General Retail Packaging EPR Compliance
Carrier bags, gift wrapping, and transit packaging — retailers face EPR obligations at every stage of the supply chain.
Retail (General) EPR: What You Need to Know
General retailers face EPR obligations both as sellers of packaged goods and as providers of additional packaging (carrier bags, gift wrapping). The scope of your obligation depends on whether you sell own-brand products, third-party brands, or both.
For own-brand products, you are responsible for all packaging — primary (product packaging), secondary (multipack/shelf-ready packaging), and any transit packaging. For third-party brands, the brand owner or importer is typically responsible for the product packaging, but you are responsible for any additional packaging you supply (carrier bags, gift wrap, e-commerce boxes).
For 2025-2026, base fees per tonne are: paper and card at £196 (paper bags, boxes), plastic at £423 (plastic bags, void fill). Switching to paper carrier bags reduces EPR costs compared to plastic.
See also our guides for e-commerce and fashion retail.
Common Retail (General) Packaging
These are the key packaging types you need to track and report for EPR compliance in the retail (general) sector.
Carrier Bags
Paper, plastic, or fabric bags provided at point of sale. All are packaging under EPR regardless of whether a charge is made.
Gift Wrapping
Wrapping paper, gift bags, and ribbon offered as a service. All count as packaging if provided with a purchase.
Receipt Paper
Thermal receipt paper is NOT packaging — it is information. But bags or envelopes given with receipts ARE packaging.
Transit Packaging
Corrugated cases, pallet wrap, and void fill used in the supply chain from warehouse to store.
Shelf-Ready Packaging
Cases designed to be placed directly on shelves with the lid removed. Transit packaging under EPR.
E-commerce Packaging
Boxes, mailers, and void fill for online orders shipped to customers. Track separately from in-store packaging.
What You Need to Do
As a retail (general) 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 carrier bags across all store locations
- Report own-brand product packaging in full
- Include gift wrapping services in packaging calculations
- Record transit and shelf-ready packaging
- Track e-commerce packaging separately from retail
- Submit data to DEFRA and pay EPR fees
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 Retail (General) Compliance Mistakes
Avoid these frequent pitfalls that catch out retail (general) businesses every year.
Ignoring own-brand packaging responsibility
If you sell own-brand products, you are responsible for ALL packaging on those products — not just the carrier bag. Track the primary packaging of every own-brand SKU.
Carrier bag tracking gaps
All carrier bags are packaging — paper, plastic, and reusable fabric bags. Track units and weights across all store locations.
Missing gift service packaging
Gift wrapping, gift boxes, tissue paper, and ribbon offered as a retail service are all your packaging obligation.
Not tracking online vs in-store separately
Online fulfilment uses different packaging (boxes, mailers, void fill) from in-store sales (carrier bags, gift wrap). Track both channels.
Retail (General) EPR Questions
Common questions about packaging EPR for retail (general) businesses.
Am I responsible for packaging on third-party brands I sell?
Generally no — the brand owner or importer is responsible for product packaging on third-party brands. However, you ARE responsible for any additional packaging you add: carrier bags, gift wrapping, e-commerce boxes, and any own-label products.
Do reusable bags for life count?
Yes. Reusable bags for life (whether plastic, fabric, or jute) are packaging under EPR when first supplied. However, replacement bags in a documented return/reuse scheme may have different treatment.
Is gift wrapping offered as a service packaging?
Yes. Wrapping paper, gift bags, tissue paper, and ribbon supplied with a purchase are all packaging. If customers pay for the service, it is still packaging — the charge does not change the classification.
How do I report shelf-ready packaging?
Shelf-ready packaging (SRP) is classified as transit packaging. If you are the brand owner using SRP, report it. If a supplier sends you goods in SRP, the supplier reports it.
Ready to get your retail (general) business compliant?
Join hundreds of UK businesses using EPR Compliance to meet their packaging obligations effortlessly.
Start Your Free Trial