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Guide 8 min read

EPR for Cleaning Products: Packaging Compliance Guide

EPR Compliance Team

Table of Contents


Key Takeaways

  • Cleaning product companies with £1M+ turnover and 25+ tonnes of packaging are obligated under packaging EPR.
  • HDPE bottles and trigger sprays are the dominant packaging format, and spray triggers with mixed plastic/metal components attract higher fees.
  • Refill formats (pouches, concentrates, tablets) can significantly reduce per-unit packaging weight and EPR costs.
  • The Plastic Packaging Tax also applies to cleaning product packaging with less than 30% recycled content — this is a separate cost on top of EPR fees.
  • Labels, caps, and trigger mechanisms must all be individually classified and weighed for EPR reporting.

Why Cleaning Product Companies Must Comply

The UK cleaning products sector — covering household cleaners, laundry detergent, dishwashing products, air fresheners, and industrial cleaning chemicals — is heavily reliant on plastic packaging. HDPE bottles, trigger sprays, pouches, and refill packs are the industry staples.

Under packaging EPR, every piece of packaging placed on the UK market must be accounted for. For cleaning product manufacturers and importers, this means tracking not just the main bottle but every cap, trigger, label, and shrink sleeve.

For EPR basics, see what packaging EPR is.

Obligation Thresholds

Standard thresholds:

  • Annual turnover of £1 million or more
  • Handle 25 or more tonnes of packaging per year

Cleaning product companies easily exceed these thresholds. A company producing 5 million 500ml spray bottles annually generates approximately 150 tonnes of HDPE packaging from bottles alone.

Check who needs to register for packaging EPR for complete threshold guidance.

Cleaning Product Packaging Types

Primary Packaging

  • HDPE bottles — the most common format (spray cleaners, detergents)
  • PET bottles — clear bottles for some products
  • Trigger spray mechanisms — multi-component (PP body, metal spring, PE dip tube)
  • Pump dispensers — similar multi-material construction
  • Flexible pouches — refill packs (often multi-layer)
  • Cardboard boxes — for tablets, pods, powder detergents
  • Paper wraps — eco-brand solid cleaning bars
  • Aluminium cans — aerosol air fresheners, spray starch
  • Shrink sleeves — plastic film labels

Secondary Packaging

  • Corrugated cardboard — retail-ready cases
  • Shrink wrap — bundling multi-packs
  • Cardboard sleeves — wrapping multi-packs

Transit Packaging

  • Corrugated cases — shipping boxes
  • Stretch wrap — pallet wrap
  • Pallet sheets — interlayer sheets
  • Strapping — plastic or paper banding

Component-Level Tracking

Under EPR, you must report each packaging component separately. A single spray bottle might include:

ComponentMaterialTypical Weight
Bottle bodyHDPE30g
Trigger sprayPP/metal15g
Dip tubePE2g
Shrink sleeve labelPVC/PET3g
Cap (if applicable)PP5g
Total55g

At 10 million units, that is 550 tonnes of primary packaging.

EPR Fee Impact

MaterialFee per tonne (approx.)Cleaning Product Use
HDPE£360Bottles
PP£360Caps, triggers
PET£360Clear bottles
PVC (sleeves)£440+Shrink sleeve labels
Aluminium£230Aerosol cans
Paper/card£215Boxes, labels
Multi-material£461Laminated pouches
Corrugated card£215Transit packaging

A medium-sized cleaning product brand handling 500 tonnes of packaging could face annual EPR fees exceeding £150,000, with plastic packaging being the dominant cost driver.

For the full fee schedule, see the EPR fees by material type guide.

Data Collection

Leverage Existing Specifications

Cleaning product manufacturers typically have detailed packaging specifications for every SKU because of product safety labelling requirements. Use these as the foundation for your EPR data:

  1. Extract packaging specs from your product database/ERP system
  2. Verify weights by physically weighing samples (specs may be nominal weights)
  3. Include every component — bottles, caps, triggers, labels, seals, and closures
  4. Map to material types using your supplier’s material declarations
  5. Multiply by production/sales volumes for annual tonnage
  6. Allocate nation data using distribution records

Common Oversights

  • Trigger spray mechanisms — often forgotten or lumped with the bottle
  • Label materials — shrink sleeves, pressure-sensitive labels, printed cartons
  • Tamper-evident seals — the plastic ring under caps
  • Promotional packaging — seasonal gift sets, limited editions
  • Transit packaging additions by third-party logistics providers

For detailed guidance, see how to report packaging data to DEFRA.

Cost Reduction Strategies

1. Lightweighting Bottles

HDPE bottle technology has advanced significantly. Modern bottles can be 15-20% lighter than older designs while maintaining performance. A 5g reduction per bottle across 10 million units saves 50 tonnes of plastic — and approximately £18,000 in EPR fees.

2. Eliminate PVC Shrink Sleeves

PVC shrink sleeve labels attract the highest plastic fee rates and are difficult to recycle. Alternatives include:

  • Direct printing on the bottle (no label waste)
  • Paper labels — pressure-sensitive paper labels
  • PET or PETG shrink sleeves — recyclable alternatives
  • PP labels — matching the bottle material for recyclability

3. Introduce Refill Formats

Refill packs use significantly less packaging per unit of product:

FormatPackaging WeightSavings vs Spray Bottle
Standard 500ml spray bottle55g
500ml refill pouch12g78% less
Concentrated refill sachet (makes 500ml)5g91% less
Dissolvable tablet + reusable bottle3g95% less

The EPR savings from refill formats are substantial and growing as more consumers embrace them.

4. Switch to Recycled Content

Using 30%+ recycled plastic content exempts you from the Plastic Packaging Tax (£210.82/tonne) and may qualify for lower modulated EPR fees as the scheme evolves.

5. Standardise Trigger Mechanisms

If you produce multiple products in similar bottle sizes, using a single trigger design across the range simplifies data collection and allows bulk purchasing at lower cost.

The Refill Revolution and EPR

The cleaning products industry is at the forefront of the refill movement, driven partly by EPR costs and partly by consumer demand. Key trends:

  • In-store refill stations — customers bring their own bottles
  • Concentrated refills — smaller pouches that customers dilute at home
  • Dissolvable tablets and pods — minimal packaging
  • Subscription refill models — regular deliveries in lightweight packaging

From an EPR perspective, refill formats dramatically reduce per-unit packaging weight. A brand that converts 50% of its volume to refills can cut its EPR packaging tonnage by 30-40%.

For more on refills and subscription models, see our EPR for subscription box businesses guide.

Plastic Packaging Tax Overlap

Cleaning product companies face a double obligation:

  1. Packaging EPR fees — based on packaging weight and material
  2. Plastic Packaging Tax — £210.82/tonne on plastic packaging with less than 30% recycled content

These are separate charges. A company paying EPR fees on plastic packaging must ALSO pay the Plastic Packaging Tax if the recycled content threshold is not met.

For a comparison of these two regimes, see EPR vs Plastic Packaging Tax.

Getting Started

  1. Verify your obligation using the EPR compliance checklist
  2. Audit every packaging component across your product range
  3. Register with a compliance scheme or the Environment Agency
  4. Submit data via DEFRA’s RPD portal
  5. Develop a roadmap for packaging optimisation

Calculate your estimated fees with the EPR fee calculator and see our pricing page for compliance management tools.

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