EPR for Manufacturers
As a manufacturer, you perform multiple obligated activities — from raw material packaging to finished goods. Understand your full EPR scope.
Manufacturers typically perform several obligated activities under EPR: manufacturing packaging (if you make the packaging itself), packing/filling (putting products into packaging), and potentially selling (if you sell direct). Each activity carries separate reporting obligations.
Your EPR obligations cover all packaging you use or produce:
- Primary packaging — packaging directly containing your products
- Secondary packaging — grouped packaging (multipacks, display outers)
- Transit packaging — packaging used for shipping and distribution
For UK manufacturers, the key challenge is tracking packaging across production lines. Each product may use different packaging materials and weights. Building a Packaging Bill of Materials (BOM) for each product or product family is essential for accurate reporting.
Manufacturers exporting products should note that packaging on goods sold outside the UK is not subject to UK EPR. However, packaging on goods sold within the UK or imported back into the UK is fully obligated.
If you manufacture packaging materials (e.g., you are a corrugated box maker or a bottle manufacturer), you have obligations as a packaging manufacturer — a specific activity type with its own reporting requirements.
Your Key Obligations
- Track all packaging used across production lines by material and weight
- Build Packaging BOMs for each product or product family
- Report primary, secondary, and transit packaging separately
- Exclude packaging on exported goods from UK EPR calculations
- Submit data to DEFRA via the RPD portal by reporting deadlines
- Pay EPR fees based on total UK-obligated packaging weight
Sector-Specific Guides
Electronics
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Pharmaceutical & Healthcare
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Drinks & Beverages
EPR compliance for UK drinks manufacturers, importers, and retailers. Track bottles, cans, cartons, ...
Common Questions
Do I report packaging on products I export?
No. Packaging on goods exported from the UK is not subject to UK EPR. Only packaging on goods sold or distributed within the UK is obligated. Keep clear records separating domestic and export packaging volumes.
What if I manufacture the packaging itself?
If you manufacture packaging materials (boxes, bottles, bags), you have obligations as a packaging manufacturer — a specific activity type. You report the tonnage of packaging you manufacture and sell to other businesses.
How do I track packaging across multiple production lines?
Build a Packaging Bill of Materials (BOM) for each product. List every packaging component, its material, and weight. Multiply by production volumes. Our platform automates this calculation.
Am I responsible for packaging my suppliers send me?
Generally no — your suppliers are responsible for the packaging they use to ship materials to you. You are responsible for packaging YOU apply to YOUR products and ship to YOUR customers.
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