Non-Branded Packaging

Non-Branded Packaging - Who is the obligated producer?

Moving to a Single Point of Compliance

Under EPR (Extended Producer Responsibility) the packaging regulations are moving away from the current shared responsibility to a single point of compliance. This will in the main, focus on brand owner or importer, however there are other categories for certain business models such as online marketplaces.

Who is responsible for Non-Branded Packaging?

Non-Branded Packaging will be the producer’s responsibility - initiating the pack/fill operation. (This is placing goods into packaging that’s unbranded when it’s supplied.)

Placing goods into unbranded packaging when it’s supplied, will mean you may need to act. *This could be goods you packaged for your own organisation or for another organisation.

Importing products in non-branded packaging

If your organisation imports and supplies products for the UK market your organisation may be obligated under EPR regulations.

*If, however unbranded packaging, is supplied to a large organisation which applies its own brand to the packaging before distributing it on will mean the responsibility as the single point of compliance will be with the large organisation.

Suppling empty non-branded packaging

If you import or manufacture empty non-branded packaging, you may be obligated depending on the type of businesses you are supplying to are not classed as a large producer. The onus is on you to check they are registered.

You will be classed as a “small organisation” if either of the following apply:

• your annual turnover is between £1 million and £2 million, and you are responsible for supplying or importing more than 25 tonnes of empty packaging or packaged goods in the UK
• your annual turnover is over £1 million, and you are responsible for supplying or importing between 25 tonnes and 50 tonnes of empty packaging or packaged goods in the UK

You will be classed as a “large organisation” if both of the following apply:

• you have an annual turnover of £2 million and above
• you are responsible for supplying or importing more than 50 tonnes of empty packaging or packaged goods into the UK market

Note: You should base your annual turnover on your most recent annual accounts.

How ERP can help

ERP’s compliance team are supporting hundreds of companies navigate these changes – enquire today about becoming a member.

ERP’s data services team are specialists in collecting, checking and calculating the data companies need for packaging data reporting – enquire today about how they can help

Want to know more?

Download our Factsheets:

Data Services Factsheet here:

Packaging Compliance Factsheet here:

EPR Factsheet here:

Contact us today:

Telephone: +44 (0)20 3142 6452 E-mail: uk@erp-recycling.org

Author: Simon Hubbard, Business Manager, ERP UK