Packaging design and use - your responsibilities

You may only place new or reconditioned packaging on the market in the EU if it meets the following requirements.

  • Reduced package - The packaging must be reduced to the minimum, in volume and weight, that guarantees: that the packaged product has the appropriate level of safety and hygiene, and that consumers find it acceptable.
  • Reduced environmental impact - The packaging must be designed, manufactured and commercialised so that the impact on the environment when it or its residues are finally disposed off is minimised.
  • Reduced levels of noxious and hazardous substances - The packaging must not contain high levels of noxious or hazardous substances, so that the amounts of these substances are minimal when the packaging waste is landfilled or incinerated - for example, from ash or leachate, the liquid that drains from a landfill site.
  • Limited levels of regulated metals - The sum of the concentration levels of lead, cadmium, mercury and hexavalent chromium in the packaging and in any of its packaging components must not be more than 100 parts per million by weight. There are a few exemptions from the limits - see “Packaging design and use - exemptions from the regulations” in this guide.
  • Pay the plastic packaging tax  - The Plastic Packaging Tax only applies to manufacturers and importers of plastic packaging components which contain less than 30% recycled plastic. Packaging should only contain recycled plastic where it is permitted under other regulations and food safety standards. For more information visit:

    GOV.UK: Plastic packaging tax

  • The packaging must be manufactured so that it can be reused or recycled.
  • For packaging you intend to be recovered by recycling, it must be manufactured so that a percentage (by weight) of the material can be recycled. The percentage varies according to the type of material and the current standards in the European Union.
  • For packaging you intend to be recovered by energy recovery, it must allow for the maximum amount of energy to be recovered - if you burn any packaging waste, it must produce more energy than is used by the incineration process.
  • For packaging you intend to be for recovery by composting, it must be of biodegradable material such that it doesn't hinder the separate collection and composting process. To be biodegradable the packaging must decompose mostly into carbon dioxide, biomass and water.

Packaging design - additional requirements for reusable packaging

In addition to the previous requirements, to place on the market packaging designed to be reusable, the packaging must meet the following requirements:

  • the packaging must be appropriate for being reused several times, in normal conditions of use.
  • once used, the packaging must be suitable for processing so as to meet health and safety requirements for the workplace
  • once at the end of its useful life, the packaging must meet one of the requirements for recovery.

Demonstrating compliance

The best way to demonstrate you comply with the packaging design requirements is to follow the European Standards on designing packaging, or the British Standards.

Keeping records

You must:

  • be able to demonstrate that your packaging complies with the Packaging (Essential Requirements) Regulations
  • keep records: keep evidence that your packaging complies with the Packaging (Essential Requirements) Regulations, for at least four years from the date the packaging was first placed on the market.
  • be able to supply these details within 28 days, if requested by the enforcement authority. The enforcement authority is, in Northern Ireland, the Department of Enterprise, Trade and Investment, and, in Scotland, the trading standards departments of local authorities.

How you hold this information is up to you. You may need to keep a variety of document types to ensure you have evidence for all of the requirements.

You could keep records of:

  • existing technical documents on the design and use of your packaging
  • existing quality assurance documents
  • environmental management systems and auditing documents
  • documents relating to other packaging standards.

Report packaging data

You will need to report packaging data if all the following apply to you:

  • you’re an individual business, subsidiary or group (but not a charity)
  • you have an annual turnover of £1 million or more (based on your most recent annual accounts)
  • you’re responsible for over 25 tonnes of packaging in a calendar year (January to December)
  • you carry out any of the packaging activities

The packaging activities:

If you do any of the following you may need to take action:

  • supply packaged goods to the UK market under your own brand
  • place goods into packaging that’s unbranded when it’s supplied
  • use ‘transit packaging’ to protect goods during transport so they can be sold to UK consumers
  • import products in packaging
  • own an online marketplace
  • hire or loan out reusable packaging
  • supply empty packaging

For more information about reporting of packaging data see:

GOV.UK: Prepare for extended producer responsibility

Other packaging requirements

Additional requirements may apply if you produce or use specialist packaging, such as food contact packaging or medical packaging, or packaging for hazardous chemical products.

You can read guidance on medical product packaging on GOV.UK website.

GOV.UK: Medicines: packaging, labelling and patient information leaflets

You can read guidance on food contact packaging on the FSA website: Food Standards Agency: Food packaging requirements

Requirements for packaging used for hazardous chemical products

If you are a supplier of chemical substances and mixtures, (manufacturer, importer, distributor, downstream user), your packaging has to meet the requirements of the CLP Regulation on classification, labelling and packaging of substances and mixtures.

The packaging to be used for hazardous chemicals:

  • must not let the hazardous chemical escape
  • must not get damaged by the hazardous chemical
  • must be strong enough to allow normal handling conditions
  • if it is re-closable package, must continue to prevent escape after repeated use,
  • in some cases, must not have a shape or designation likely to attract the curiosity of children or mislead costumers
  • in some cases, must have child resistant closures or fastenings, and tactile warnings for visually impaired costumers

There are labelling requirements for this packaging. Find out your obligations under these regulations in Classifying and labelling chemicals.

Further information

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