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regulation

Packer/Filler

A producer that physically places goods into packaging. Under EPR, packers and fillers must report the packaging they use and may share obligations with brand owners depending on the arrangement.

A packer/filler is an activity type under pEPR that describes a business which physically packs or fills products into packaging. This includes contract packers who package goods on behalf of brand owners.

Packer/fillers have specific obligations:

  • Report packaging they fill or pack through RPD
  • Must distinguish between packaging they own and packaging belonging to the brand owner
  • Are responsible for secondary and transit packaging they add

The relationship between packer/fillers and brand owners is important for avoiding double-counting. Where a contract packer uses packaging supplied by the brand owner, the brand owner reports it. Where the packer/filler supplies their own packaging, they report it. Clear contractual agreements should define these responsibilities. Packer/fillers operating above the obligated thresholds must register with a compliance scheme.

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