EPR Guide - Flipbook - Page 13
Hiring or loaning out reusable packaging
If your business provides reusable packaging (for example, pallets, kegs,
crates or other returnable transit packaging) by hiring or loaning it to
others, you may have EPR obligations. Reusable packaging is within scope
because it will eventually need managing at end-of-life. Reusable packaging
providers are listed as “service providers” who bear EPR responsibility.
Using “transit packaging” to protect goods during transport to UK
consumers
This point particularly affects logistics and ful昀椀lment providers. If you
add transit packaging to goods (e.g. putting products into shipping boxes
with protective 昀椀ll, or wrapping pallets) for delivery to end users, you are
performing a packaging activity. For example, a third-party logistics (3PL)
昀椀rm that boxes and shrink-wraps a retailer’s orders for home delivery
must record and report that packaging. Often the brand owner/retailer
will include transit packaging in their own EPR reporting, but if they don’t
(say, because they are too small or it wasn’t agreed), the logistics provider
could be seen as the producer for that
transit packaging. Bottom line: logistics
companies should track all packaging
they use in distribution and have clear
agreements with clients on who will
handle the EPR obligations (to avoid
“free-rider” scenarios).
Summary
If your company makes, uses, sells, or disposes of packaging in the UK supply chain, you likely have
some responsibility under EPR so long as you meet the size thresholds. Roles like brand owners and
importers are usually the primary obligated producers, but contract packers and logistics providers
must also engage by supplying data and possibly taking on compliance for unregistered partners.
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