E-commerce EPR Compliance

E-commerce is one of the fastest-growing sectors affected by UK packaging EPR, and for many online sellers, EPR compliance is entirely new territory. Unlike traditional retail where packaging is often handled by suppliers or distributors, e-commerce businesses are directly responsible for every piece of packaging that leaves their warehouse — from the shipping box down to the packing tape.

The first thing every e-commerce seller needs to understand is this: if you pack and ship products to consumers, you are performing an obligated activity (packing/filling). This means if your business meets the turnover and tonnage thresholds (£1 million turnover AND 25+ tonnes of packaging), you must register, report, and pay EPR fees.

For marketplace sellers on Amazon, eBay, Etsy, and similar platforms, the rules depend on who handles fulfilment. If you use Fulfilment by Amazon (FBA), Amazon handles the shipping packaging and may take on certain EPR obligations for that packaging. However, if you fulfil orders yourself (even if the sale was made through a marketplace), you are the obligated producer for all shipping packaging you use. This distinction catches many sellers off guard.

Third-party logistics (3PL) providers add another layer of complexity. If you outsource fulfilment to a 3PL warehouse, the packaging they use on your behalf is still your EPR responsibility. You need to obtain detailed packaging specifications from your 3PL partner — including the exact weight and material type of every box, mailer, void fill material, and tape they use for your orders. Many e-commerce businesses have found that their 3PL uses significantly more packaging than they realised, impacting their total reported weight.

Void fill is a frequently overlooked packaging category. Air pillows, packing peanuts, shredded paper, crinkle-cut kraft paper, and tissue paper are all packaging under EPR rules. E-commerce businesses that buy these in bulk often have no idea how much each unit weighs. Before your first EPR report, weigh sample units of every void fill material you use and calculate per-shipment weights.

Returns packaging is another area where e-commerce sellers lose track. If you include a returns bag, return label in a pouch, or pre-paid envelope in your shipments, those items count as packaging you have placed on the market. Even if the customer does not use the returns packaging, you must include it in your reported totals because you supplied it.

Branded inserts — thank you cards, promotional flyers, discount vouchers, care instructions — are also packaging under EPR definitions. While individually these are very light, at scale across thousands of orders they contribute to your total packaging weight. Track them by material type (usually paper/card) and include them in your quarterly reports.

E-commerce businesses have a unique advantage when it comes to EPR optimisation: because you control your own packaging choices, you can directly reduce your EPR fees by switching to lighter or more recyclable alternatives. Replacing plastic poly mailers with paper mailers, switching from bubble wrap to paper-based protection, and right-sizing boxes to reduce void fill can all lower your reported packaging weight and your EPR costs.

The 2025-2026 fee rates are worth understanding. Paper and card (cardboard boxes, paper mailers) is charged at £196 per tonne, while plastic (poly mailers, bubble wrap, tape, air pillows) is charged at £423 per tonne — more than double. An e-commerce business shipping 500 orders per day using 40 tonnes of cardboard and 10 tonnes of plastic annually would face EPR fees of roughly £12,070. Switching just 5 tonnes of plastic mailer bags to paper alternatives could save over £1,100 per year in fees alone.

E-commerce businesses with annual turnover of £1 million or more and handling 25 or more tonnes of packaging must comply. Large producers (turnover £2 million+ AND more than 50 tonnes) report every 6 months via the RPD portal — H1 data due by 1 October, H2 data due by 1 April. Small producers report annually with data due by 1 April. Charities are exempt. The scheme is administered by PackUK, and our platform generates RPD-compatible reports formatted for direct upload.