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Should I include packaging material in the environmental questionnaire

Packaging material usually falls under waste, not under scope 1

Yes, packaging material usually appears in the environmental questionnaire, but not as a separate chapter. It comes up in two different questions, and it is wise to know in advance under which. First as a waste stream: packaging material that the company itself purchases and disposes of (cardboard, film, pallets) counts towards how much waste the company generates per year and in what portion of it is collected separately. That is the most common place where it reappears.

Second, packaging material can reappear in scope 3, if the customer asks about emissions across the entire value chain. The EFRAG VSME basic module does not standardly count packaging as scope 1 or 2 — these are respectively the direct emissions from the company's own facilities and the indirect emissions from purchased energy. Packaging material that is purchased from a supplier, or that ends up as waste at the customer, falls under scope 3 according to the GHG Protocol: upstream if it concerns purchased packaging, downstream if it concerns packaging of the company's own product. How that distinction works in practice is detailed in the guidance on scope 1, 2 and 3 together. If the questionnaire has no scope 3 question, there is usually no separate place for packaging needed — the waste question then covers it already.

Where that points to: the VSME modules and the scope classification of GHG Protocol

The EFRAG VSME basic module has no separate section on "packaging"; the concept only reappears implicitly within the waste indicators and, in the extended module, within the scope 3 categories distinguished by the GHG Protocol. Without an explicit packaging question in the customer's list, there is thus no independent basis to report it separately; the classification then simply follows the waste or scope 3 question that is already being asked.

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.