Table of Contents
- Why Packaging Categories Matter for EPR
- Primary Packaging
- Secondary Packaging
- Tertiary (Transit) Packaging
- Shipment Packaging
- How to Classify Your Packaging
- Common Classification Mistakes
- Reporting Categories in DEFRA’s RPD Portal
Why Packaging Categories Matter for EPR
When you report your packaging data to DEFRA via the RPD portal, you must classify every packaging item into one of four categories as defined in the official EPR guidance: primary, secondary, tertiary (transit), or shipment. Getting the classification wrong can lead to rejected submissions, inaccurate fee calculations, or enforcement action.
Each category represents a different role in the supply chain, and DEFRA requires this breakdown to understand how packaging waste flows through the UK economy — from manufacturer to consumer to waste stream. The category affects how your packaging is reported, though EPR fees are calculated based on material type rather than category.
Understanding these categories is essential for accurate EPR reporting. Let us walk through each one with real-world examples.
Primary Packaging
Primary packaging is the packaging that directly contains or holds the product and is typically the packaging the end consumer sees and handles. It is the first layer of packaging that comes into contact with the product itself.
Examples of Primary Packaging
- A plastic bottle holding shampoo or a soft drink
- A cardboard cereal box that directly contains the cereal bag
- A polybag wrapping an individual garment
- A glass jar containing jam or sauce
- A blister pack holding tablets or cosmetics
- A tin can containing baked beans
- A tube of toothpaste or hand cream
Key Characteristics
Primary packaging is almost always consumer-facing — the end user interacts with it when they purchase and use the product. It is designed to protect, contain, and often market the product.
The label on a primary packaging item (such as a paper label on a glass bottle) is itself a separate packaging component and must be reported by its own material type.
Secondary Packaging
Secondary packaging is used to group multiple primary-packaged products together. It is sometimes called grouped packaging or multipack packaging. Secondary packaging is typically removed before the product reaches the end consumer, though not always.
Examples of Secondary Packaging
- A cardboard tray holding six tins of soup
- A shrink-wrap band bundling four bottles of water together
- A display box containing twelve lipsticks on a retail shelf
- A cardboard sleeve around a multipack of crisps
- An outer carton holding a gift set of beauty products
Key Characteristics
Secondary packaging serves a logistical or marketing purpose — it groups individual products for retail display, wholesale distribution, or consumer convenience. It may or may not be seen by the end consumer.
The critical distinction from primary packaging is that secondary packaging does not directly contain the product. The product is already in its primary packaging; secondary packaging groups those primary units together.
Tertiary (Transit) Packaging
Tertiary packaging, also known as transit packaging, is used to protect products during transportation and distribution. It is used in the business-to-business supply chain and is almost never seen by end consumers.
Examples of Tertiary Packaging
- Corrugated shipping cases used to transport products from warehouse to retailer
- Pallets (wooden or plastic) used to stack and move goods
- Pallet wrap (stretch film) securing items to a pallet
- Edge protectors and corner boards
- Foam inserts protecting fragile goods during transit
- Strapping used to secure boxes on pallets
Key Characteristics
Transit packaging exists purely to facilitate safe transportation through the supply chain. It is typically removed at the receiving point (warehouse, distribution centre, or retail store) and disposed of through commercial waste streams.
Because transit packaging enters commercial waste streams rather than household waste, it may attract different treatment under EPR. However, you must still report it accurately by material type and weight.
Shipment Packaging
Shipment packaging is a category specifically relevant to e-commerce and direct-to-consumer businesses. It covers packaging used to ship individual orders directly to consumers.
Examples of Shipment Packaging
- Cardboard shipping boxes used for online orders
- Poly mailer bags used to send clothing or soft goods
- Bubble wrap or void fill protecting items during delivery
- Packing tape used to seal shipping boxes
- Returns bags included inside the parcel
Key Characteristics
Shipment packaging is distinct from transit packaging because it reaches the end consumer. When you ship a product directly to a customer’s door, the shipping box and all protective materials inside it are shipment packaging.
This category has grown significantly with the rise of e-commerce. If you are an online seller, shipment packaging likely represents a major proportion of your total packaging obligation.
How to Classify Your Packaging
Follow this decision tree to classify any packaging item:
- Does it directly contain or touch the product? → Primary packaging
- Does it group multiple primary-packaged products together? → Secondary packaging
- Is it used to transport goods through the B2B supply chain? → Tertiary (transit) packaging
- Is it used to ship individual orders directly to end consumers? → Shipment packaging
A Worked Example
Consider a fashion brand shipping a jumper:
| Packaging Item | Material | Category |
|---|---|---|
| Polybag wrapping the jumper | Plastic | Primary |
| Swing tag on the jumper | Paper/card | Primary |
| Tissue paper wrapping | Paper/card | Primary |
| Branded mailer bag | Plastic | Shipment |
| Thank you card insert | Paper/card | Shipment |
| Packing tape | Plastic | Shipment |
Each item is a separate line in your RPD report, reported by material type, weight, and packaging category.
