Practical answers to the questions UK businesses ask most - drawing on 35+ years of industry experience.
1. What's the difference between primary, secondary and tertiary packaging - and why does it matter?
2. What is the UK Plastic Packaging Tax and does my business need to pay it?
3. What is Extended Producer Responsibility (EPR) for packaging, and who does it affect?
4. What does 'sustainable packaging' actually mean - and how do I know if a product genuinely is?
5. How can I reduce my packaging costs without compromising product protection?
The terms primary, secondary, and tertiary packaging are not just industry jargon - they have real regulatory and financial consequences.
Why does this matter?
Under the UK’s Extended Producer Responsibility (EPR) rules, effective from 2025, the way you classify your packaging directly influences the fees you pay. Properly identifying whether a packaging component is primary, secondary, or tertiary allows businesses to track, report, and apply “modulated fees” based on factors like material type and recyclability.
This system encourages the use of sustainable, recyclable materials, since packaging that is difficult to recycle -like mixed plastics - incurs higher costs, whereas paper-based or easily recyclable materials are cheaper.
Additionally, optimising or right-sizing each packaging tier prevents over-engineering. Primary packaging doesn’t need to be stronger than necessary for transit - the secondary and tertiary layers are designed to handle protection during shipping. This ensures cost efficiency and material optimisation across the supply chain.
Expert note:
When we carry out packaging audits, misclassification between tiers is one of the most common issues we find - particularly in businesses where procurement of packaging sits across multiple departments. Getting one person with a clear overview of the full packaging stack makes a noticeable difference.
The Plastic Packaging Tax (PPT) was introduced by HMRC in April 2022 and applies to plastic packaging manufactured in or imported into the UK that contains less than 30% recycled content by weight. As of 1st April 2025, the rate is £223.69 per tonne, rising to £228.82 per tonne from April 2026.
Your business is liable to register if it manufactures or imports 10 or more tonnes of plastic packaging within any rolling 12-month period. Registration must be completed within 30 days of hitting that threshold, with quarterly returns submitted to HMRC thereafter.
Even if your business doesn't directly manufacture or import plastic packaging, it's worth understanding your exposure. Businesses elsewhere in the supply chain can face secondary liability if their supplier hasn't paid the tax – which is why due diligence on your packaging suppliers is increasingly important.
The most straightforward way to reduce or eliminate the tax is to switch to packaging that meets the 30% recycled content threshold. Many cardboard and paper-based packaging options already exceed this, and there's a growing range of polythene products with verified recycled content that qualify for exemption.
Expert note:
One important change coming in April 2027: pre-consumer waste will no longer count towards the 30% recycled content calculation. If your supplier is currently using pre-consumer recycled material to meet the threshold, now is the time to start asking questions.
Extended Producer Responsibility (EPR) is the UK government's mechanism for transferring the full cost of managing household packaging waste from local authorities to the businesses that put that packaging on the market. The scheme is administered by PackUK and is hosted by Defra across all four UK nations.
It affects businesses that are UK-established, have a turnover of at least £1 million, and handle more than 25 tonnes of packaging annually.
Large producers – those with over £2 million turnover and more than 50 tonnes – face the heaviest obligations, including biannual data reporting and direct fee payments from October 2025 onwards.
The fees themselves are based on material type and, from 2026 onwards, recyclability. Under the Recyclability Assessment Methodology (RAM), packaging will be rated red, amber or green – with higher fees for materials that are harder to recycle at kerbside. For 2025 the base fee for plastic is £423 per tonne; glass is £192 per tonne.
Expert note:
We work with a number of customers who weren't aware they'd crossed the EPR thresholds until they reviewed their packaging data properly. If you're unsure whether you're obligated, the first step is simply totalling up all the packaging - by material - that you handle in a year. From there, the picture usually becomes clear fairly quickly.
It's a fair question, because 'sustainable' gets used to describe everything from paper carrier bags to compostable film, and the reality is more nuanced than the marketing.
In practice, sustainable packaging generally means packaging that does one or more of the following:
The most useful question isn't 'is this packaging sustainable?' but 'is this packaging recyclable by my customers, through the collection infrastructure they actually have access to?'
Paper and cardboard, corrugated cases, and many polythene products can all be recycled through mainstream kerbside or in-store collection routes in the UK.
Compostable packaging, despite sounding positive, often requires industrial composting facilities that most consumers don't have access to.
