EPR for Online Retailers
Online retailers face EPR obligations on fulfilment packaging — boxes, mailers, void fill, and everything you use to ship to customers.
Online retailers have EPR obligations on all packaging they supply to customers. This includes:
- Fulfilment packaging — shipping boxes, mailer bags, padded envelopes
- Void fill — bubble wrap, air pillows, paper fill, packing peanuts
- Branded elements — tissue paper, stickers, branded tape, thank-you cards
- Product packaging — if you sell own-brand products, all primary packaging
If you sell third-party branded products, the brand owner is typically responsible for the product packaging. But YOU are responsible for all additional packaging you add during fulfilment.
For Amazon sellers and marketplace traders: if you use FBA (Fulfilment by Amazon), Amazon handles some packaging obligations. But if you self-fulfil, the fulfilment packaging is entirely your EPR responsibility.
Returns present a common question. You report the packaging you originally supplied. If a customer returns an item, you do not re-report the packaging — your original outbound report covers it.
See our Amazon seller EPR guide and e-commerce packaging guide for detailed compliance help.
Your Key Obligations
- Track all fulfilment packaging by material and weight
- Report void fill, branded tissue, tape, and inserts
- Distinguish between own-brand and third-party product packaging
- Track packaging by channel if using multiple marketplaces
- Submit data to DEFRA via the RPD portal
- Pay EPR fees based on total fulfilment packaging weight
Common Questions
Am I responsible for product packaging on items I resell?
If you sell third-party branded products, the brand owner is responsible for their product packaging. You are responsible for fulfilment packaging you add — boxes, mailers, void fill, branded elements.
What about Amazon FBA packaging?
If you use Fulfilment by Amazon, Amazon handles the fulfilment packaging. You are still responsible for any packaging you apply before sending inventory to Amazon warehouses (e.g., prep packaging, poly bags, labels).
Do I report packaging on returned items?
No. Report the packaging you supply with each outbound order. Returns do not create additional reporting obligations. The original shipment packaging is already covered.
Is branded tissue paper and tape packaging?
Yes. Branded tissue paper, custom tape, stickers, thank-you cards, and any other branded inserts are all packaging. Track their weight and include in your EPR calculations.
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