Common Classification Mistakes
Confusing Shipment and Transit Packaging
If a box goes from your warehouse to a retailer’s store, it is transit packaging. If the same box goes from your warehouse to a consumer’s home, it is shipment packaging. The destination determines the category.
Treating Secondary Packaging as Primary
A cardboard sleeve around a multipack of yoghurt pots is secondary packaging, not primary. The yoghurt pots themselves are primary packaging.
Forgetting Component Packaging
A glass perfume bottle with a plastic spray pump, a paper label, and a cardboard outer box involves four separate packaging components across three material types and potentially two categories (the bottle, pump, and label are primary; the outer box may be primary or secondary depending on context).
Ignoring Returns Packaging
If you include a returns bag in your e-commerce shipments, it counts as shipment packaging that you have placed on the market — even if the customer never uses it.
Reporting Categories in DEFRA’s RPD Portal
When you submit your packaging data through the RPD system, each line of your CSV report must include a packaging category field. DEFRA uses these categories to:
- Calculate the proportion of your packaging entering household versus commercial waste streams (see DEFRA’s RPD guidance for details)
- Determine appropriate fee rates (household packaging typically attracts higher fees)
- Assess the environmental impact of different packaging flows
Our platform automatically handles category classification. When you enter a packaging item, we guide you through selecting the correct category based on how you use it. Your exported DEFRA-ready reports include the correct category codes for direct upload.
Why Category Classification Affects Your Compliance
Getting packaging categories right is not just an administrative requirement — it has practical consequences for your EPR compliance.
Fee Allocation and Local Authority Funding
DEFRA uses category data to understand the split between household and commercial waste streams. Primary and shipment packaging overwhelmingly ends up in household waste (collected by local authorities from consumers), while tertiary packaging enters commercial waste streams (collected from businesses). Secondary packaging may enter either stream depending on the context.
This distinction matters because EPR fees are designed to fund local authority collection of household packaging waste. If your category classifications are wrong — for example, reporting shipment packaging as tertiary — it distorts the data DEFRA uses to calculate how much funding local authorities should receive. Persistent misclassification could trigger an audit from the Environment Agency.
Sector-Specific Category Challenges
Different industries face different classification challenges:
Food and drink manufacturers often have complex category chains. A glass jar of sauce (primary) sits in a cardboard tray (secondary) which is wrapped in shrink film (secondary), placed into a corrugated shipping case (tertiary), and stacked on a pallet with stretch wrap (tertiary). That is five packaging items across three categories from a single product.
Subscription box businesses must distinguish between product packaging inside the box (primary) and the subscription box itself plus inserts (shipment). The outer branded box is shipment packaging even though it serves a marketing function — the category is determined by its role in the supply chain, not its design intent.
Businesses selling through both retail and DTC channels may use the same packaging classified differently depending on the route to market. A branded gift box sent to a retailer for shelf display is secondary packaging. The same gift box shipped directly to a consumer who ordered it online is shipment packaging. The destination determines the category.
Multi-Material Packaging: Reporting by Component
Many packaging items are made from multiple materials. Under EPR, you must break these down into individual components and report each one separately. This is one of the most time-consuming but important aspects of accurate reporting.
Step-by-Step Component Breakdown
For each multi-material packaging item:
- Identify every physical component — the main container, any closures, labels, seals, overwraps, and inserts
- Determine the material type for each component using DEFRA’s eight material categories
- Weigh each component separately (or use supplier spec sheets for per-component weights)
- Assign the same packaging category to all components of a single packaging item — if the bottle is primary, the cap and label are also primary
- Report each component as a separate line in your RPD submission
Common Multi-Material Examples
| Product | Component | Material | Category |
|---|---|---|---|
| Wine bottle | Glass bottle | Glass | Primary |
| Wine bottle | Cork/screw cap | Wood/Aluminium | Primary |
| Wine bottle | Paper label (front) | Paper/card | Primary |
| Wine bottle | Paper label (back) | Paper/card | Primary |
| Wine bottle | Foil capsule | Aluminium | Primary |
| Cereal box | Cardboard outer | Paper/card | Primary |
| Cereal box | Plastic inner bag | Plastic | Primary |
| Takeaway meal | Plastic tray | Plastic | Primary |
| Takeaway meal | Film lid | Plastic | Primary |
| Takeaway meal | Card sleeve | Paper/card | Secondary |
This component-level reporting is essential for accurate fee calculations, because each material attracts a different per-tonne rate. A seemingly simple product like a perfume bottle might generate five or six separate reporting lines.
When Components Cannot Be Separated
Some packaging items have components that are permanently bonded together — such as a paper cup with a plastic lining or a metalised film pouch. These items should be reported under the material that makes up the majority of the weight. If the paper cup is 80% paper and 20% plastic by weight, report it as paper and card. However, if it has a distinct plastic or wax lining that makes it a composite, it may fall under fibre-based composite (the highest-fee category at £461/tonne). Check DEFRA’s material classification guidance carefully for borderline items.
Need help classifying your packaging? Check our EPR glossary for detailed term definitions, or use our free compliance checker to see if your business is obligated. For guidance on accurately weighing your packaging, see our measurement guide, and explore our packaging hub for sector-specific advice.
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