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How-To 6 min read

How to Estimate Packaging Tonnage for EPR

EPR Compliance Team

Table of Contents


Key Takeaways

  • You need a tonnage estimate to determine whether you are obligated under EPR (the 25-tonne threshold) and whether you are a small or large producer (50-tonne threshold).
  • Three estimation methods: top-down (procurement spend), bottom-up (product-level weights), and industry benchmarks.
  • Procurement data is the fastest route — your packaging purchase orders already contain the volume data you need.
  • Do not over-engineer your initial estimate — a rough figure within 20% is sufficient to determine your obligation status.
  • Once you know you are obligated, invest in accurate measurement for formal reporting.

Why Estimation Matters

Before committing to full EPR compliance, you need to know whether you are obligated. The key threshold is 25 tonnes of packaging per year. If you are below this (and below £1M turnover), you are exempt.

Many businesses are unsure whether they reach 25 tonnes. A quick estimate can answer this question without the expense of a full packaging audit.

For full threshold details, see who needs to register for packaging EPR.

Quick Estimation Methods

Method 1: Packaging Procurement Spend

Look at your packaging purchase orders for the past 12 months:

  1. List all packaging purchased — boxes, bags, film, labels, pallets, void fill
  2. Note the quantities — number of units or weight ordered
  3. Convert to tonnes — your supplier’s invoices often show weight

Example:

  • 50,000 corrugated boxes at 400g each = 20 tonnes
  • 100,000 polybags at 5g each = 0.5 tonnes
  • 200 rolls of stretch wrap at 15kg each = 3 tonnes
  • Total = 23.5 tonnes (close to the threshold — investigate further)

Method 2: Dispatch-Based Estimate

Count outgoing shipments and estimate average packaging per shipment:

  1. How many orders do you dispatch per year?
  2. What is the average packaging weight per order?

Example: 30,000 orders/year x 900g average packaging = 27 tonnes

Method 3: Product-Based Estimate

For each major product, estimate the packaging weight:

  1. Pick up 5-10 products from your range
  2. Remove and weigh the packaging (even a kitchen scale works for a rough estimate)
  3. Multiply by annual sales volume

Bottom-Up Calculation

For a more precise estimate:

Step 1: Group Your Products

Categorise your products by packaging type:

GroupExample ProductsPackaging Type
ASmall boxed itemsCardboard box + polybag
BLarge itemsCorrugated box + foam inserts
CBagged itemsPlastic bag only
DLiquidsPlastic bottle + cap + label

Step 2: Weigh Sample Packaging from Each Group

GroupSample Packaging WeightNumber of Samples
A85g5 (averaged)
B1,200g3 (averaged)
C12g5 (averaged)
D35g5 (averaged)

Step 3: Multiply by Annual Sales

GroupAverage WeightAnnual UnitsAnnual Tonnage
A85g100,0008.5
B1,200g10,00012.0
C12g200,0002.4
D35g80,0002.8
Total25.7 tonnes

Step 4: Add Transit Packaging

Do not forget:

  • Pallet wrap: Estimate rolls used x weight per roll
  • Outer cases: Used for shipping groups of products
  • Pallets: If you send one-trip pallets, each is 20-25 kg

Transit packaging typically adds 10-30% to your product packaging tonnage.

Using Procurement Data

Your packaging procurement records are a goldmine for estimation:

What to FindWhere to Look
Boxes purchasedPackaging supplier invoices
Bags and film purchasedPackaging supplier invoices
Pallets purchasedPallet supplier invoices
Stretch wrap purchasedPackaging/logistics invoices
Labels and tapeStationery/packaging budgets

Most packaging suppliers can provide a total weight summary for all items you purchased in a year.

Industry Rules of Thumb

If you cannot get precise data, these benchmarks may help:

Business TypeTypical Packaging Tonnage
Small retailer (100 orders/day)10-30 tonnes
Medium manufacturer (£5M turnover)30-100 tonnes
Food manufacturer (£10M turnover)100-500 tonnes
E-commerce retailer (1,000 orders/day)50-150 tonnes
Drinks manufacturer (£5M turnover)200-1,000+ tonnes

These are very rough guides — your actual tonnage depends on your specific products and packaging.

From Estimate to Accuracy

Once your estimate shows you are obligated (over 25 tonnes), transition from estimation to accurate measurement:

  1. Conduct a formal packaging audit — see how to audit packaging weights
  2. Set up ongoing data collection — see how to set up packaging data collection
  3. Register with a compliance scheme or directly with the Environment Agency
  4. Submit accurate data through DEFRA’s RPD portal

What If You Are Close to 25 Tonnes?

If your estimate is near the threshold (20-30 tonnes), you should:

  1. Conduct a more thorough estimate to confirm your position
  2. Include ALL packaging — transit packaging is often the item that pushes businesses over
  3. Consider growth — if you are at 22 tonnes now but growing, you may exceed 25 tonnes next year
  4. Monitor regularly — re-estimate annually

Getting Started

  1. Pull your packaging purchase orders for the last 12 months
  2. List and estimate using one of the methods above
  3. Determine your obligation status — above or below 25 tonnes
  4. If obligated, plan your next steps using the EPR compliance checklist

Use the EPR fee calculator with your estimates and visit our pricing page.

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