Household vs Non-Household Packaging: The UK EPR Guide
If you are a organisation required to report packaging under extended producer responsibility (EPR), you must assess whether your packaging is household or non-household.
Always Non-Household
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Secondary Packaging Wrappers/groupings used for branding or logistics.
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Tertiary Packaging Pallets, shrink wrap, and transit packaging.
Presumed Household
The following are classed as Household unless specific conditions are met:
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Primary Packaging The immediate wrapper or container for the product.
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Shipment Packaging Packaging used for shipping products to end-consumers.
When to Class Primary/Shipment as Non-Household
You can only reclassify primary or shipment packaging as non-household if:
Direct B2B Supply
Supplied to a business/public institution that is the end user (e.g., restaurant using ingredients and discarding packaging).
Specialist Design
Product is designed only for business use and is not likely to end up in a household or public bin.
Importer Discard
You import packaging and discard it yourself without supplying it to anyone else in the UK.
Automation & In-Built Assessors
Avoid the manual headache of assessing thousands of SKUs. Our software combines powerful data automation with in-built assessors that guide you through the Environment Agency's logic. By providing information on distribution channels and product design, the system automatically assists in tagging your packaging as Household or Non-Household.
Evidence is Mandatory
If you cannot provide sufficient evidence for non-household status, you must class it as household. This evidence must be kept for at least 7 years.
Acceptable B2B Evidence:
- Legally binding agreements prohibiting onward supply
- Sales records showing all packaging is removed by the customer
- Signed customer declarations with supporting inspection reports
- Invoices with VAT numbers for business-only accounts
Classification Factors:
- Size/Weight: Does it fit in a 240L bin or exceed 30kg?
- Restrictions: Is possession restricted by law (e.g., Poisons Act)?
- Distribution: Exclusive B2B channels only?
- Attributes: Durability, voltage, or industrial specs.
Defining Public Institutions
EPR counts the following as public institutions:
Real-World Classification Examples
Industrial Coffee Machines
Non-HouseholdScenario: Manufacturer sells via wholesaler to both public and business, but product is designed for industrial catering.
Even if a consumer buys one, it's an exceptional case. Because it's designed for business use and likely discarded in business bins, it can be non-household with evidence.
Desk Stationary/Chairs
HouseholdScenario: Wholesale importer supplies desk chairs to a business, who then provides them to consumers.
The packaging must be reported as household as the business sold to will end up supplying the chairs and packaging to consumers and the chairs are not designed for "business use only."
Hospital Food/Sandwiches
HouseholdScenario: Sandwiches supplied through a wholesaler to a hospital staff canteen.
The hospital is not the end user (the staff are). The product is not designed for "business use only," so it must be reported as household.