Industrial Products Packaging EPR Compliance
From precision components in VCI bags to machinery in wooden crates, industrial packaging has heavy-duty EPR obligations.
Industrial & Manufacturing EPR: What You Need to Know
Industrial packaging is characterised by heavy individual packaging weights — a single wooden crate can weigh more than a retailer's entire monthly packaging output. This makes accurate per-shipment tracking essential for compliance.
Many industrial businesses use returnable transit packaging (RTPs) such as steel stillages, plastic totes, and reusable pallets. These may be exempt from EPR if they operate in a documented closed-loop system. However, you must maintain records proving the reuse — including trip counts, return rates, and end-of-life disposal. Without documentation, RTPs are treated as single-trip packaging.
For 2025-2026, the base fees per tonne are: wood at £280 (crates, one-way pallets), plastic at £423 (VCI bags, foam, wrap), steel at £44 (banding, drums). The low steel rate benefits industrial businesses using steel strapping and containers.
See also our guides for automotive, construction, and chemical products packaging.
Common Industrial & Manufacturing Packaging
These are the key packaging types you need to track and report for EPR compliance in the industrial & manufacturing sector.
Wooden Crates
Custom timber crates for machinery and large components. Report under wood material. ISPM-15 treatment does not affect EPR classification.
VCI Bags & Paper
Volatile Corrosion Inhibitor packaging for metal parts. Bags (plastic) and paper each reported under their respective material.
Heavy-Duty Poly Bags
Thick PE bags for heavy components and fasteners. Often 100-200 micron — report under plastic by weight.
Steel Banding
Steel strapping for securing heavy loads to pallets. Report under steel material.
Foam Dunnage
Custom-cut PE or PU foam protecting precision parts in transit. Report under plastic.
Pallet Wrap & Edge Boards
LLDPE stretch wrap and card edge protectors for palletised shipments. Transit packaging.
What You Need to Do
As a industrial & manufacturing 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 packaging including heavyweight items (crates, pallets)
- Report VCI and corrosion-protection packaging
- Document reusable vs single-trip packaging status
- Include dunnage and void fill materials
- 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 Industrial & Manufacturing Compliance Mistakes
Avoid these frequent pitfalls that catch out industrial & manufacturing businesses every year.
Wooden crate weight underestimation
A custom wooden crate for a machine can weigh 50-200kg. Even a few dozen shipments per year can mean tonnes of wood packaging. Weigh actual crates.
Ignoring VCI packaging
VCI bags and papers used for corrosion protection are packaging. They are used on almost every metal part and add up quickly across product ranges.
Reusable packaging documentation
Returnable transit packaging (steel stillages, plastic totes) may be exempt — but only with documented proof of reuse. Keep detailed records.
Not tracking one-way pallets
One-way timber pallets are packaging. CHEP/reusable pallets in a closed loop may be exempt. Distinguish between them in your records.
Industrial & Manufacturing EPR Questions
Common questions about packaging EPR for industrial & manufacturing businesses.
Are returnable packaging items exempt from EPR?
Potentially yes, but only with documented proof of a closed-loop reuse system. You must track trip counts, return rates, and end-of-life disposal. Without documentation, all packaging is treated as single-trip.
How do I weigh wooden crates?
Weigh the empty crate on a platform scale. For standard crate sizes, create a weight register. For custom crates, weigh each one. Crate weights can range from 10kg to 200kg+ depending on size and construction.
Do ISPM-15 heat-treated pallets have different EPR treatment?
No. ISPM-15 treatment (for international phytosanitary compliance) does not affect EPR classification. Heat-treated and non-treated timber pallets are both reported under wood material.
Are foam inserts used inside reusable totes packaging?
If the foam inserts are single-use (replaced each trip), they are packaging. If they are permanently fixed inside the reusable tote and form part of the reusable system, they may be covered by the reuse exemption.
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