Table of Contents
- What Makes You an Importer Under EPR?
- What Counts as Imported Packaging?
- From-Country Data Requirements
- How Import Packaging Is Classified
- Transit Packaging Obligations
- The Importer’s Full Packaging Footprint
- Worked Example 1: Fashion Importer
- Worked Example 2: Food and Drink Importer
- Worked Example 3: Electronics Importer
- Practical Steps for Importers
- Common Questions from Importers
Key Takeaways
- If you import packaged goods into the UK, you are responsible under EPR for all packaging on those goods — product packaging, inner packaging, and transit packaging.
- The same EPR thresholds apply: £1m+ turnover and 25+ tonnes of packaging.
- Importers must report the from-country (country of origin) for imported packaging using ISO country codes.
- Transit packaging (pallets, stretch wrap, outer cases) on imported goods is your responsibility even if it never reaches the end consumer.
- Import packaging is classified using the same categories as domestic packaging: primary (P1), secondary (P2), tertiary (P3), and shipment (SP).
Importing packaged goods into the UK triggers specific obligations under the packaging EPR regulations. As an importer, you take on responsibility for the packaging that enters the UK with your products — responsibility that would otherwise sit with the brand owner or packer if those entities were based in the UK. This places UK importers in a unique position within the EPR framework, with additional data requirements around country of origin and a potentially larger packaging footprint than they realise.
This guide explains exactly what counts as imported packaging, how to classify and report it, and provides worked examples for common import scenarios.
What Makes You an Importer Under EPR?
Under the EPR regulations, you are performing an obligated activity as an importer if you bring packaged goods into the UK from outside the UK. This includes:
- Direct imports — You purchase goods from overseas suppliers and import them into the UK yourself
- Goods imported on your behalf — You use a freight forwarder, customs broker, or fulfilment partner to bring goods into the UK, but you are the owner of the goods at the point of import
- Goods imported from the EU, EEA, or rest of world — All non-UK origins count as imports (post-Brexit, EU goods entering the UK are imports)
The critical factor is ownership at the point of import. If you own the goods when they cross the UK border, you are the importer regardless of who physically transports them.
Importers vs Distributors
If a UK-based distributor imports goods and then sells them to UK retailers, the distributor is the importer for EPR purposes. The retailers who buy from the distributor are not importers — they are purchasing goods that are already on the UK market.
However, if a UK retailer places a direct order with an overseas factory and arranges shipping to the UK, the retailer is the importer.
Does the Importer Threshold Apply Separately?
No. The same thresholds apply to all obligated producers regardless of activity type. If your business meets the EPR thresholds — £1 million turnover and 25 or more tonnes of packaging across all activities — you are obligated. The 25-tonne threshold is measured across all your packaging, not just imported packaging. A business handling 15 tonnes of imported packaging and 12 tonnes of domestic packaging handles 27 tonnes total and is above the threshold.
What Counts as Imported Packaging?
As an importer, you are responsible for all packaging that enters the UK with your imported goods. This includes every layer of packaging, from the product packaging the consumer sees to the transit packaging that is removed and discarded at your warehouse.
Product Packaging (Enters the UK With the Product)
- Primary packaging — The packaging directly containing the product: bottles, boxes, bags, blister packs, jars, tubes
- Inner packaging — Components within the primary packaging: foam inserts, tissue paper, instruction leaflets (paper/card), desiccant packets
- Labels — Product labels, regulatory labels, barcodes (paper or plastic)
- Closures — Caps, lids, pumps, sprayers, seals (often a different material from the primary packaging)
Grouping Packaging
- Secondary packaging — Multipacks, bundled units, cardboard sleeves grouping multiple items, shrink-wrapped sets
Transit Packaging (Often Discarded Before Products Reach Shelves)
- Outer cases — Corrugated cardboard cases containing multiple units for shipping
- Pallet wrap — Stretch film around palletised goods
- Strapping — Plastic or metal bands securing cases to pallets
- Edge protectors — Cardboard or plastic corner pieces protecting goods on pallets
- Dividers — Cardboard sheets between layers of products on a pallet
- Timber pallets — Wooden pallets used to transport goods (if they enter the UK and are not returned to the sender)
- Dunnage — Inflatable bags, foam blocks, or other materials used to fill voids in containers and prevent movement during transit
- Container liners — Plastic or paper liners inside shipping containers
- Documentation sleeves — Plastic pouches containing shipping documents affixed to the outside of cases
All of this packaging is your EPR responsibility as the importer.
