Unfilled Packaging
Empty packaging that is supplied by one business to another for filling. The obligation for unfilled packaging depends on whether it is branded (brand owner reports) or unbranded (filler reports).
Unfilled packaging refers to empty packaging that is supplied along the supply chain before being filled with product. Understanding who reports unfilled packaging is important for avoiding gaps or double-counting.
Reporting rules for unfilled packaging:
- Branded unfilled packaging — the brand owner reports it when filled
- Unbranded unfilled packaging — the packer/filler reports it when they fill it
- Imported unfilled packaging — the importer reports it on import
Common scenarios include: a glass jar manufacturer supplying jars to a food producer (the food company as brand owner reports the jars), or a contract packer receiving unbranded pouches and filling them (the packer reports). Clear contractual arrangements between packaging suppliers and fillers should specify reporting responsibilities. Unfilled packaging that is exported from the UK is not reportable under UK pEPR — only packaging placed on the UK market counts.
Related Terms
Brand Owner
A producer category under EPR referring to the business whose brand appears on p...
Packer/Filler
A producer that physically places goods into packaging. Under EPR, packers and f...
Importer
A business that brings packaged goods or empty packaging into the UK from abroad...
Packaging Component
An individual element that forms part of a complete packaging item, such as caps...
Placed on Market
The point at which packaging or a packaged product is first made available in th...
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