How to Classify Packaging Activities for EPR

Table of Contents

• Why Activity Classification Matters
• The Six Activity Types
• How to Determine Your Activities
• Multiple Activities
• Common Scenarios
• Getting It Right
• Key Takeaways

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Key Takeaways

• Your EPR obligation depends on which packaging activities you perform — different activities create different levels of obligation.
• Most businesses perform multiple activities — you may be a manufacturer for some products and an importer for others.
• The “first to place on the UK market” principle determines who has the primary obligation for each piece of packaging.
• Importers bear the heaviest obligation as they are responsible for all packaging on goods entering the UK.
• Getting your activity classification wrong can lead to under-reporting (and penalties) or over-reporting (and unnecessary costs).

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Why Activity Classification Matters

Under UK packaging EPR, your specific obligations depend on which activities you perform in relation to packaging. The system is designed so that each piece of packaging is reported by one party — the business best placed to account for it.

If you classify your activities incorrectly, you may:

• Report packaging that is actually someone else’s obligation (over-reporting)
• Fail to report packaging that is your obligation (under-reporting and regulatory risk)
• Pay incorrect fees

Understanding your activities is a foundational step in EPR compliance.

For EPR basics, see what packaging EPR is.

The Six Activity Types

1. Manufacturer

You make packaging or convert packaging materials into packaging

Examples:

• You produce corrugated boxes from cardboard sheets
• You print and fold retail cartons from blank board
• You extrude and blow-mould plastic bottles

Obligation: You are responsible for the packaging you manufacture.

2. Packer/Filler

You put products into packaging

Examples:

• You fill bottles with drinks in your factory
• You pack food into trays and seal with film
• You box your products for retail sale

Obligation: You are responsible for the packaging you fill/pack with product.

3. Importer

You bring packaged goods or empty packaging into the UK from abroad

Examples:

• You import finished products from China/Europe in their packaging
• You import empty packaging materials (bags, boxes) for use in the UK
• You buy from overseas suppliers who ship directly to the UK

Obligation: You are responsible for ALL packaging on the imported goods — both the product packaging and the transit packaging. This is typically the heaviest obligation.

4. Seller (Brand Owner)

You sell goods under your own brand name

Examples:

• Supermarket own-brand products
• Private-label products manufactured by someone else but sold under your brand
• Products you commission from a contract manufacturer

Obligation: You are responsible for the packaging on goods sold under your brand, even if someone else physically made the packaging.

5. Distributor

You supply packaged goods to other businesses or consumers without changing the packaging

Examples:

• Wholesalers distributing branded products to retailers
• Online retailers dispatching branded goods
• Cash-and-carry operators

Obligation: Generally limited — the brand owner or importer typically holds the primary obligation. However, if you add packaging (e.g., e-commerce shipping boxes), you are responsible for that additional packaging.

6. Service Provider

You supply packaging to be filled at the point of sale

Examples:

• Supplying takeaway cups, bags, and containers to cafes
• Providing carrier bags to retailers

Obligation: Responsibility depends on whether you fill the packaging (your obligation) or supply it empty (supplier’s obligation). Cafes and restaurants that fill cups and bags are typically responsible as packer/fillers.

How to Determine Your Activities

Decision Flow

For each product you handle, ask:

1. Did you make the packaging? → Manufacturer
2. Did you fill/pack the product into the packaging? → Packer/Filler
3. Did you import the packaged product? → Importer
4. Is it sold under your brand name? → Seller/Brand Owner
5. Did you just distribute/resell it? → Distributor

You may answer “yes” to multiple questions — that is normal.

Multiple Activities

Most businesses perform multiple activities:

Activity Combination	Example
Importer + Seller	You import goods from abroad and sell them under your brand
Manufacturer + Packer	You make bottles AND fill them with product
Importer + Distributor	You import goods and distribute to UK retailers
Packer + Seller	You pack products (made by others) under your brand

When you perform multiple activities on the same packaging, you typically report under the highest obligation activity (usually importer or manufacturer).

Common Scenarios

Scenario 1: UK Retailer Selling Branded Goods

You buy branded products from UK-based suppliers and sell them in your shops. Your activity: Distributor Your obligation: Minimal for the product packaging (the brand owner reports it). But you ARE responsible for any packaging you add (carrier bags, gift wrap, e-commerce boxes).

Scenario 2: Online Retailer Importing Directly

You buy products from overseas manufacturers and sell them online. Your activity: Importer + Distributor Your obligation: ALL packaging on imported goods PLUS any e-commerce packaging you add.

Scenario 3: Supermarket Own-Brand

You commission products made by contract manufacturers, sold under your supermarket brand. Your activity: Seller (Brand Owner) Your obligation: All packaging on your own-brand products.

Scenario 4: Food Manufacturer

You make food products, pack them into your own packaging, and sell to retailers. Your activities: Packer/Filler + Seller Your obligation: All packaging you create and fill.

Scenario 5: Coffee Shop Chain

You buy cups, lids, and bags from suppliers, then fill them at point of sale. Your activity: Packer/Filler (service packaging) Your obligation: The service packaging you fill — cups, bags, food containers.

For more on service packaging, see EPR for bakeries and cafes.

Getting It Right

Common Mistakes

1. Retailers claiming they have no obligation — if you import goods or sell own-brand products, you do
2. Importers ignoring transit packaging — you are responsible for ALL packaging on imported goods, including the outer cases and pallet wrap
3. Brand owners assuming the manufacturer reports — if it is your brand, it is your obligation
4. Distributors not tracking their added packaging — e-commerce boxes, carrier bags, and gift wrap are your obligation

Documentation

Record your activity classification for each product line. This forms part of your compliance evidence:

Product Line	Activity	Obligation
Own-brand widgets	Importer + Seller	All packaging
Distributed Brand X items	Distributor	E-commerce packaging only
In-store carrier bags	Service provider	Carrier bags

For reporting guidance, see how to report packaging data to DEFRA and use our EPR compliance checklist.

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