | Yes | | Complex object links | Parent/child article relationships | Conditional (for sets) | | Duty holder type | Producer/assembler, importer, or distributor | Yes | | Upstream SCIP number | Reference for Simplified SCIP Notification | Conditional (for SSN) | | Market of placement | EU country where the article is placed on market | Yes | | Submission route | Portal, IUCLID Cloud, or S2S connector | Optional |

Tip: Parakeet packages these fields into IUCLID‑compatible exports (including i6z) and preserves confirmations alongside Article 33 disclosures for full auditability.

Introduction

Industrial packagers face two concurrent obligations in the EU and UK: (1) packaging Extended Producer Responsibility (EPR) reporting to national regulators/PROs, now framed by the EU Packaging and Packaging Waste Regulation (PPWR), and (2) chemicals transparency under REACH, including Article 33 communication and SCIP notifications when SVHCs exceed 0.1% w/w in articles. The PPWR entered into force on February 11, 2025, replacing Directive 94/62/EC and applying 18 months after entry; it harmonizes rules affecting packaging design, recyclability, recycled content, and labeling. UK EPR has live data reporting with CSV submissions and recyclability (RAM) assessments beginning in 2025. These regimes change reporting scope, required fields, and deadlines that packaging producers must meet.

What Parakeet Risk does for packaging EPR and REACH/SCIP

Parakeet Risk is an AI‑native GRC platform used by industrial manufacturers, pharma, and consumer goods/packaging teams to centralize packaging compliance, automate evidence, and maintain audit‑ready records across sites and suppliers. Capabilities include:

• Unified data model for packaging bills of materials (articles and complex objects), supplier certifications, and market placements, with audit trails and material traceability from sourcing to delivery. Packaging compliance for consumer goods.

• Automated regulatory tracking and research via the Rosella AI Compliance Agent to monitor PPWR updates, REACH Candidate List changes, and national EPR portal requirements; outputs structured checklists and evidence packs.

• Spreadsheet‑friendly workflows that preserve existing Excel models while adding validations, version control, approvals, and export automation. Features.

• Integrations to operational systems (ERP/finance/HRIS/collaboration) to pull packaging volumes, SKU hierarchies, supplier master data, and to deliver alerts in Slack/Teams and tasks in Trello. Integrations.

Step‑by‑step workflow: Packaging EPR reporting (EU/UK)

1) Define producer roles and markets of sale

• Identify legal entities and roles (brand owner, importer, distributor, marketplace operator) per country. Register where required (e.g., Germany’s LUCID Packaging Register) and enroll with a producer responsibility organization (PRO/dual system) if packaging is subject to system participation. Store registration IDs (e.g., DE “LUCID” UIN) and brand names.

2) Establish reporting periods and deadlines

• Maintain a country calendar (e.g., UK EPR: 2024 data due by April 1, 2025 for small/large organizations per scope; RAM recyclability assessments for household packaging reported from October 1, 2025 for Jan–Jun 2025 period). Parakeet surfaces regulator notices and date shifts as tasks.

3) Collect packaging “placed‑on‑market” (POM) data

• Capture by legal entity and country: packaging activity (own brand, importer, distributor, online marketplace, hired/loaned, supplied as empty), packaging type (household vs non‑household), class (primary/secondary/shipment/tertiary), material/sub‑material, weight (kg) and units, reuse/refill status, DRS applicability, and where required, nation‑of‑sale/discard.

4) Recyclability and fee modulation inputs

• For the UK in 2025, calculate RAM ratings (red/amber/green) per component, capture design features affecting recyclability, and attach methodology statements for regulators. Track evolving PPWR recyclability and reuse targets for EU portfolios.

5) Validate and normalize data

• Parakeet runs unit consistency checks, duplicate detection, and material code validation against local schemas; it also preserves evidence (invoices, BOMs, weighbridge data) for regulator queries.

6) Generate regulator‑ready files and submit

• Output country‑specific CSV for the UK “report packaging data” service (single CSV encompassing all required columns). Maintain organization/brand/partner CSV templates. For EU PRO portals, export mapped CSV/XLSX as required by each scheme; store confirmations.

7) Monitor fees and ROI

• Track eco‑contributions and disposal fees (e.g., UK EPR fees) and modulated fee impacts; push summary cost lines into ERP/BI dashboards.

