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does packaging material fall under the waste question in the list

Packaging material falls under the waste question, not alongside it

Yes, packaging material belongs to the question about total waste per year, not to a separate section. The VSME baseline module asks about waste as one line item, broken down by hazardous and non-hazardous, and not by waste streams per material type. Packaging material — cardboard, film, pallets, plastic — simply counts towards the total weight of non-hazardous waste, unless your customer's contract contains a separate column for packaging. The latter occurs with larger retailers and food companies, but is then an addition by that customer to the format, not part of the standard question.

Where things often go wrong: the separation question. The question about which part is collected separately concerns the ratio of separated versus mixed, and packaging waste counts twice — once in the total, once in the separated part if your waste processor registers it as a separate stream (for example "paper/cardboard" or "plastic packaging"). If you don't have that breakdown, then the answer to the separation question is an estimate or "unknown", not a guess upwards. Also do not confuse this with the emissions question: packaging material that you purchase from suppliers falls under scope 3, not under the waste line — see the explanation for scope 3 emissions in the value chain if a customer has included separate rules for it.

Basis: the waste indicator in the VSME module

The EFRAG VSME standard treats waste as one indicator with a weight in kilograms or tonnes, broken down by hazardous/non-hazardous, without mandatory breakdown by material type — packaging is thus by standard part of that total line item, not a separate line. If a customer specifically asks for packaging weight separately, that is a separate question from that portal, and not a question that follows from the VSME baseline itself.

What this is based on

The regulation itself is on EUR-Lex. We refer for each claim; you do not have to take our word for it.

What you concretely need to do

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This is not legal advice. This page provides general information on the regulations this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.

Written with AI based on the sources above, checked by a human on 2026-09-05. Is something incorrect? Let us know — corrections receive priority.