EPR Guide - Flipbook - Page 43
Example 2: Contract Packer / Ful昀椀ller for Others
LogiPack Services is a 3PL that provides warehousing and ful昀椀llment services. One of
its clients is an overseas brand of supplements selling direct to UK consumers
through an online store. LogiPack stores the bulk product (unpackaged pills)
and packages them for each order, putting pills into bottles, adding labels, then
into shipping boxes with 昀椀ller. Who is the “producer” here? The supplement
brand has no UK entity, and LogiPack is effectively the 昀椀rst to place the
packaged goods on the UK market. Therefore, LogiPack becomes the obligated
producer for all packaging it uses. It must register for EPR, even though it’s a
service provider, because otherwise that packaging would escape regulation.
LogiPack’s responsibilities include reporting the bottles, labels, and shipping
materials. Let’s say in 2025 it used 5t of plastic (bottles), 1t of paper (labels), and 10t
of cardboard (shipping boxes) for that client’s operations. It will get a fee for ~16t of
household packaging (since it goes to consumers). To mitigate this, LogiPack might
either charge the client for these fees or renegotiate the contract.
Outcome
Strategically, LogiPack invests in optimizing the packaging: they switch to a smaller,
lighter-weight box for shipping that saves 20% cardboard use, and ensure all packaging
is paper or easily recyclable plastic to avoid Red ratings. They turn this into a selling
point for potential clients: “We handle your UK orders sustainably and compliantly,
no hidden EPR surprises.” Additionally, for any other clients who are UK entities,
LogiPack carefully delineates who reports what. If they ful昀椀l for a large UK
retailer (which is itself registered), the retailer might want to report the shipping
packaging as part of their data. In such cases, LogiPack provides detailed
data back to the client rather than reporting it under its own registration, to
avoid double counting. Communication and clarity are key in such multi-party
scenarios.
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