Step‑by‑step workflow: REACH Article 33 and SCIP notifications

1) Build an article/complex object structure

• Model packaging components (articles) and packaging sets (complex objects). Map supplier declarations and SDS data to each component.

2) Screen against the REACH Candidate List

• On each update, Rosella flags substances of very high concern (SVHCs) present in articles. Parakeet records 0.1% w/w determinations at the article level (“once an article, always an article”), and prepares Article 33 disclosures for B2B recipients and 45‑day consumer requests.

3) Determine SCIP applicability and duty holder

• If an article placed on the EU market contains an SVHC above 0.1% w/w, an EU producer/assembler, importer, or distributor placing the article on the market must notify ECHA (retailers selling directly and exclusively to consumers are excluded). SCIP has been mandatory since January 5, 2021.

4) Choose notification route

• Full notification: prepare an IUCLID‑based dossier covering article identification, Candidate List substance name, concentration range/location, and safe‑use information, including complex object relationships.

• Simplified SCIP Notification (SSN): where permitted, reference an upstream supplier’s SCIP number to avoid duplicative dossiers (commonly used by distributors). Parakeet stores and validates upstream SCIP numbers.

5) Prepare fields and export

• Parakeet structures data to the SCIP format (compatible with IUCLID) and exports the fields required to build dossiers in IUCLID (including i6z‑based exchanges). Teams can then submit via the ECHA Submission Portal, IUCLID Cloud, or a system‑to‑system (S2S) connector.

6) Maintain and re‑use

• Re‑use components for quasi‑identical articles, leverage referencing to build complex objects, and update dossiers when an SVHC is removed or when the Candidate List changes (ECHA added five entries on January 21, 2025, bringing the list to 247 entries).

Required data fields and export formats (concise)

Sources for formats and fields: UK EPR CSV specification and templates; ECHA REACH Article 33 guidance; ECHA SCIP format and IUCLID documentation.

Retailer portals (practical considerations)

• Amazon Seller Central EPR compliance: marketplaces may require proof of EPR (e.g., Germany LUCID UIN for packaging). Non‑compliance can lead to listing suspension or pay‑on‑behalf programs. Parakeet stores portal credentials, EPR IDs, and submission receipts alongside SKUs.

• Zalando zDirect: partners selling in Germany/France must provide EPR registration numbers (packaging is mandatory in DE) or face suspension. Parakeet maintains portal‑ready EPR IDs and brand mappings.

Implementation notes for PPWR alignment

• PPWR harmonizes packaging rules across the EU, including targets for recyclability, reuse, recycled content and restrictions on substances of concern (e.g., PFAS thresholds in certain food‑contact packaging). Track EU‑level targets in Parakeet and cascade design‑for‑recycling guidance to engineering and suppliers. Application begins 18 months after entry into force (i.e., August 12, 2026), with some staged obligations thereafter.

FAQs

• Does Parakeet submit directly to ECHA or national portals?

• Parakeet prepares regulator‑ready data (e.g., UK CSVs; IUCLID‑compatible field sets) and maintains evidence. Submission can be completed in your regulator portals, IUCLID Cloud, or through your chosen S2S connector, with Parakeet preserving submission proofs.

• When do we need a SCIP notification for packaging?

• When any packaging article placed on the EU market contains a Candidate List SVHC above 0.1% w/w. Many packaging components are articles; if the threshold is exceeded, notify and provide safe‑use information.

• How often does the Candidate List change?

• ECHA updates the Candidate List periodically (commonly twice per year). For example, on January 21, 2025, five substances were added (247 entries total), which can trigger new Article 33/SCIP duties. Parakeet monitors these updates.

• What UK data format is required in 2025?

• A single CSV per submission using the official column schema; use the published templates/generators to avoid validation errors.

• What if we sell through marketplaces?

• Marketplaces increasingly enforce EPR. Amazon requires EPR IDs (e.g., LUCID) and can deactivate non‑compliant listings; Zalando requires partners to provide EPR numbers for DE/FR. Store and reuse these IDs in Parakeet.

Why Parakeet for industrial packaging compliance

• Industrial‑specific AI (Rosella) to translate evolving PPWR/REACH/EPR rules into your day‑to‑day tasks and evidence.

• Spreadsheet synergy to operationalize existing BOM/weight models with governance and exports, avoiding disruptive rip‑and‑replace.

