Key Takeaways

Separable components are reported individually by their own material type — this usually results in lower total fees.
Non-separable composites are reported as one item classified by the predominant material — and typically attract the highest fees.
Correctly identifying whether components are separable is the most important classification decision for multi-material packaging.
A cardboard box with a pop-out plastic window is separable (two items); a PE-lined coffee cup is composite (one item).
Misclassifying separable items as composites is one of the most expensive errors in EPR reporting.

The Multi-Material Challenge

Most packaging in the real world contains more than one material. A bottle has a cap, a box has a label, a pouch has a zipper. Under EPR, each material attracts a different fee rate, so how you classify multi-material packaging directly affects your costs.

The critical question is always: can the consumer easily separate the materials, or are they bonded together?

For the full multi-material classification guide, see multi-material packaging and EPR.

Classification Rules

Rule 1: Separable Components

If a consumer can easily separate the materials (by hand, without tools), report each component as its own material.

Examples:

Plastic cap on a glass jar → glass + plastic (two entries)
Paper label on a plastic bottle → plastic + paper (two entries)
Cardboard sleeve on a plastic pot → cardboard + plastic (two entries)

Rule 2: Non-Separable Composites

If the materials are bonded and cannot be separated, report the whole item as one entry classified by the predominant material by weight.

Examples:

Tetra Pak carton (card/PE/aluminium) → fibre-based composite (one entry)
PE-lined paper cup → fibre-based composite (one entry)
Metalised plastic film → plastic composite (one entry)

Rule 3: Predominantly Paper = Fibre Composite

If a non-separable composite is predominantly paper or card by weight, it is classified as “fibre-based composite” at £461/tonne — the highest rate.

Step-by-Step Classification Process

Step 1: List Every Component

For each packaging item, identify all materials present.

Example — A retail food product:

Corrugated outer box (cardboard)
Printed inner carton (cardboard with PE coating)
Plastic tray (PP)
Film lid (PET/PE laminate)
Paper label on outer box

Step 2: Test Separability

For each pair of materials, ask: can the consumer easily separate them?

Component Pair	Separable?	Reasoning
Outer box + label	Yes	Label peels off
Inner carton (coated)	No	PE coating is bonded to card
Plastic tray + film lid	Yes	Film peels off tray

Step 3: Classify Each Item

Item	Classification	Material
Outer box	Corrugated card	Paper/card
Label	Paper	Paper
Inner carton	Fibre-based composite	Composite
Plastic tray	PP plastic	Plastic
Film lid	Plastic (or composite if multi-layer)	Plastic

Step 4: Weigh Each Classified Item

Use the methodology described below.

Weighing Multi-Material Items

For Separable Components

Separate the components physically
Weigh each component on a precision scale
Record the weight against the component’s material classification

For Non-Separable Composites

Weigh the complete item — do not try to separate layers
Record the total weight against the composite classification
You do NOT need to determine the weight of individual layers

Practical Tips

Use a razor blade to carefully separate bonded components if you need to determine which material is predominant
Request layer specifications from your packaging supplier — they will know the weight breakdown
Weigh 3-5 samples and average the results to account for manufacturing variation
Record your methodology — this is your evidence for audits

For detailed weighing guidance, see how to audit packaging weights.

Reporting in the RPD Portal

When submitting data through DEFRA’s Report Packaging Data portal:

Separable Components

Create separate data entries for each component:

Entry 1: Outer box — Material: Paper/card — Weight: 120g — Category: Primary
Entry 2: Plastic cap — Material: Plastic (PP) — Weight: 5g — Category: Primary
Entry 3: Paper label — Material: Paper — Weight: 2g — Category: Primary

Non-Separable Composites

Create a single entry for the composite:

Entry 1: Coated carton — Material: Fibre-based composite — Weight: 45g — Category: Primary

Common Data Entry Errors

Reporting separable items as composites — inflates fees
Splitting composite items into separate materials — underestimates the composite impact
Forgetting small components — caps, seals, labels all need entries
Using nominal weights instead of actual weights — verify with physical measurement

For full reporting details, see how to report packaging data to DEFRA and the DEFRA RPD CSV format guide.

Cost Impact Examples

Getting multi-material classification right has significant cost implications:

Example: 10 Tonnes of Cardboard Box with Plastic Window

If Classified As…	Fee	Cost
Separable (9t card + 1t plastic)	£215 x 9 + £380 x 1	£2,315
Composite (10t fibre composite)	£461 x 10	£4,610

Difference: £2,295 — nearly double.

Multiply this across your full product range, and correct classification can save tens of thousands of pounds.

Getting Started

Audit your multi-material packaging across your product range
Apply the separability test to each item
Classify and weigh accordingly
Update your packaging register with correct classifications
Re-calculate your EPR fees — you may find significant savings

Use the EPR fee calculator and visit our pricing page.

How to Handle Multi-Material Packaging in EPR Reporting

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