Why Online Sellers Are Affected by EPR

If you sell products online and ship them to customers in the UK, you are performing an obligated activity under EPR regulations. Specifically, you are packing or filling goods into packaging — which is one of the five activities that trigger EPR obligations.

This means that if your business meets both the turnover threshold (£1 million or more) and the tonnage threshold (25 or more tonnes of packaging per year), you must register, report your packaging data, and pay EPR fees.

For many online sellers, EPR compliance is entirely new territory. Unlike traditional retail, where packaging responsibilities may be shared across the supply chain, e-commerce businesses are typically responsible for every piece of packaging that leaves their warehouse — from the shipping box to the void fill to the packing tape.

Not sure if you are obligated? Use our free compliance checker to find out in 60 seconds.

Marketplace Sellers: Amazon, eBay, Etsy

One of the most common questions from online sellers is: “I sell on a marketplace — am I still responsible for EPR?”

The answer depends on who handles fulfilment:

Self-Fulfilled Orders

If you fulfil orders yourself — packing products in your own warehouse, home, or office and shipping them via a courier — you are the obligated producer for all shipping packaging you use. This applies regardless of whether the sale was made through Amazon, eBay, Etsy, your own website, or any other channel.

Fulfilment by Amazon (FBA)

If you use Amazon’s FBA service, Amazon handles the shipping packaging (boxes, tape, void fill). Amazon takes on certain EPR obligations for the shipping packaging they use. However, any product packaging you supply to Amazon (such as polybags around garments, branded boxes, or labels) remains your responsibility.

Other Marketplace Fulfilment Programmes

For other marketplace fulfilment services, check the specific terms. In general, the party that physically packs and ships the product bears responsibility for the shipping packaging, while product packaging responsibility stays with the brand owner or importer.

For Amazon-specific guidance, read our dedicated guide.

What Packaging Counts for Online Sellers?

Every piece of packaging involved in getting your product from warehouse to customer counts. This includes items many online sellers overlook:

Shipping Packaging (Most Obvious)

Cardboard shipping boxes — your largest packaging component by weight
Poly mailer bags — plastic or paper mailing bags for soft goods
Padded envelopes — jiffy bags or bubble-lined mailers

Protective Packaging (Often Forgotten)

Bubble wrap — sheets or rolls used to wrap fragile items
Air pillows — inflated plastic cushions filling empty space
Packing peanuts — loose fill protective material
Shredded paper or kraft paper — paper-based void fill
Foam inserts — moulded or cut foam protectors

Product Packaging (Your Responsibility If You Brand It)

Product boxes — branded boxes that contain the product
Polybags — plastic bags wrapping individual items
Tissue paper — used to wrap products attractively
Swing tags and labels — card or plastic tags on products

Ancillary Packaging (Easily Missed)

Packing tape — plastic or paper tape sealing boxes
Thank you cards — printed inserts included in orders
Promotional flyers — marketing materials in parcels
Returns bags or labels — pre-paid returns packaging included in shipments

Every one of these items must be tracked by material type and packaging category for your EPR submission.

Third-Party Fulfilment and 3PL Packaging

If you outsource fulfilment to a third-party logistics (3PL) provider, the packaging they use on your behalf is still your EPR responsibility. The obligation follows the brand owner, not the party physically packing the goods.

This means you need detailed packaging specifications from your 3PL partner:

Exact box sizes and weights for each box type they use for your orders
Void fill type and quantity — what protective materials they use and how much per order
Tape type and weight — plastic or paper, and estimated usage per box
Mailer bag specifications — material, size, and weight if used

Many online sellers discover that their 3PL uses significantly more packaging than expected. A fulfilment centre optimised for speed may use oversized boxes or excessive void fill. Understanding exactly what packaging is used on your orders is essential for accurate reporting.

Top tip: Request a quarterly packaging summary from your 3PL showing total quantities used for your orders, broken down by packaging type and material.

Returns Packaging: An Often-Missed Obligation

If you include a returns bag, returns label pouch, or pre-paid envelope inside your shipments, these items count as packaging you have placed on the market. Even if the customer never uses them, you must include their weight in your reported totals.

This catches out many e-commerce businesses. A returns bag weighing 15 grams, included in 200,000 orders per year, adds 3 tonnes to your packaging obligation — with EPR fees of £1,269 if it is plastic (at £423/tonne) or £588 if it is paper (at £196/tonne).

Consider whether you need to include returns packaging in every order, or whether you could offer downloadable returns labels instead — reducing both packaging waste and EPR costs.

How to Track Packaging as an Online Seller

E-commerce businesses have an advantage: most packaging decisions are standardised and repeatable. Here is a practical tracking approach:

Step 1: Audit Your Packaging Types

List every packaging item used in your operation. For each item, record:

Material type (plastic, paper/card, etc.)
Weight per unit (from supplier spec sheets or sample weighing)
Packaging category (primary, shipment, etc.)

Step 2: Track Order Volumes

You already know how many orders you ship. Multiply order volumes by packaging quantities per order to calculate total packaging weight.

Step 3: Account for Variations

Different products may use different packaging. A fragile item ships in a box with bubble wrap; a t-shirt ships in a poly mailer. If you have multiple packaging configurations, track each separately.

Step 4: Include Product Packaging

Do not forget the product packaging that goes inside the shipping packaging — polybags, tissue paper, branded boxes, tags, and inserts all count.

Our platform’s guided data entry system is designed specifically for this workflow. Enter your packaging types once, then update volumes each reporting period.

Estimating Your Fees as an Online Seller

Here is a realistic example for a mid-sized online retailer:

Business profile: 300 orders per day, mixed products, self-fulfilled

Packaging Item	Material	Per-Order Weight	Annual Weight	Fee Rate	Annual Fee
Cardboard boxes	Paper/card	250g	27.4 tonnes	£196	£5,370
Poly mailer bags	Plastic	30g	3.3 tonnes	£423	£1,396
Air pillows	Plastic	15g	1.6 tonnes	£423	£677
Packing tape	Plastic	5g	0.5 tonnes	£423	£212
Thank you cards	Paper/card	8g	0.9 tonnes	£196	£176
Returns bags	Plastic	15g	1.6 tonnes	£423	£677

Total estimated annual EPR fees: £8,508

Use our EPR fees calculator guide for more worked examples.

Getting Compliant: Next Steps

Check your obligation status — use our free compliance checker
Audit your packaging — list every packaging type, material, and weight
Determine your producer size — are you a small or large producer?
Set up tracking — start recording packaging data by material type and category
Submit on time — know your reporting deadlines
Generate your report — our platform exports DEFRA-ready RPD reports

Explore our e-commerce sector guide for more packaging-specific guidance, or browse the EPR glossary for definitions of key terms.

Start your free trial and see how easy EPR compliance can be for online sellers.

Packaging EPR for Online Sellers: What UK E-commerce Businesses Must Know

Table of Contents