From-Country Data Requirements
One of the key additional requirements for importers is reporting the country of origin for imported packaging. This data helps DEFRA understand the origins of packaging entering the UK waste stream and is used for policy analysis and international reporting.
How to Report From-Country
In your RPD CSV submission, the from_country column requires the ISO 3166-1 alpha-2 country code for each row of imported packaging data. Common codes include:
| Country | Code | Country | Code | |
|---|---|---|---|---|
| China | CN | Germany | DE | |
| India | IN | France | FR | |
| Turkey | TR | Italy | IT | |
| Vietnam | VN | Spain | ES | |
| Bangladesh | BD | Netherlands | NL | |
| Thailand | TH | Poland | PL | |
| Taiwan | TW | United States | US | |
| South Korea | KR | Ireland | IE | |
| Japan | JP | Belgium | BE |
When From-Country Is Required
- Imported packaging: The from_country field must contain the ISO country code of the country where the packaging was when you imported it. This is typically the country of manufacture, but more precisely it is the country from which the goods were dispatched to the UK.
- Domestic packaging: For packaging sourced within the UK (not imported), leave the from_country field blank.
Multi-Source Imports
If you import the same product from multiple countries — for example, the same plastic bottle filled in both China and Germany — you need separate rows for each country of origin, with the weight split accordingly.
If your products pass through intermediary countries (e.g., manufactured in Vietnam, consolidated in a Chinese port, shipped to the UK), the from_country should reflect where the goods were dispatched from for the journey to the UK. In most cases, this is the country of manufacture, but for consolidated shipments, check with your freight forwarder.
How Import Packaging Is Classified
Import packaging uses the same classification system as domestic packaging:
Primary Packaging (P1)
The consumer-facing packaging that directly contains the product. For imported goods, this is the product packaging designed by the overseas manufacturer or brand.
Importer responsibility: You report the full weight of the primary packaging on imported goods. If you are the brand owner, this is unambiguously your obligation. If you are importing goods under another brand (e.g., as a distributor), you still report the packaging because you are the entity that brought it into the UK.
Secondary Packaging (P2)
Grouping packaging used to bundle or present products together. This may have been applied by the overseas manufacturer or at a consolidation point before export.
Importer responsibility: Report all secondary packaging that enters the UK with your goods. If you add further secondary packaging in the UK (e.g., creating multipacks from individually imported units), the UK-added packaging is a separate domestic obligation, not an import.
Tertiary Packaging (P3)
Transit packaging used to protect goods during shipping and distribution. For imports, this includes everything from the outer shipping cases to the pallet wrap and strapping.
Importer responsibility: This is where importers often have a larger packaging footprint than they expect. All transit packaging that enters the UK with your goods is your responsibility — even if it is removed and discarded at the port, your freight forwarder’s warehouse, or your own distribution centre before it ever reaches a customer.
Shipment Packaging (SP)
Packaging used to ship products directly to end consumers. For importers who sell direct-to-consumer, any packaging applied in the UK for consumer shipments (e-commerce boxes, mailer bags) is reported as shipment packaging under the domestic packing/filling activity.
However, if goods are imported in packaging that goes directly to the consumer (e.g., a product imported in a retail-ready box that ships straight from your warehouse to the customer), that packaging may be classified as both imported and shipment packaging.
Transit Packaging Obligations
Transit packaging is the area where importers are most likely to under-report. Many businesses focus on the product packaging — the box the consumer sees — and forget about the layers of transit packaging that were discarded at the warehouse.
Common Transit Packaging on Imports
| Item | Material | Typical Weight Range |
|---|---|---|
| Corrugated outer case (medium) | Paper and card | 300g - 800g per case |
| Pallet wrap (per pallet) | Plastic | 200g - 500g per pallet |
| Strapping (per pallet) | Plastic | 100g - 300g per pallet |
| Edge protectors (set of 4) | Paper and card | 200g - 600g per set |
| Timber pallet | Wood | 15 - 25 kg per pallet |
| Layer dividers (per layer) | Paper and card | 100g - 400g per sheet |
| Container liner | Plastic | 2 - 5 kg per liner |
| Dunnage bags (per container) | Plastic/paper | 500g - 2 kg each |
| Documentation sleeves | Plastic | 10g - 30g each |
Calculating Transit Packaging Weight
For many importers, the easiest approach is to calculate transit packaging at the shipment level:
- Determine packaging per shipping unit — How is one case packed? (weight of outer case + share of pallet wrap + share of strapping + share of edge protectors)
- Determine cases per pallet — How many cases fit on one pallet?
