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. The DEFRA guidance on preparing for EPR provides further detail on how packaging is defined for regulatory purposes.
Industry-Specific Packaging Items Often Overlooked
Different sectors tend to miss different packaging items. Here is a sector-by-sector guide to commonly overlooked packaging.
Food and Drink
- Absorbent pads in meat trays — these are packaging components (typically plastic or mixed fibre)
- Twist ties and clips on bread bags — small but reportable, usually plastic or metal
- Desiccant sachets inside food packaging — the sachet itself is packaging, even if the desiccant inside is not
- Price stickers applied to fruit or vegetables — each one is a packaging component
- Tray liners in bakery or deli products — paper or plastic liners count
Beauty and Cosmetics
- Pump mechanisms — typically a combination of plastic and metal, requiring component-level reporting
- Droppers and applicators — the glass pipette and rubber bulb are separate material components
- Protective inserts — moulded plastic or card inserts holding products in place within an outer box
- Travel pouches — fabric or plastic pouches provided with beauty products are packaging
- Cellophane overwrap on boxed products — easy to forget as it is often the first thing discarded
E-commerce
- Stickers sealing tissue paper — small adhesive labels are packaging
- String or ribbon on gift-wrapped items — decorative elements serving a presentation function
- QR code cards and instruction leaflets placed inside parcels — classified as packaging
- Branded stickers on the outside of mailer bags — packaging components
- Fragile labels applied to shipping boxes — adhesive labels are packaging
Manufacturing and Wholesale
- Interleaving sheets — paper or plastic sheets placed between stacked items
- Dunnage bags — inflatable bags used to fill voids in containers
- VCI paper (Vapour Corrosion Inhibitor) — anti-rust paper wrapping metal components
- Silica gel sachets in electronics packaging — the sachet material is packaging
- Cable ties used to secure products to backing cards — plastic ties are packaging
Conducting a Thorough Packaging Audit
If you are unsure whether you are capturing all your packaging, a structured audit will identify gaps. The DEFRA guidance on preparing for EPR recommends a comprehensive approach.
Step 1: Walk the Process
Physically follow a product from receipt (or manufacture) through to dispatch. At each stage, note every packaging material the product touches:
- Inbound: What packaging do products arrive in from suppliers? If you import, all inbound packaging on imported goods is your responsibility
- Storage: Is any packaging added or removed during warehousing?
- Packing: What packaging do you add when preparing orders for dispatch?
- Dispatch: What packaging is used for shipping — boxes, tape, labels, void fill?
Step 2: Examine a Sample of Finished Parcels
Take 10 completed orders across your product range and unpack them completely. List every single item, no matter how small. Weigh each component individually using a precision scale (accurate to 0.1g for small items). This reveals items that your current records may be missing.
Step 3: Check Your Incoming Packaging
If you receive products from suppliers in packaging that you then pass on to consumers (such as branded product boxes), that packaging is your EPR responsibility. Request packaging specifications from every supplier and cross-reference against your packaging register.
Step 4: Review Ancillary and Service Packaging
Do you provide carrier bags at point of sale? Gift wrapping? Coffee cups at your office reception that are available to visitors? Any packaging provided at the point of consumption could be your responsibility if you supply it.
Step 5: Calculate Total Tonnage
Multiply per-unit weights by annual volumes to calculate your total packaging tonnage by material type. Our fee calculator guide then shows you the financial impact.
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. For sector-specific packaging guidance, see our packaging hub with dedicated guides for food and drink, beauty, and e-commerce businesses. To understand the fees associated with each material type, see our fee breakdown guide.
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