Chemical Products Packaging EPR Compliance
UN-rated drums, IBCs, and hazmat containers must meet both safety regulations and EPR obligations.
Chemicals & Hazardous EPR: What You Need to Know
Chemical companies face the dual burden of hazmat packaging regulations (ADR/UN ratings) alongside EPR obligations. A common misconception is that packaging required by safety regulations is exempt from EPR — it is not. All packaging, regardless of why it is required, must be reported under EPR.
The biggest reporting challenge is multi-material IBCs. A standard 1000-litre composite IBC contains an HDPE inner bottle, a galvanised steel cage, a wooden pallet base, and paper/card labels — four materials that must all be reported separately. Our platform includes IBC-specific templates to simplify this.
For 2025-2026, the base fees per tonne are: steel at £44 (drums, cages — the lowest rate), plastic at £423 (HDPE bottles, drums), wood at £280 (pallet bases), and paper and card at £196 (labels). Chemical companies using steel drums benefit from the very low steel EPR fee rate.
See also our guides for construction and automotive packaging.
Common Chemicals & Hazardous Packaging
These are the key packaging types you need to track and report for EPR compliance in the chemicals & hazardous sector.
Steel Drums
UN-rated steel drums (205-litre) for industrial chemicals. Report under steel material. Include bungs and closures.
HDPE Drums
Plastic drums for corrosive and non-corrosive chemicals. Report under plastic. Include caps and seals.
IBCs (Intermediate Bulk Containers)
1000-litre composite containers with steel cage and PE inner bottle. Multi-material requiring split reporting.
Jerrycans
HDPE or steel jerrycans (5-25 litres) for chemicals and solvents. Include caps and safety vents as packaging.
Labels & Hazard Diamonds
GHS hazard labels, product labels, and safety data. Paper or plastic labels are packaging under EPR.
Pallet Packaging
Stretch wrap, strapping, and edge boards for palletised drums and containers. Transit packaging under EPR.
What You Need to Do
As a chemicals & hazardous business handling packaging, you have specific EPR obligations under the UK's Extended Producer Responsibility scheme. Here is what you need to track and report to stay compliant.
- Track all primary packaging (drums, jerrycans, IBCs, bottles)
- Split multi-material containers into individual materials
- Distinguish between single-trip and reusable packaging
- Include labels and safety markings as packaging components
- Submit data to DEFRA via the RPD portal
- Pay EPR fees based on total packaging weight by material type
Do you need to comply?
You are obligated if your business:
- • Has an annual turnover exceeding £1 million
- • Handles more than 25 tonnes of packaging per year
- • Performs any of the obligated activities (manufacturing, importing, selling, hiring)
Even small producers below these thresholds must register as small producers under the Report Packaging Data (RPD) portal.
Common Chemicals & Hazardous Compliance Mistakes
Avoid these frequent pitfalls that catch out chemicals & hazardous businesses every year.
IBC material split errors
A composite IBC has an HDPE inner bottle (plastic), a steel cage (steel), a wooden pallet base (wood), and a cardboard label (paper/card). All four materials must be reported separately.
Confusing reusable and single-trip packaging
Reusable IBCs and drums in closed-loop systems may qualify for exemption. Single-trip packaging does not — ensure your records distinguish between them.
Not reporting safety-mandated packaging
UN-rated packaging required by ADR regulations still counts as packaging under EPR. You cannot exclude it because it is mandatory for safety.
Missing small container packaging
Small sample bottles, sachets, and promotional packs are easy to overlook but they are packaging obligations.
Chemicals & Hazardous EPR Questions
Common questions about packaging EPR for chemicals & hazardous businesses.
Are UN-rated drums exempt from EPR?
No. Drums and containers required to be UN-rated for hazardous goods transport are still packaging under EPR. Safety-mandated packaging does not receive an exemption from EPR obligations.
How do I report a composite IBC?
Split into materials: HDPE inner bottle (plastic), steel cage (steel), wooden pallet base (wood), cardboard labels (paper/card). Weigh each component and report under its respective material category.
Are reusable IBCs exempt from EPR?
IBCs in a documented closed-loop reuse system may qualify for exemption. You must keep records proving the reuse — number of trips, return rates, and end-of-life disposal. Single-trip IBCs are not exempt.
Do GHS hazard labels count as packaging?
Yes. GHS hazard diamonds, product labels, and any other labelling on chemical containers are packaging components. Report by material (paper or plastic).
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