Environmental guidance for your business in Northern Ireland & Scotland

Packaging producer obligations - who do they apply to?

Packaging producer obligations - who do they apply to?

What you must do

You must comply with producer responsibility obligations if your business handles more than 50 tonnes of packaging in a calendar year and has a turnover of more than £2 million (based on the previous financial year).

The obligations apply to the total amount of packaging that your business handles, not the amount of packaging waste that your business produces.

If your business belongs to a group of companies, these requirements apply to the total amount of packaging handled by the group and the group's total annual turnover.

Do you handle packaging?

Your business handles packaging if you, or someone acting on your behalf:

  • manufacture the raw materials used to make packaging
  • convert raw materials into packaging
  • fill packaging (putting goods or products into packaging)
  • supply packaged goods to the end user (this may be another business or the public)
  • lease or hire out packaging, such as pallets
  • operate a franchise or other licensed business, including pubs
  • import packaging, packaging materials or packaged goods into the UK
  • bring transit packaging into the UK that will end up as waste in the UK.

GOV.UK: Packaging waste: producer resposnibilities

Second-hand and reusable packaging

If your business reuses second-hand packaging, sourced in the UK, you do not need to count this towards the total amount of packaging you handle. This only applies if the packaging is in its original form and you use it for the same purpose that it was made for. For example, you may reuse cardboard boxes or filling materials.

If you import reusable or reused second-hand packaging, you must count this towards the total amount of packaging you handle. Packaging that is intended to be reusable includes steel roll cages, plastic milk crates and refillable glass milk bottles.

If you produce reusable packaging you must ensure that your product complies with the Packaging (Essential Requirements) Regulations. These regulations apply to all businesses that design, produce and place packaging on the market. See the page in this guide on Packaging design and use - your environmental responsibilities

If your business reconditions or otherwise alters old packaging for a different use you must still comply with the producer responsibility obligations as the packaging is considered new to the market.

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