- Determine pallets per shipment — How many pallets per container or lorry load?
- Calculate annual volumes — How many shipments per year?
Example calculation:
A container shipment of imported food products:
- 20 pallets per container
- Each pallet: 1 timber pallet (20 kg wood), stretch wrap (350g plastic), 4 edge protectors (400g paper/card), 2 straps (200g plastic)
- 40 cases per pallet, each case weighing 500g (paper/card)
- 1 container liner (3 kg plastic)
- 4 dunnage bags (1 kg each, plastic)
Per container transit packaging:
- Wood (pallets): 20 x 20 kg = 400 kg
- Paper/card (cases): 20 x 40 x 0.5 kg = 400 kg
- Paper/card (edge protectors): 20 x 0.4 kg = 8 kg
- Plastic (wrap): 20 x 0.35 kg = 7 kg
- Plastic (strapping): 20 x 0.2 kg = 4 kg
- Plastic (liner): 3 kg
- Plastic (dunnage): 4 kg
- Total per container: 826 kg
If you import 30 containers per year: 30 x 826 kg = 24,780 kg (24.78 tonnes) of transit packaging alone — before counting any product packaging.
This illustrates why transit packaging is critical for importers. It can represent a substantial portion of your total packaging tonnage.
The Importer’s Full Packaging Footprint
An importer’s total EPR obligation is the sum of:
- Imported product packaging (P1) — all material layers
- Imported secondary packaging (P2) — grouping/multipack packaging
- Imported transit packaging (P3) — cases, pallets, wrap, strapping, etc.
- Domestic packaging added in the UK — any packaging you add after import (e.g., UK-specific labels, multipack wrappers, e-commerce shipping boxes, void fill)
Items 1-3 require from_country data in your RPD submission. Item 4 does not (it is domestic packaging).
Worked Example 1: Fashion Importer
A UK fashion brand importing garments from Bangladesh, Turkey, and China. Annual turnover £3 million.
Imported Product Packaging
| Item | Material | From Country | Annual Weight |
|---|---|---|---|
| Polybags (garments) | Plastic | BD, TR, CN | 3,000 kg |
| Cardboard hangtags | Paper and card | BD, TR, CN | 500 kg |
| Tissue paper wrapping | Paper and card | BD, TR, CN | 800 kg |
| Size sticker labels | Paper and card | BD, TR, CN | 100 kg |
Imported Transit Packaging
| Item | Material | From Country | Annual Weight |
|---|---|---|---|
| Corrugated outer cases | Paper and card | BD, TR, CN | 8,000 kg |
| Pallet wrap | Plastic | BD, TR, CN | 400 kg |
| Strapping | Plastic | BD, TR, CN | 200 kg |
| Edge protectors | Paper and card | BD, TR, CN | 300 kg |
UK-Added Packaging (Domestic)
| Item | Material | Annual Weight |
|---|---|---|
| E-commerce mailer bags | Plastic | 2,500 kg |
| E-commerce shipping boxes | Paper and card | 6,000 kg |
| Tissue paper (gift wrapping) | Paper and card | 1,000 kg |
| Packing tape | Plastic | 200 kg |
Total Packaging and Fees
| Material | Import Weight | Domestic Weight | Total | Fee | Cost |
|---|---|---|---|---|---|
| Plastic | 3,600 kg | 2,700 kg | 6,300 kg (6.3t) | £423 | £2,665 |
| Paper and card | 9,700 kg | 7,000 kg | 16,700 kg (16.7t) | £196 | £3,273 |
| Total | 13,300 kg | 9,700 kg | 23,000 kg (23t) | £5,938 |
Wait — this importer’s total tonnage is only 23 tonnes, below the 25-tonne threshold. They are not yet obligated. However, they are close enough that any business growth, or inclusion of additional packaging items they may have missed, could push them over the threshold. They should continue monitoring annually.
