Table of Contents
- Why Online Sellers Are Affected by EPR
- Marketplace Sellers: Amazon, eBay, Etsy
- What Packaging Counts for Online Sellers?
- Third-Party Fulfilment and 3PL Packaging
- Returns Packaging: An Often-Missed Obligation
- How to Track Packaging as an Online Seller
- Estimating Your Fees as an Online Seller
- Getting Compliant: Next Steps
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. Understanding what counts as packaging is the first step.
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. The DEFRA registration checker can help confirm whether your business meets the thresholds.
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
Packaging Optimisation Strategies for Online Sellers
EPR fees create a direct financial incentive to reduce and optimise your packaging. Here are practical strategies that pay for themselves through lower fees.
Right-Sizing Your Shipping Boxes
Most online sellers use a limited range of box sizes, often resulting in small products shipped in oversized boxes filled with void material. Every gram of void fill is reportable packaging that attracts EPR fees.
The fix: Invest in a wider range of box sizes or consider on-demand box-making machines for high-volume operations. A business shipping 1,000 orders per day that reduces average box weight by 50g saves 18.25 tonnes of cardboard per year — worth £3,577 in avoided EPR fees at the paper/card rate of £196/tonne.
Switching to Paper-Based Alternatives
Where product protection allows, switching from plastic to paper-based packaging materials can significantly reduce EPR costs:
| Packaging Switch | Plastic Fee (£423/t) | Paper Fee (£196/t) | Saving per Tonne |
|---|---|---|---|
| Poly mailers to paper mailers | £423 | £196 | £227 |
| Plastic air pillows to paper void fill | £423 | £196 | £227 |
| Plastic tape to paper tape | £423 | £196 | £227 |
| Bubble wrap to corrugated wrap | £423 | £196 | £227 |
For a business using 5 tonnes of plastic packaging that could be replaced with paper alternatives, the annual saving is £1,135 in EPR fees alone — before accounting for the additional savings when fee modulation takes effect from 2026-2027.
Eliminating Unnecessary Packaging Layers
Review every item in your packaging lineup and ask whether it is genuinely necessary:
- Tissue paper wrapping — is it protecting the product or purely aesthetic? If aesthetic, consider eliminating it
- Thank you cards and flyers — do they drive measurable revenue? If not, they are adding to your reportable tonnage
- Double-boxing — if your product’s own packaging is robust enough, does it need a separate shipping box?
- Excessive tape — one strip of tape sealing a box is reportable packaging; three strips cost three times as much
The waste hierarchy principle of prevention — eliminating packaging at source — offers the greatest EPR cost savings because it removes tonnage entirely from your obligation.
Multi-Platform Sellers: Consolidating EPR Data
If you sell across multiple platforms — your own website, Amazon, eBay, Etsy, TikTok Shop — consolidating your EPR data requires a structured approach.
Step 1: Map Packaging by Platform
Different platforms may require different packaging. Amazon FBA has specific packaging requirements. Your own website shipments may use branded packaging. Marketplace orders may use plain packaging. Document the packaging configuration for each platform.
Step 2: Track Volumes by Platform
Export order volumes from each platform and multiply by the per-order packaging weight for that platform’s packaging configuration. This gives you a platform-by-platform packaging breakdown.
Step 3: Consolidate into a Single Report
Your RPD submission consolidates all packaging across all platforms into a single report. Our platform allows you to enter data by channel and automatically aggregates it for DEFRA reporting.
Step 4: Adjust for Platform-Specific Obligations
Remember that for Amazon FBA orders, Amazon handles the shipping packaging obligation. Only your product packaging (sent to Amazon’s fulfilment centres) is your responsibility. For self-fulfilled orders on any platform, all packaging is yours.
The DEFRA EPR guidance provides further detail on how obligations are allocated when multiple parties are involved in the packaging and fulfilment chain.
Explore our e-commerce sector guide for more packaging-specific guidance, or browse the EPR glossary for definitions of key terms. If you also sell on Amazon, see our Amazon seller EPR guide. View our pricing plans to find the right platform for your business.
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