How to Track Imported Packaging for EPR

Table of Contents

• Why Import Tracking Matters
• What You Must Track
• Getting Data from Overseas Suppliers
• Practical Tracking Systems
• Handling Complex Import Scenarios
• Key Takeaways

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Key Takeaways

• Importers are responsible for ALL packaging on goods entering the UK — product packaging, transit packaging, and any packaging added by freight forwarders.
• Request packaging specifications from overseas suppliers in writing — most established manufacturers can provide this data.
• Set up a standardised data request template for all new suppliers to ensure consistent information.
• Customs import data provides the volume figures you need to calculate total annual tonnage.
• Missing import packaging from your EPR data is one of the most common compliance failures found in audits.

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Why Import Tracking Matters

Under UK packaging EPR, the importer is the first person to place packaging on the UK market. This makes you responsible for every piece of packaging on the imported goods — from the individual product wrapping to the stretch wrap on the pallet.

Many UK businesses are primarily importers (buying finished goods from overseas manufacturers), making import packaging tracking a critical compliance requirement.

For full importer obligations, see our EPR for importers guide.

What You Must Track

Product Packaging

Every component of the product packaging applied by the overseas manufacturer:

• Boxes, bags, pouches, bottles
• Labels, stickers, seals, caps
• Inserts, trays, dividers
• Instruction leaflets

Transit Packaging

All packaging used to ship goods from the manufacturer to the UK:

• Corrugated outer cases
• Stretch wrap (pallet wrap)
• Strapping (plastic or steel)
• Wooden pallets or crates
• Edge protectors
• Dunnage and void fill

Added Packaging

Any packaging added during the supply chain:

• Packaging applied by freight forwarders
• Re-palletisation packaging
• Customs wrapping or labelling

Getting Data from Overseas Suppliers

The Challenge

Overseas suppliers may not understand UK EPR requirements and may be unfamiliar with providing packaging weight data. You need a clear, simple approach.

Template Request

Send suppliers a standardised request for each product:

Product: [Product name/SKU]
Please provide the following packaging information:

1. Primary packaging (touches the product):
   - Component description
   - Material type (plastic PP, cardboard, etc.)
   - Weight per unit (grams)

2. Inner packaging (inside the shipping case):
   - Component description
   - Material type
   - Weight per unit

3. Shipping case:
   - Material type (corrugated cardboard)
   - Weight per case (grams)
   - Units per case

4. Pallet packaging:
   - Pallet type and weight
   - Stretch wrap weight per pallet
   - Strapping weight per pallet
   - Units per pallet

Tips for Getting Responses

1. Make it a purchase order requirement — suppliers respond to commercial requests
2. Provide clear examples — show them what you need with a filled-in template
3. Ask for the data in their language if needed — then translate
4. Start with your highest-volume suppliers — they have the most EPR impact
5. Set a deadline — and follow up

If Suppliers Cannot Provide Data

If a supplier cannot provide packaging specifications:

1. Weigh incoming shipments — unpack one order and weigh each packaging component
2. Use the sample weight for all orders of the same product
3. Document your methodology — record what you weighed and when

For weighing methodology, see how to audit packaging weights.

Practical Tracking Systems

Simple System (Spreadsheet)

Create a spreadsheet with:

Supplier	Product	Component	Material	Weight (g)	Units Imported	Annual Tonnage
Supplier A	Widget	Box	Card	120	50,000	6.0
Supplier A	Widget	Bag	PE film	5	50,000	0.25
Supplier A	Widget	Label	Paper	2	50,000	0.1

Link the “Units Imported” column to your customs/purchase data for automatic updates.

Intermediate System (ERP-Linked)

Add packaging specifications to your product master data in your ERP:

1. Create a packaging BOM for each imported product
2. Link to purchase order data for import volumes
3. Run reports for EPR submission periods

Data Sources for Import Volumes

• Customs declarations — precise volumes for each shipment
• Purchase orders — units ordered from each supplier
• Goods received notes — units actually received
• Shipping documents — bill of lading, packing lists

Handling Complex Import Scenarios

Multiple Suppliers for the Same Product

Different suppliers may use different packaging. Maintain separate packaging specs for each supplier and weight-average based on actual purchase volumes.

Re-Exported Goods

If you import goods and then export some of them (without changing the packaging), the exported portion may be excluded from your UK EPR obligation. Document your re-exports clearly.

Drop-Shipping

If an overseas supplier ships directly to your UK customer (drop-ship), you are still the importer and responsible for the packaging if the goods enter the UK under your import arrangements.

Third-Party Logistics

If a 3PL receives your imports, breaks pallets, and re-packs for UK distribution, you need to track:

• The original import packaging (your obligation)
• Any additional packaging added by the 3PL (may be their obligation — check your contract)

Getting Started

1. List all your import suppliers and products
2. Send packaging data requests to each supplier
3. Weigh samples where supplier data is unavailable
4. Link to import volume data from customs/purchasing
5. Calculate tonnage per material type

Use the EPR fee calculator to estimate costs and visit our pricing page for compliance tools. See also how to report packaging data to DEFRA.