If we add the timber pallets they receive with their imports (which they initially forgot to count):
| Wood pallets | Wood | BD, TR, CN | 4,000 kg |
Revised total: 27 tonnes — now obligated as a small producer (turnover £1-2m band does not apply since turnover is £3m, but tonnage is 25-50t, so still small producer).
Revised fees including wood: 4 tonnes x £280 = £1,120. Total: £7,058.
This example shows why transit packaging, including pallets, is critical for importers near the threshold.
Worked Example 2: Food and Drink Importer
A UK distributor importing European wines, cheeses, and specialty foods. Annual turnover £6 million.
Imported Packaging
| Item | Material | From Countries | Annual Weight |
|---|---|---|---|
| Glass wine bottles | Glass | FR, IT, ES | 45,000 kg |
| Glass jars (preserves) | Glass | IT, FR, GR | 8,000 kg |
| Steel caps/lids | Steel | FR, IT, ES | 3,000 kg |
| Corks (natural, classified “Other”) | Other | PT | 500 kg |
| Paper labels | Paper and card | FR, IT, ES | 800 kg |
| Cardboard outer cases | Paper and card | FR, IT, ES | 12,000 kg |
| Plastic shrink wrap (cases) | Plastic | FR, IT | 600 kg |
| Wooden wine crates | Wood | FR | 2,000 kg |
| Timber pallets | Wood | FR, IT, ES | 6,000 kg |
| Pallet wrap | Plastic | FR, IT, ES | 500 kg |
| Cheese wax coating (Plastic) | Plastic | FR, NL | 200 kg |
| Vacuum-sealed plastic film | Plastic | FR, IT, NL | 1,500 kg |
UK-Added Packaging
| Item | Material | Annual Weight |
|---|---|---|
| UK-specific labels | Paper and card | 300 kg |
| Cardboard cases for UK distribution | Paper and card | 5,000 kg |
| Pallet wrap (UK distribution) | Plastic | 400 kg |
Total Packaging and Fees
| Material | Total Weight | Fee Rate | Annual Cost |
|---|---|---|---|
| Glass | 53,000 kg (53t) | £192 | £10,176 |
| Paper and card | 18,100 kg (18.1t) | £196 | £3,548 |
| Plastic | 3,200 kg (3.2t) | £423 | £1,354 |
| Steel | 3,000 kg (3t) | £259 | £777 |
| Wood | 8,000 kg (8t) | £280 | £2,240 |
| Other | 500 kg (0.5t) | £259 | £130 |
| Total | 85,800 kg (85.8t) | £18,225 |
This business is a large producer (turnover £6m, tonnage 85.8t) and must report every 6 months. Glass dominates both by weight and by cost, despite having the lowest per-tonne fee rate.
Worked Example 3: Electronics Importer
A UK seller of consumer electronics imported primarily from China and Taiwan. Annual turnover £4 million.
Imported Packaging
| Item | Material | From Countries | Annual Weight |
|---|---|---|---|
| Product boxes (printed card) | Paper and card | CN, TW | 15,000 kg |
| Plastic clamshell/blister packs | Plastic | CN | 4,000 kg |
| Expanded polystyrene inserts | Plastic | CN, TW | 3,000 kg |
| Polybag wrapping | Plastic | CN, TW | 1,500 kg |
| Paper instruction manuals | Paper and card | CN, TW | 2,000 kg |
| Corrugated outer cases | Paper and card | CN, TW | 10,000 kg |
| Pallet wrap | Plastic | CN, TW | 600 kg |
| Strapping | Plastic | CN, TW | 300 kg |
| Timber pallets | Wood | CN | 5,000 kg |
| Edge protectors (card) | Paper and card | CN, TW | 400 kg |
UK-Added Packaging
| Item | Material | Annual Weight |
|---|---|---|
| E-commerce shipping boxes | Paper and card | 8,000 kg |
| Void fill (paper) | Paper and card | 1,500 kg |
| Mailer bags | Plastic | 800 kg |
| Packing tape | Plastic | 300 kg |
Total Packaging and Fees
| Material | Total Weight | Fee Rate | Annual Cost |
|---|---|---|---|
| Paper and card | 36,900 kg (36.9t) | £196 | £7,232 |
| Plastic | 10,500 kg (10.5t) | £423 | £4,442 |
| Wood | 5,000 kg (5t) | £280 | £1,400 |
| Total | 52,400 kg (52.4t) | £13,074 |
Large producer (turnover £4m, tonnage 52.4t). Plastic packaging represents only 20% of weight but 34% of cost, demonstrating the disproportionate cost impact of high-fee materials.
