Retail (General) EPR for Retailers (Physical)
EPR packaging obligations for retailers (physical) in the retail (general) sector. Understand your specific requirements, packaging types, and reporting obligations.
Your Obligations as Retailers (Physical)
Physical retailers have EPR obligations that depend on what they sell and what additional packaging they provide:
- Carrier bags — paper, plastic, and reusable bags provided at point of sale
- Own-brand packaging — ALL packaging on own-label products
- Gift wrapping — wrapping paper, gift bags, ribbon, and tissue offered as a service
- Display packaging — shelf-ready packaging and point-of-sale displays you provide
For third-party branded products you stock, the brand owner or importer is typically responsible for product packaging. Your responsibility as a retailer is limited to packaging YOU provide in addition to the product packaging.
However, if you sell own-brand (private label) products, you are responsible for ALL packaging on those products — from primary packaging through to transit packaging used in your supply chain.
Multi-site retailers must aggregate packaging data across all store locations for a single group-level EPR submission.
Retail (General) Sector Packaging
As retailers (physical) in the retail (general) sector, you need to track these common packaging types:
Carrier Bags
Paper, plastic, or fabric bags provided at point of sale. All are packaging under EPR regardless of ...
Gift Wrapping
Wrapping paper, gift bags, and ribbon offered as a service. All count as packaging if provided with ...
Receipt Paper
Thermal receipt paper is NOT packaging — it is information. But bags or envelopes given with receipt...
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...
Key Obligations Checklist
- Track carrier bag usage across all store locations
- Report all own-brand product packaging in full
- Include gift wrapping and seasonal packaging
- Record display packaging and point-of-sale materials
- Aggregate data across all store locations
- Submit data to DEFRA and pay EPR fees
Common Questions
Am I responsible for packaging on brands I stock?
Generally no — the brand owner is responsible for their product packaging. You are responsible for carrier bags, own-brand products, gift wrapping, and any additional packaging you provide.
Do reusable bags count?
Yes. All bags provided at point of sale are packaging under EPR when first supplied — including bags for life and jute bags. The charge you make for the bag does not change its classification.
How do I track packaging across multiple stores?
Centralise packaging data collection. Use head-office procurement records for carrier bags and own-brand packaging. Use store-level sales data to allocate packaging volumes. Our platform supports multi-site aggregation.
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