Look for packaging that carries the OPRL (On-Pack Recycling Label) scheme markings.
These are based on real recycling infrastructure data for the UK and are a reliable guide to what can genuinely be recycled.
Avoid vague claims like 'eco-friendly' or 'green' without supporting evidence - under UK consumer protection law, unsubstantiated green claims increasingly carry legal risk.
Expert note:
We always recommend asking your packaging supplier for the full material specification, not just a sustainability claim. The recycled content percentage, the recyclability route, and whether the product is on a recognised scheme like OPRL – those are the three questions worth asking before making any decision.
This is something most businesses have asked themselves, and the honest answer is that the two goals - cost reduction and adequate protection - are more compatible than many assume. Most of the time, over-packaging is the actual problem.
The biggest single lever is right-sizing. Sending goods in a box that's two sizes too large forces you to buy more void fill, more dunnage, and more tape - and it increases dimensional weight charges from your courier. A packaging audit looking at your top 20 SKUs by despatch volume often uncovers significant savings in a relatively short time.
Beyond box size, material specification is worth reviewing. Many businesses are using a heavier grade than their product actually requires, simply because that's what was specified when the line was first set up. Moving from a 150K/150T BC double-walled case to a well-specified single-wall equivalent can cut material cost meaningfully on high-volume lines.
Tape is another area frequently overlooked. Switching to a higher-performance tape – one with better initial tack and adhesion – often allows a reduction in tape usage per carton, which saves both material and machine time. The cheapest tape per metre is rarely the cheapest tape per carton sealed.
Finally, consolidating your range of box sizes and packaging materials with a single supplier typically gives you better pricing, simpler stock management, and access to volume-based improvements.
Expert note:
When we run a packaging and process review for a customer, we rarely come away without finding at least one change that pays for itself within a few months. The savings aren't always dramatic individually, but they add up – especially on high-volume despatch operations
E-commerce packaging has to do something that retail shelf packaging doesn't: survive a multi-stage parcel network, arrive looking presentable, and open cleanly for the customer - all while keeping dimensional weight (and therefore courier costs) as low as possible.
Corrugated cardboard remains the workhorse of e-commerce despatch for most product categories. It offers an excellent strength-to-weight ratio, it's widely recyclable, and it can be sourced in an enormous range of sizes.
Postal boxes with self-locking bases are particularly practical for lower-weight items as they remove the need for tape on the base.
For softer goods – clothing, textiles, gifts – postal bags (both paper-based and polythene) are often a better fit than rigid boxes. They're lighter, they conform to the product rather than creating wasted space, and they typically attract lower volumetric weight charges.
Protective void fill and cushioning should be matched to your fragility requirements. Crumpled kraft paper is sufficient for many products and has strong customer perception as a sustainable choice.
Bubble wrap and foam remain appropriate for genuinely fragile items. Air pillows are good for lightweight void-filling where paper would add too much weight.
The unboxing experience matters increasingly for brand perception – particularly for premium or gifted products. Custom printed tissue, branded tape, or a simple printed insert can add a great deal of perceived value at minimal cost.
Expert note:
One of the most common mistakes in e-commerce packaging is specifying the right box for the average product, rather than mapping your packaging range to your actual SKU spread. A proper size analysis almost always reveals the opportunity to reduce the number of box sizes you're holding whilst covering your range more efficiently.
Packaging Recovery Notes (PRNs) and Packaging Export Recovery Notes (PERNs) are the mechanism through which obligated packaging producers demonstrate compliance with recycling targets under UK law.
If your business meets the EPR thresholds (broadly, £1 million+ turnover and 25 tonnes+ of packaging handled), you are likely to have a PRN obligation alongside your EPR disposal fee obligations. The two run in parallel – EPR fees and PRN obligations are separate, not interchangeable.
PRNs are issued by accredited reprocessors (recycling facilities) and exporters each time they process or export a tonne of recovered packaging material. By purchasing PRNs, your business is effectively financing the recycling of a tonne of packaging waste – and evidencing that it has done so.
Most businesses that are obligated use a compliance scheme (such as Valpak) to manage their PRN obligations. The scheme handles the purchasing and submission on your behalf, in return for an annual fee based on your packaging volumes.
PRN prices fluctuate with market conditions – the price of a paper PRN, for example, moves with the fortunes of the recovered paper market. This is worth factoring into your compliance cost forecasting, particularly as EPR fees add a second variable to the equation.
