Understand the definition of packaging and when to report it under EPR

This article explains how to confirm if packaging is obligated or not under the EPR regulations.

9 February 2026

1. Identify the sales unit

The sales unit is the packaged product(s) at the point of sale to the final user, including both the product and its packaging.

2. Remove the product

The product or group of products consumed or used by the final user is not reported. Some items may appear to have outer packaging that is actually an ‘integral part of the product’ and should not be classified as packaging.

Common items considered a product and not reported:

• Envelopes for greeting cards
• Rolls containing camera film
• Fire extinguishers
• Wrapping paper (when sold as a product).

Common items where 'packaging' is integral to the product and not reported:

• Ink cartridges
• Tea bags
• Barbecue foil trays
• Single-use coffee pods
• Epi Pens
• Grow bags
• Kebab skewers
• Ice lolly sticks
• Silage wrap
• Tampon applicator
• Water filter cartridges

If the product itself is empty packaging that will go on to perform a packaging function once supplied to a customer, and you are not classed as a ‘distributor’ under the EPR data reporting regulations, then it does not need to be reported as packaging.

3. Exclude durable packaging

Packaging intended to store a product for its lifetime by the user (typically over five years) is not obligated.

Common items considered durable packaging and not reported:

• Power tool cases
• Carrying cases for cameras
• CD cases
• First-aid boxes
• Games boxes
• Razor handle holders
• Room deodorisers (plastic outer for re-filling)
• Glasses cases

4. The packaging function test

After steps 1-3, confirm if the packaging performs any of these functions: containment, protection, handling, delivery or presentation. If not, it is not obligated.

Common items not performing one of the packaging functions and not reported:

• Durable trays and cutlery served on airlines
• Disposable cutlery
• Removal boxes
• Spoons or leaflets with medicines

5. The packaging type test

Next, if packaging doesn’t fall under the primary, secondary, tertiary, or shipment categories, it is not obligated

From 2025, shipment packaging is defined as “tertiary packaging on, or used to contain, items supplied or intended for supply to a consumer”.

Example: Lightweight carrier bags sold at checkout are shipment packaging, even when purchased by the consumer - they remain packaging, not a product.

Labels

Labels are only considered packaging if they perform a packaging function:

• Not obligated: Labels showing only barcodes, expiry dates, Hazchem, or pharmacy info.
• Obligated: Labels with care instructions (protection/presentation) or product descriptions or brand names (presentation).

When is packaging finished?

Packaging and packaging components are only reported under EPR only when ‘finished’—after the last substantial modification before pack/filling.

Substantial modifications include extrusion, moulding, printing, laminating, and cutting. Processes like blowing, labelling, and sealing are not considered substantial.

Manufacturers and converters must determine if they are the liable EPR producer making this final substantial modification before pack/filling and are performing one of the packaging activities that picks up the obligation (e.g. distributor).

Avoid double reporting

Packaging, or a packaging component, should only be reported once by a liable business under the EPR regulations. When a producer is responsible for reporting an item of packaging, no subsequent supply of the packaging will incur an additional obligation.

For instance, a business imports a bottle of wine and supplies it to a retailer. The retailer then applies their brand to some of the bottles. The retailer should only report the label that it has added, as the importer has already reported the bottle and cork.

We’re here to help

If you’re unsure after completing the above checks, contact your account manager or the helpdesk for assistance.