Cleaning Products Packaging EPR Compliance
Spray bottles, refill pouches, and trigger heads — cleaning product packaging has specific EPR reporting requirements.
Cleaning Products EPR: What You Need to Know
Cleaning product companies face a unique EPR challenge with trigger spray heads — these multi-component mechanisms containing plastic, metal springs, and sometimes glass tubes are classified as packaging rather than product. Getting the material classification right is important for accurate reporting.
The growing trend towards refill pouches introduces another complexity. While refill pouches use less plastic per dose than rigid bottles (good for sustainability), multi-layer laminates containing aluminium are classified as fibre-based composite at £461/tonne — the highest fee rate. Mono-material refill pouches attract only the plastic rate of £423/tonne.
For 2025-2026, the base fees per tonne are: plastic at £423 (bottles, caps, pouches), paper and card at £196 (cartons, labels), and steel at £44 (aerosol cans). Cleaning product companies using concentrated refill formats can significantly reduce total packaging weight and therefore EPR fees.
See also our guides for chemical products and e-commerce packaging.
Common Cleaning Products Packaging
These are the key packaging types you need to track and report for EPR compliance in the cleaning products sector.
HDPE Bottles
Plastic bottles for liquid cleaners, detergents, and disinfectants. Include caps and trigger spray heads as separate components.
Trigger Spray Heads
PP/PE trigger mechanisms with metal springs. Multi-material component requiring material split reporting.
Refill Pouches
Flexible laminate pouches for concentrated refills. Often multi-material — report each layer separately.
Outer Cartons
Card boxes and multipacks for retail display. Report under paper/card material category.
Labels
Paper or plastic labels on bottles and containers. Separate packaging component for EPR reporting.
Shrink Wrap Multipacks
LDPE shrink wrap holding multipacks of bottles together. Secondary packaging under EPR.
What You Need to Do
As a cleaning products 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 (bottles, caps, trigger heads, pouches)
- Report labels as separate packaging components
- Split multi-material items into individual materials
- Include shrink wrap and multipack packaging
- 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 Cleaning Products Compliance Mistakes
Avoid these frequent pitfalls that catch out cleaning products businesses every year.
Forgetting trigger spray heads
Trigger spray mechanisms are packaging, not product. They contain PP, PE, and metal springs — report as multi-material or under the dominant material.
Misclassifying refill pouches
Multi-layer laminate pouches may be fibre-based composite (highest fee rate) if they contain aluminium. Plastic-only laminates are just plastic.
Not reporting labels separately
Labels on bottles are a separate packaging component. If the label is paper and the bottle is HDPE, report each under its respective material.
Ignoring promotional packaging
Promotional bundles, gift sets, and seasonal packaging are all EPR-obligated even if temporary.
Cleaning Products EPR Questions
Common questions about packaging EPR for cleaning products businesses.
Are trigger spray heads packaging or product?
Trigger spray heads are classified as packaging under EPR. They enable the dispensing of the product from its container. Report the dominant material (usually PP) and note any metal components.
How do I report concentrated refill pouches?
If the pouch is mono-material plastic, report under plastic. If it contains aluminium layers, it may be classified as fibre-based composite (highest fee rate). Check your pouch specifications for exact material layers.
Do I report the label on a bottle separately?
Yes, if the label is a different material from the bottle. A paper label on an HDPE bottle should be reported as paper/card packaging separately from the plastic bottle.
Are aerosol cans covered by EPR?
Yes. Steel or aluminium aerosol cans (for air fresheners, furniture polish, etc.) are packaging under EPR. Report the can, the cap, and any over-cap as separate components by material.
Ready to get your cleaning products business compliant?
Join hundreds of UK businesses using EPR Compliance to meet their packaging obligations effortlessly.
Start Your Free Trial