EPR Guide - Flipbook - Page 12
Importing products in packaging
Importers that bring in packaged goods and raw packaging are equivalent
to producers under EPR. If you import any products in packaging (for resale,
or even for use within your business), you are responsible for that packaging
once it enters the UK market. This includes things like imported raw
materials or components that come in packaging which you discard in the
UK. For example, a UK manufacturer importing parts or ingredients shrinkwrapped on pallets must account for that shrink wrap and other packaging
waste they dispose of in the UK. (Note: If you import on behalf of a UK brand
owner, typically the UK brand company would register as the producer. But
if you import products from an overseas brand or supplier that has no UK
presence, your company becomes the obligated producer for the packaging
on those goods.)
Distributing or supplying empty packaging
Packaging converters or suppliers that sell empty packaging (e.g. bottles,
boxes, pallets, etc.) to businesses which are not themselves obligated
producers (for instance, a small business below the thresholds) are on
the hook for that packaging. In other words, there should be no regulatory
“gaps”, every piece of packaging should have an obligated producer. If
you manufacture or import empty packaging and your customer isn’t
caught by EPR, then you are considered the producer for those items
and must report them.
Online marketplace operators (for non-UK vendors)
If you operate an online marketplace (website or app) and allow non-UK
businesses to sell packaged goods or empty packaging to UK consumers,
your company is deemed to be the supplier of that packaging. You must
register and ful昀椀l EPR responsibilities for all such packaging sold via
your platform into the UK. (If the sellers on your platform are UK
businesses, then those businesses themselves handle EPR
compliance; your platform is not counted as doing the “online
marketplace” activity in that scenario.)
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