Table of Contents
- DEFRA’s Definition of Packaging
- The Three Functions of Packaging
- What Clearly Is Packaging
- What Is Not Packaging
- Borderline Items: The Grey Areas
- Component Packaging and Multi-Material Items
- Service Packaging and Packaging at the Point of Sale
- How to Decide If Something Is Packaging
DEFRA’s Definition of Packaging
Under the UK’s Extended Producer Responsibility regulations, packaging is defined as any material used to contain, protect, handle, deliver, or present goods — from the point of production to the point of consumption by the end user.
This definition is deliberately broad. It captures far more than just the obvious boxes and bottles. Understanding exactly what falls within this definition is essential for accurate EPR reporting, because missing packaging items means under-reporting, which can lead to enforcement action.
The definition covers packaging at all stages of the supply chain, including:
- Packaging on products sold to consumers (sales packaging)
- Packaging used to group products together (grouped packaging)
- Packaging used during transport and distribution (transit packaging)
- Packaging used to ship orders directly to consumers (shipment packaging)
The Three Functions of Packaging
DEFRA applies three tests to determine if an item is packaging. An item is packaging if it serves any of these functions:
1. Containment
The item holds or contains a product. A bottle containing shampoo, a box containing cereal, or a bag containing sweets all serve a containment function.
2. Protection
The item protects a product during storage, handling, transport, or sale. Bubble wrap around a vase, a corrugated case around glass bottles, or a polybag around a garment all serve a protective function.
3. Presentation
The item presents or displays a product for sale. A blister pack displaying a toy, a gift box presenting cosmetics, or a windowed carton showing biscuits all serve a presentation function.
If an item serves any one of these functions in relation to a product, it is almost certainly packaging under EPR regulations.
What Clearly Is Packaging
These items are unambiguously packaging and must be included in your EPR data:
Primary (Sales) Packaging
- Bottles, jars, tubs, pots (glass, plastic, metal)
- Boxes, cartons, sleeves (cardboard, paperboard)
- Bags, pouches, sachets (plastic, paper)
- Tubes (cosmetics, food)
- Cans and tins (aluminium, steel)
- Blister packs and clamshells
- Wrapping film (cling film, flow-wrap)
Secondary (Grouped) Packaging
- Multipack bands and shrink wrap
- Display trays and cases
- Outer boxes for gift sets
- Cardboard trays for tins or jars
Tertiary (Transit) Packaging
- Corrugated shipping cases
- Pallets (wooden and plastic)
- Pallet wrap and stretch film
- Strapping and edge protectors
Shipment Packaging
- Shipping boxes for e-commerce orders
- Mailer bags (poly and paper)
- Void fill materials
- Bubble wrap and protective inserts
Component Packaging
- Bottle caps and closures
- Pump mechanisms and spray nozzles
- Labels (paper and plastic)
- Tamper-evident seals
- Packing tape
What Is Not Packaging
These items are not classified as packaging:
- The product itself — a plastic storage box sold as a product is not packaging
- Parts of a product — a teabag is part of the product, not packaging (though the outer box is packaging)
- Items with no packaging function — a coat hanger in a wardrobe is not packaging (but a hanger shipped with a garment for retail display may be)
- Shipping containers — large freight containers used for international transport are not packaging
- Reusable items designed for lifetime use — a metal lunchbox sold as a product is not packaging
The key distinction is whether the item is integral to the product (not packaging) or serves to contain, protect, or present the product (packaging).
Borderline Items: The Grey Areas
Several items sit in a grey area that catches businesses out:
Hangers
A coat hanger sold as a standalone product is not packaging. But a hanger included with a garment for retail display or shipping is packaging. Fashion brands must report the weight of hangers shipped with garments.
Labels and Tags
Paper labels, plastic sleeve labels, and swing tags are all packaging components. Even a small sticker on an apple is packaging. These items are lightweight individually but can add up to significant tonnage across high-volume product lines.
Stickers and Seals
Tamper-evident seals, freshness stickers, and promotional labels on products are all packaging. They serve a containment or protection function.
Thank You Cards and Inserts
Printed cards, flyers, and promotional inserts placed inside e-commerce parcels are classified as packaging because they are placed within the packaging system. Online sellers must include them in their reported data.
Ribbons and Ties
Ribbons, bows, and ties used to present products (particularly in gift packaging) are packaging. If it forms part of the product presentation, it counts.
Wooden Crates and Pallets
Wooden crates used to transport goods are transit packaging. Pallets are also packaging. However, if you hire or loan reusable pallets, they are reported under the hiring/loaning obligated activity.
Component Packaging and Multi-Material Items
Many packaging items are made from multiple materials. Under EPR regulations, each material component must be reported separately by weight:
Example: A Glass Perfume Bottle
| Component | Material | Weight |
|---|---|---|
| Glass bottle | Glass | 150g |
| Plastic spray pump | Plastic | 12g |
| Metal ferrule | Aluminium | 3g |
| Paper label | Paper/card | 2g |
| Outer carton | Paper/card | 45g |
| Cellophane overwrap | Plastic | 4g |
That is six separate packaging components across four material types — all requiring individual reporting lines in your RPD submission.
For beauty businesses and other sectors with complex packaging, component-level tracking is essential for accurate compliance.
Service Packaging and Packaging at the Point of Sale
Service packaging is packaging filled or assembled at the point of sale. Examples include:
- Carrier bags provided at checkout
- Paper bags for bakery items
- Takeaway food containers
- Gift wrapping offered in store
If your business provides service packaging to customers, those items are your EPR responsibility. The obligation falls on the business that supplies the empty packaging or fills it at the point of sale.
How to Decide If Something Is Packaging
When you encounter an item you are unsure about, apply this three-step test:
Step 1: Does It Contain, Protect, or Present a Product?
If yes, it is almost certainly packaging. If no, consider whether it serves any ancillary packaging function (such as keeping a product clean or facilitating its handling).
Step 2: Would the Product Be Sold Without It?
If removing the item would mean the product cannot be sold, stored, or transported safely, the item is packaging. A bottle is needed to sell liquid products. A shipping box is needed to transport e-commerce orders.
Step 3: Is It Integral to the Product or Separate?
If the item is consumed or used up alongside the product, it may be part of the product (not packaging). If it is discarded after the product is removed, it is packaging.
When in doubt, classify the item as packaging and report it. Under-reporting carries compliance risk, whereas over-reporting only means slightly higher fees — a much safer position.
Explore our EPR glossary for definitions of key terms, check your obligation status with our free compliance checker, or review the full packaging categories breakdown.
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