Packaging for machinery or electrical equipment businesses

This guidance is relevant if you package machinery or electrical and electronic equipment (EEE) that you place on the market or produce packaging waste from deliveries of raw materials or drums of solvents, chemicals or lubricants.

If you place packaging on the market you are responsible for ensuring that the packaging meets environmental standards. If you place large amounts of packaging on the market, you are also responsible for recovering and recycling packaging waste you create.

If you produce, fill, sell or handle packaging the packaging regulations will affect you.

What you must do

There are two sets of packaging regulations that you may need to comply with:

  • The Packaging (Essential Requirements) Regulations apply to you if your business produces packaged products, or places packaging or packaged goods on the market.
  • The Producer Responsibility Obligations (Packaging Waste) Regulations apply to you if your business handles more than 50 tonnes of packaging in a year and has a turnover of more than £2 million.

In England, Scotland and Wales the Essential Requirements Regulations are enforced by the trading standards departments of local councils.

 In Northern Ireland the Essential Requirements Regulations are enforced by the Department of Enterprise, Trade and Investment.

The Producer Responsibility Obligations are administered by your environmental regulator.

Packaging essential requirements

If your business produces packaged products, or places packaging or packaged goods on the market, you must follow the Packaging (Essential Requirements) Regulations by:

  • not exceeding limits on concentrations of certain heavy metals such as lead, cadmium and mercury in your packaging 
  • using the minimum packaging necessary
  • producing packaging that can be reused, recovered or recycled
  • keeping records for four years as evidence that you are complying.

See our guidance on the Packaging (Essential Requirements) Regulations in:

England on Business Link: Packaging design and use - your environmental responsibilities
Northern Ireland on NIBuinsessInfo: Packaging design and use - your environmental responsibilities
Scotland on Business Gateway: Packaging design and use - your environmental responsibilities
Wales on Business.Wales.gov.uk: Packaging design and use - your environmental responsibilities

In addition to meeting the Packaging (Essential Requirements) Regulations, you must also comply with the duty of care for waste.

See our guidance on duty of care in:

England on Business Link: Duty of care - your responsibilities
Northern Ireland on NIBusinessInfo: Duty of care - your responsibilities
Scotland on Business Gateway: Duty of care - your responsibilities
Wales on Business.Wales.gov.uk: Duty of care - your responsibilities

Producer responsibility obligations

If your business handles, manufactures, converts, packs, fills, sells or imports over 50 tonnes of packaging or packaging materials in a year and has a turnover exceeding £2 million per year, you must: 

  • register with your environmental regulator
  • pay for the recovery and recycling of a certain amount of packaging waste
  • provide your environmental regulator with evidence that you have met your obligations.

See our guidance on Producer Responsibility Obligations in:

England on Business Link: Packaging producer obligations - who they apply to
Northern Ireland on NIBuinsessInfo: Packaging producer obligations - who they apply
Scotland on Business Gateway: Packaging producer obligations - who they apply
Wales on Business.Wales.gov.uk: Packaging producer obligations - who they apply

To store any packaging waste before it is recycled you may need an exemption from waste permitting or licensing.

There are three ways to comply with the producer responsibility obligations:

  • Join a registered compliance scheme.
  • Calculate and fulfil your own obligations.
  • Use the allocation method if your turnover is £2-5 million.

For explanations of these methods see our guidance on how to comply with the producer responsibility obligations in:

England on Business Link: Packaging producer obligations - compliance schemes
Northern Ireland on NIBuinsessInfo: Packaging producer obligations - compliance schemes
Scotland on Business Gateway: Packaging producer obligations - compliance schemes
Wales on Business.Wales.gov.uk: Packaging producer obligations - compliance schemes

England on Business Link: Packaging producer obligations - individual route
Northern Ireland on NIBuinsessInfo: Packaging producer obligations - individual route
Scotland on Business Gateway: Packaging producer obligations - individual route
Wales on Business.Wales.gov.uk: Packaging producer obligations - individual route

Good practice

Minimise the volume of packaging that you use, and maximise the amount of packaging you recycle. You could:

  • introduce returnable and reusable packaging in cooperation with your supply chain and customers
  • shred old paper to reuse as packaging filling
  • keep old bubble wrap or polystyrene to reuse as packaging
  • reuse packaging such as wooden pallets, cardboard boxes or padded envelopes
  • buy a compactor or baler to crush packaging into blocks - you will be able to transport larger volumes of packaging, which will reduce your recycling or disposal costs
  • separate different types of packaging for recycling to reduce your recycling costs
  • buy from suppliers that minimise packaging in their products
  • buy from suppliers that use recyclable or biodegradable packaging
  • try to reduce the packaging in your own products - if the boxes you use are several times larger than the product inside, redesign them
  • make use of the free resources available from Envirowise to improve efficiency.

Envirowise

Buy goods in bulk to reduce packaging. For example:

  • buy paint in one 5 litre drum, instead of buying five individual one-litre drums
  • buy a bigger jar of coffee once a month, instead of buying smaller jars every week.
You could also:

  • use recyclable or biodegradable materials to package your products
  • remove disposable plastic cups from drinks machines, and ask staff to use their own mugs instead
  • when organising events, meetings or conferences, use bowls of sugar, jugs of milk and reusable or biodegradable cutlery instead of many small, individually packaged products
  • buy recycled office stationery that uses recyclable or biodegradable packaging.

Use directories to find local recycling services for your packaging.

Find your nearest waste site
Lets Recycle: Recycling and waste directory
Northern Ireland Waste Works

Further information on packaging regulations

Department for Business, Innovation & Skills (BIS): Packaging guidance