Understanding EPR Packaging
Some of the products we supply may be considered packaging under UK EPR rules. Packaging under EPR is any product that is used to:
Contain a product – holds the product itself, e.g., a bag, pouch, bottle, or box.
Protect a product – keeps the product safe during storage or transport, e.g., bubble wrap, pallet wrap, sleeves.
Handle or deliver a product – helps move or ship goods, e.g., pallets, crates, trays used for shipping.
Present or display a product – used for marketing or showing the product, e.g., branded outer boxes, display trays.
Not included: Items that are not used to contain, protect, transport, or present goods (e.g., machinery, consumables like labels or additives) or packaging that never enters the supply chain.
Why this matters: Answering the questions in this questionnaire accurately ensures that we report only the products that count as EPR packaging, helping both your business and ours comply with the regulations.
What Are The Packaging Types?
Primary packaging
Primary packaging is what’s used to contain a single ‘sales unit’ to sell to customers. For a sales unit that’s made up of lots of items, such as a multipack, the primary packaging includes all of the packaging on the items.
For example, if you sell peas in steel tins with paper labels, the primary packaging is ‘steel tin’ and ‘paper label’.
For a multipack of crisps in plastic bags, the primary packaging is the ‘plastic bags’ around the crisps and the larger ‘plastic bag’ around the crisp packets.
Secondary packaging
Secondary packaging is for grouping several ‘sales units’ for selling or transport purposes. Organisations may also use secondary packaging to display goods in shops.
For example, if you place tins of peas onto a cardboard tray and place the tray onto a supermarket shelf, the secondary packaging is ‘cardboard tray’.
Shipment packaging
Shipment packaging is any packaging added to primary packaging for goods sold online or by mail order and delivered directly to the purchaser or to a shop or collection point. Shipment packaging can include cardboard boxes, bubble wrap and mail bags.
For example, if you sell a mobile phone directly to a purchaser online, in a cardboard box and then place the box into a mail bag before posting it, the primary packaging is the cardboard box and the mail bag is shipment packaging.
Tertiary packaging
Tertiary or transit packaging is used to group secondary packaging units together to protect them while being transported or handled through the supply chain.
Tertiary packaging does not include road, rail, ship and air containers.
For example, if secondary packaging units are placed into larger cardboard boxes that are sealed with plastic parcel tape and put onto wooden pallets to be transported, the tertiary packaging is ‘cardboard box’, ‘plastic tape’ and ‘wooden pallet’.