Cost reduction opportunity: If expanded polystyrene inserts (3 tonnes) could be replaced with moulded paper/card alternatives: savings = (3 x £423) - (3 x £196) = £681 per year, plus future modulated fee savings as polystyrene may attract higher fees from 2026-2027.
Practical Steps for Importers
1. Map Your Supply Chain
Document every overseas supplier and the countries from which you import. You will need this for from_country reporting. Maintain a supplier register that includes country of dispatch.
2. Request Packaging Specifications from Suppliers
Ask every overseas supplier for detailed packaging specifications for every component — including transit packaging. Specifications should include material type and weight per unit. Many overseas manufacturers, particularly in Asia, can provide this data on request.
3. Audit Transit Packaging
Work with your freight forwarder or warehouse operator to identify and weigh all transit packaging that arrives with your imports. This is the most commonly missed category. Arrange for a sample shipment to be thoroughly documented — photograph and weigh every piece of transit packaging.
For guidance on measurement methods, see our packaging weighing guide.
4. Track Import Volumes
Maintain records of how many units of each product you import per country, per reporting period. This data, combined with per-unit packaging weights, gives you the total imported packaging weight.
5. Separate Import and Domestic Packaging
In your data management system, clearly distinguish between imported packaging (requiring from_country data) and domestic packaging (from_country left blank). This distinction is essential for accurate RPD CSV submissions.
6. Consider the Plastic Packaging Tax
If you import 10 or more tonnes of plastic packaging per year, you may also be liable for the Plastic Packaging Tax in addition to EPR. Check both sets of thresholds.
Common Questions from Importers
”If my overseas supplier is a large company, don’t they handle EPR?”
No. Overseas suppliers have no obligations under UK EPR — the scheme applies to businesses operating within the UK. As the importer, you assume EPR responsibility for all packaging that enters the UK with the goods you import. Your supplier’s size or environmental credentials are irrelevant.
”What about goods imported from the EU after Brexit?”
EU goods imported into the UK are treated the same as goods from any other country for EPR purposes. If you import packaged goods from France, Germany, or any EU member state, you are the importer and are responsible for all packaging on those goods. Report the from_country using the relevant ISO code (FR, DE, etc.).
”Do I report the shipping container as packaging?”
No. ISO shipping containers (the metal containers used on ships and lorries) are not considered packaging under EPR. They are reusable transport equipment. However, everything inside the container — pallets, cases, wrap, strapping, dunnage — is packaging.
”What about pallets that are returned to the supplier?”
If timber pallets are imported into the UK and then returned to the overseas supplier (reverse logistics), they may qualify as reusable packaging with reduced or different reporting obligations. However, most import pallets are not returned — they enter the UK waste stream. If your pallets are genuinely returned in a documented closed-loop system, consult the RPD guidance for reusable packaging rules.
”I use a fulfillment centre — who is the importer?”
The importer is the entity that owns the goods at the point of UK border crossing. If you contract with a fulfilment partner who imports goods on your behalf, but you own the goods, you are the importer. If the fulfilment partner buys the goods first and then sells them to you within the UK, they are the importer.
”Can I claim a deduction for packaging waste I export?”
If you export goods from the UK in packaging, you may be able to adjust your EPR data to exclude packaging that leaves the UK. However, the reporting requirements for exported packaging are specific — consult the RPD guidance for rules on deductions for exported packaging.
Simplify Import Packaging Compliance
Managing EPR compliance as an importer involves tracking packaging data across multiple countries, suppliers, and material types. Our platform is designed to handle this complexity — with built-in from-country tracking, material classification, and automated fee calculations for all eight material types.
You might also find our nation data reporting guide useful for understanding how to report the UK distribution of your imported goods. For a complete walkthrough, see our EPR compliance checklist, and learn about what counts as packaging to ensure you are capturing every component.
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