Expert note:
The interaction between PRN obligations and the new EPR disposal fees is an area where a number of our customers are seeking clarity at the moment. The short answer is that both apply simultaneously – you can't offset one against the other.
Poor storage is one of the quieter costs in a packaging operation - the boxes that get crushed at the bottom of a stack, the tape that won't unwind cleanly because it's been stored at the wrong temperature, the stretch film that's been nicked by a forklift. None of it is catastrophic individually, but it adds up.
Corrugated cardboard is hygroscopic - it absorbs moisture from the air, which compromises its stacking strength. Flat-packed cases should be stored horizontally, off the floor on racking, away from external walls, and away from any source of damp. In high-humidity environments (cold stores, for instance), moisture-resistant corrugated grades or polythene-wrapped pallet storage are worth considering.
Adhesive tapes are sensitive to both temperature and humidity. The ideal storage temperature is between 15°C and 25°C. Tapes stored in cold conditions should be allowed to acclimatise before use - applying cold tape to a cold carton is a reliable recipe for poor adhesion and production line stoppages.
Stretch film and polythene products should be kept wrapped or in their original packaging until needed, away from UV light and sharp objects. FIFO (first in, first out) rotation matters here – polythene degrades over time and old stock should always be used before new.
A regular review of your minimum and maximum stock levels - combined with reliable replenishment from your supplier – is more effective than holding large buffer stocks. Carrying excessive packaging inventory ties up space and cash, and increases the risk of product becoming obsolete (particularly if you're subject to EPR reporting, where accurate data on what's actually being used matters).
Expert note:
We offer an inventory management service to a number of our customers, where we hold stock on their behalf and replenish to agreed levels. For businesses with limited warehouse space or variable demand, it's often a more efficient model than holding everything in-house.
Price is the obvious starting point, but it's rarely the best single criterion - particularly for businesses where packaging is a critical part of the production or despatch process. A cheaper tape that fails in the machine at 3pm on a Friday costs considerably more than the saving.
Reliability of supply is arguably more important than unit price for most businesses. Your packaging supplier should have demonstrable stock depth on your key lines, clear lead times, and a track record of delivering on them. Ask about their warehouse capacity and stock-holding for your most critical materials.
Accreditation matters. ISO 9001 certification means the supplier's quality management processes are independently audited - it's a baseline assurance that what you ordered last time will be what you receive next time. ISO 14001 (environmental management) and ISO 45001 (health and safety) are also worth looking for, particularly if your own business is subject to supply chain sustainability requirements.
Look for a supplier with genuine technical expertise, not just a catalogue. The ability to carry out a packaging audit, advise on specification, and help you navigate regulatory changes (particularly EPR and the Plastic Packaging Tax) is increasingly valuable as the compliance landscape becomes more complex.
Finally, consider the relationship and the people. A supplier with a named account manager who understands your business, knows your products, and proactively flags issues before they become problems is worth considerably more than one where every call starts from scratch.
Expert note:
We've been supplying packaging since 1989, and in our experience the businesses that get the best value from a supplier relationship are those that treat it as a partnership rather than a purely transactional arrangement. The more context we have about a customer's operation, the more useful we can be.
A packaging audit is a systematic review of the packaging materials, specifications and processes your business currently uses - typically carried out by a specialist at your site. The objective is to identify opportunities to reduce cost, improve performance, address compliance gaps, or all three.
In practice, a thorough audit covers:
The outcomes vary, but common findings include: boxes that are oversized for their contents, tape applied in unnecessarily long runs that could be shortened without affecting carton integrity, protective materials specified for a worst-case scenario that rarely occurs in practice, and materials sourced from multiple suppliers where consolidation would achieve better pricing.
Most reputable packaging suppliers will offer a packaging audit either free of charge or at low cost, on the understanding that any specification improvements will be supplied by them. There's nothing wrong with that arrangement, provided the audit is conducted rigorously and the recommendations are genuinely grounded in your requirements rather than the supplier's product range.
For businesses spending meaningfully on packaging – typically from around £50,000 a year upwards - a proper audit usually identifies savings that significantly outweigh any cost involved. For smaller businesses, even a lighter-touch review of your top-volume lines is often a useful exercise.
Expert note:
Our Packaging and Process Review service is available to both existing and prospective customers. We don't charge for it, and there's no obligation – the view we've always taken is that if we're genuinely helpful, the relationship tends to follow.
