EPR for Importers
As an importer, you take on EPR responsibility for ALL packaging on products you bring into the UK — including factory-applied packaging.
Importers have one of the broadest EPR obligations. When you import finished goods into the UK, you become responsible for all packaging on those products — including packaging applied by overseas manufacturers that you had no involvement in choosing.
This means you need accurate packaging specifications from your overseas suppliers. For each imported product, you must know:
- Every packaging component (primary, secondary, transit)
- The material of each component
- The weight of each component
Getting this information from overseas suppliers can be challenging. We recommend creating a Packaging Specification Request document for your supply chain, asking for gram-weights per packaging component per material for every product you import.
If you import goods and then repackage them (e.g., decanting bulk products into retail packaging), you have dual obligations: importer obligations for the original packaging, and packing/filling obligations for the new packaging you apply.
Read our detailed guide on EPR for importers for step-by-step compliance instructions.
Your Key Obligations
- Obtain packaging specifications from ALL overseas suppliers
- Track every packaging component on imported goods by material and weight
- Report all imported packaging to DEFRA via RPD portal
- If repackaging, report both imported and new packaging separately
- Pay EPR fees on the full weight of packaging entering the UK
- Keep supplier packaging specifications on file for 7 years
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Common Questions
Am I responsible for packaging I did not choose?
Yes. As the importer, you take on EPR responsibility for ALL packaging on imported products — even factory-applied polybags, foam inserts, and shrink wrap that you had no involvement in specifying.
How do I get packaging weights from overseas suppliers?
Send a Packaging Specification Request to each supplier asking for gram-weights per component per material. Many suppliers already have this data for their own compliance. Our platform includes a supplier request template.
What if my supplier cannot provide weights?
If supplier data is unavailable, you must weigh sample products yourself. Order a sample shipment and weigh each packaging component individually. Use these weights for all units from that supplier until weights change.
Do I report packaging on goods I re-export?
If you import goods into the UK and then re-export them without selling them in the UK, the packaging is not UK-obligated. Keep clear records of import/re-export flows.
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