EPR for Distributors & Wholesalers
Distributors face EPR obligations on transit packaging and any repackaging activities in the supply chain.
Distributors and wholesalers occupy a specific position in the EPR supply chain. Your obligations depend on what packaging activities you perform:
- Transit packaging — if you repackage goods for distribution (new boxes, pallet wrap, void fill), that packaging is your obligation
- Own-brand goods — if you sell own-brand/private-label products, you are responsible for all packaging on those products
- Packing/filling — if you break bulk and repack into smaller quantities, the new packaging is your obligation
A common scenario: you receive palletised goods from a manufacturer and break them down into smaller shipments for retailers. The transit packaging you add (new boxes, dividers, wrap) is your EPR obligation. The original product packaging remains the manufacturer's obligation.
Cash-and-carry operators have additional considerations around carrier bags and shopping bags provided to trade customers.
Your Key Obligations
- Track transit packaging added during distribution
- Report repackaging activities separately
- Include pallet wrap, strapping, and void fill
- Report own-brand product packaging if applicable
- Submit data to DEFRA via the RPD portal
- Pay EPR fees on packaging you add to the supply chain
Common Questions
Am I responsible for packaging that passes through my warehouse?
Not automatically. If goods pass through your warehouse in their original packaging without any repacking, the original producer retains responsibility. You are only responsible for packaging YOU add or change.
What if I break bulk and repack?
If you break bulk shipments into smaller quantities and add new packaging (boxes, dividers, wrapping), that new packaging is your EPR obligation. The original product packaging remains the manufacturer's responsibility.
Do I report pallet wrap?
Yes, if you apply the pallet wrap. Stretch wrap, strapping, and edge boards you use for outbound shipments are your transit packaging obligation.
What about cash-and-carry bags?
Shopping bags provided to trade customers at cash-and-carry outlets are packaging. Track usage and report under the appropriate material category.
Ready to get your EPR compliance sorted?
Start your free trial today. Built specifically for UK businesses.
Start Your Free Trial