EPR Guide - Flipbook - Page 16
What Exactly Counts as “Packaging”
for Reporting?
The rule of thumb is anything that is used to contain, protect, handle, deliver or present goods
is packaging. This ranges from obvious items like boxes, packets, bottles, cans, pallets and
wrapping, to less obvious things like labels, tape, and even items designed to be 昀椀lled at the
point of sale (e.g. reusable coffee cups). If it’s part of the packaging of a product, it should
be counted. (There are technical de昀椀nitions for primary vs secondary vs tertiary packaging,
essentially consumer unit packaging vs grouped packaging vs transport packaging, and the
regulations cover all those levels.)
Household vs Non-Household Packaging: When reporting, producers must distinguish
household packaging (waste likely arising from households or street bins, which local councils
deal with) versus non-household (B2B packaging waste handled commercially). Packaging
on consumer goods, ecommerce parcels, grocery items, etc., are “household” packaging.
Packaging used purely in business-to-business settings (like industrial bulk packaging, tertiary
transit packaging disposed of by a retailer, etc.) is “non-household.” The idea being producers
now fund council collections of household waste. There have been some debates and
clari昀椀cations around borderline cases (e.g. “transit” packaging that
ends up in a store’s bin might count as non-household). If in doubt,
consult the detailed guidance or regulators’ interpretations (the National
Packaging Waste Database hosts technical guidance on de昀椀nitions).
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