EPR Guide - Flipbook - Page 44
Example 3: Importer and Distributor
GlobalParts Ltd. imports industrial machinery components from China,
which come heavily packaged (wooden crates, foam, etc.). They then
distribute these components to UK factories (B2B, not to households).
GlobalParts has £5m revenue and imports 200t of packaging with the
products each year. Although the end users are businesses, GlobalParts
still crosses the thresholds, so it must register. It reports those 200t
as packaging it was responsible for importing. However, because this
packaging is disposed of in factories (non-household waste), GlobalParts
doesn’t pay waste fees on it, EPR fees are only on household waste.
(GlobalParts does still need to get PRNs covering recycling of some of
that packaging, under the old rules, until they are fully phased out.)
Suppose some components include a retail-packaged spare part that will
go to a consumer; for that portion, they would differentiate and pay fees
on that consumer packaging.
Outcome
To comply practically, GlobalParts had to work with its Chinese suppliers
to get data on packaging weights (language and units conversion issues
ensued, but they managed). They even asked one supplier to reduce
excess packaging, both to lower shipping costs and now because it
lowers future EPR liabilities.
This example underscores that even if you primarily do B2B, you’re not
off the hook, you must register and report, and you could be hit with fees
if any of your packaging targets consumers or if rules expand.
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