• Unified risk ecosystem to connect suppliers, certifications, incident/quality data, and financials, so compliance cost and risk impact are visible to operations and finance stakeholders.

Citations (selected)

• EU PPWR entry into force and application: European Commission and EU Publications Office.

• UK EPR required fields, CSV format, RAM timing: DEFRA/Environment Agency guidance.

• REACH Article 33 communication obligations (0.1% w/w, 45‑day consumer response): ECHA.

• SCIP duty holders, information requirements, and start date; SCIP format/IUCLID/i6z and S2S: ECHA.

• Candidate List update (Jan 21, 2025 – 247 entries): ECHA.

Packaging EPR Reporting Mechanics

Last updated: Oct 2025

This section gives practitioners copy‑ready CSV examples, fee‑modulation inputs, and cross‑jurisdiction schema notes. Parakeet ships these as downloadable templates and validates them against local portal rules so files pass first‑time.

UK “report packaging data” — example CSV (single file)

Use a single CSV per submission covering placed‑on‑market data. Confirm the latest columns in the regulator portal; Parakeet keeps templates synchronized and flags breaking changes.

organisation_id,reporting_period_start,reporting_period_end,producer_role,packaging_activity,packaging_type,packaging_class,material,sub_material,weight_kg,units,nation_of_sale,ram_color,design_features,methodology_reference,drs_applicable,reuse_refill
ACME-UK-001,2025-01-01,2025-06-30,brand_owner,own_brand,household,primary,plastic,HDPE,125.37,5500,England,Green,"detachable-sleeve; mono-material","RAM v1.2 – ACME method",No,Reusable

Common values

• producer_role: brand_owner | importer | distributor | marketplace | hired_or_loaned | empty_packaging_supplier

• packaging_type: household | non_household

• packaging_class: primary | secondary | shipment | tertiary

• nation_of_sale: England | Scotland | Wales | Northern Ireland (when nation data is required)

• ram_color: Red | Amber | Green

Parakeet also generates companion CSVs (organisation, brands, partners) where requested by the service:

# organisation.csv

organisation_id,company_name,companies_house_number,registered_address
ACME-UK-001,ACME Brands Ltd,01234567,"1 River Way, London, SW1A 1AA"

# brands.csv

organisation_id,brand_name
ACME-UK-001,ACME Household
ACME-UK-001,ClearPack

# partners.csv

organisation_id,partner_type,partner_name,registration_id
ACME-UK-001,reprocessor,GreenCycle Ltd,GRN-99821

Fee‑modulation and recyclability inputs (captured per component)

• RAM rating with evidence (methodology version, date, responsible engineer)

• Design features impacting recyclability (e.g., detachable sleeves, labels/inks/adhesives, closures, barrier layers)

• Reuse/refill status and rotations; DRS applicability where relevant

• Material/sub‑material taxonomy and contamination risks

• Recycled content percent (if reported) with certificate references Parakeet enforces required/conditional fields, unit checks, and evidence attachments (invoices, BOM snapshots, weighbridge data).

EU PRO portal exports — schema notes (summary)

While formats vary by scheme, most portals request the following minimum set. Parakeet maps a single data model to each portal’s CSV/XLSX layout and stores submission receipts.

• Identification: legal entity, producer role, registration IDs (e.g., national registers/PRO IDs), brand names

• Scope: market of sale, reporting period, placed‑on‑market status

• Packaging details: household vs non‑household; primary/secondary/shipment/tertiary class; material/sub‑material; component weight and count; reuse/refill

• Modulation inputs: recyclability attributes and design features; sometimes recycled content and labeling fields

Example PRO‑style CSV (illustrative):

entity_id,country,period_start,period_end,role,packaging_class,material,sub_material,weight_kg,units,reuse,modulation_attribute
ACME-EU-001,FR,2025-01-01,2025-06-30,producer,secondary,paper,cartonboard,212.9,1800,No,detachable-label

Governance tips

• Keep a controlled “code list” for materials, sub‑materials, packaging classes, and RAM attributes; Parakeet publishes these as shared dictionaries with versioning.

• Lock reporting periods; changes require approval and generate an audit trail.

• Reconcile ERP shipment lines to POM records monthly; Parakeet posts fee summaries to your ERP/BI for finance sign‑off.