EPR Guide - Flipbook - Page 11
Packaging Activities & Roles in the
Supply Chain
It’s not just packaging manufacturers or brand owners that are affected. The
regulations de昀椀ne “packaging activities” – if your business performs any of
these activities and meets the thresholds above, you are an obligated packaging
producer:
Supplying Packaged Goods Under Your Own Brand
If your brand is on a product’s packaging (e.g. as a manufacturer or retailer’s own brand),
you are responsible for that packaging. The brand owner usually bears 100% of the EPR
obligation for their branded packaging. For example, a UK food manufacturer selling
sweets under its own brand must register and handle EPR for those sweet wrappers.
(If the same factory produces sweets for a supermarket’s private-label brand, the
supermarket, as the brand owner, would be the obligated producer instead.)
Placing Goods Into Packaging (Packing or Filling)
Companies that pack products into packaging, including contract packers who
pack goods for other brands, are performing a packaging activity. If you package
goods for a client with a UK brand, typically the brand owner is deemed the
producer for EPR purposes (and responsible for compliance). However, if you pack
goods for an unbranded product or for a company that is below EPR thresholds,
you may inherit the obligations. Example: A contract manufacturer packages
cosmetics for an overseas brand not established in the UK, here the
UK packer could be treated as the 昀椀rst supplier in the UK and thus
the EPR-subject producer. In any case, contract packers must
coordinate closely with their clients, they will likely need to
provide detailed packaging data to the brand owner for reporting,
and should have clarity on who will pay EPR fees in their supply
contracts.
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