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EPR Exemptions & Declarations

Reasons your organisation may be exempt from PB Group
charging you the EPR Household levy and how to declare it

When do EPR exemptions apply?

The EPR levy applies to all ‘Household Packaging’ PB Group supplies, but we can cater for exemptions to suit your organisation.

This page outlines a range of EPR exemptions that may apply to you – to your business as a whole, or for specific products or specific orders placed with PB Group.

If you qualify for one of these exemptions, we can remove the EPR Household Packaging levy from your prices once you have submitted a declaration of exemption.

If you know your organisation is exempt, you can register a company-wide declaration of exemption online. For all other declarations, please speak to your PB Group sales agent or account manager when you place an order.

We also offer the flexibility to change your default exemption status for specific products or orders, as required.

What are the most common reasons for an EPR exemption?

Products are to be exported outside of the UK

EPR only applies to UK packaging waste, so if your order is to be exported for use or resale abroad, EPR charges do not apply.
1

Your company is EPR-registered and you complete your own EPR reporting and fee collection

EPR 'Household' levy only needs to be paid once for every packaging product on the UK market. If your company is EPR registered and you submit your own EPR returns and fees, we can remove the EPR levy from your PB Group orders.
2

Your organisation is a charity or not-for-profit

If you are a charity or a not-for-profit organisation, you may be exempt from EPR or subject to different EPR thresholds. These exemptions are typically based on your organisation's legal structure and turnover.
3

Your packaging is for internal business use

EPR is only liable on packaging that ends up in UK domestic waste streams. If you are buying packaging for internal company use and you know that it will end up in your business waste, then EPR may not apply.
3

Products are not considered packaging under EPR legislation

Some products may not qualify as regulated packaging under current definitions (e.g. durable containers sold as part of the product). You may wish to declare these items outside the scope of EPR to remove the EPR levy.
4

You are a re-seller who will pass on EPR further down the chain

In some B2B chains, responsibility for EPR is passed on to the final UK seller or brand owner. If you are an intermediary in one of these chains, let us know and we may be able to remove EPR fees.
6

You have an industry-specific EPR exemption

Certain industries - including the medical, chemical, and food industries - have narrow exclusions for regulated packaging, especially where regulatory packaging is required by law. If you have an industry-specific EPR exemption, we won't include EPR fees in your order.
5

This list is not exhaustive, but covers some of the most common reasons that companies might be exempt from EPR.

If you are unsure as to whether any EPR exemption applies to your business, please speak to your PB Group sales agent or account manager. If you know that your company is exempt from EPR, you can make a company-wide declaration of exemption.

What is Household packaging?

Understanding whether packaging is classified as household or non-household is a fundamental part of EPR. This distinction affects how you assess and report your packaging, and ultimately the fees you need to pay.

There is an essential distinction between what the new EPR legislation classes as household packaging and what is deemed industrial or transit packaging.

Household packaging is used by individuals and ends up in houses and other consumer premises. This definition covers primary packaging such as those for consumer goods, food and drink, alongside postal packaging used for eCommerce.

EPR fees will not apply to secondary and tertiary packaging, mainly covering that used to transport goods in B2B applications.

What packaging data do businesses need to report for EPR?

Producers need to gather accurate data on the type, weight, and material of all packaging they place on the market. This includes specific details on each material used, considering its recyclability. Producers should also capture data on the intended use, such as household or business packaging, to ensure compliance with EPR requirements. Collecting this data thoroughly helps streamline reporting and supports sustainable choices across the supply chain and ensures accurate payments.

What declarations of EPR exemption are offered by PB Group?

PB Group can provide an EPR exemption for any of the following, subject to a declaration of exemption:

Product

An exemption for a certain product whenever you order it

If you regularly order a product from PB Group that is exempt from EPR, you can declare that exemption and PB Group will remove the EPR levy from that particular product whenever you order it, even if other products in those orders require EPR to be paid.

Your UK-based retail company orders carrier bags and mailing bags from PB Group for customer use, along with bin bags and recycling sacks to manage your internal waste. You know that the waste sacks will always end up in your business waste, so you can declare a product exemption to remove the EPR levy from these products in the future. EPR will continue to apply to the carrier bags and mailing bags, as these products will end up in domestic UK waste streams.

A company-wide exemption that applies to all orders, by default

If you declare a company-wide exemption, your PB Group orders will be exempt from EPR by default. We will remove the EPR levy from your entire order unless otherwise instructed (we can turn this exemption off on request).

Your company is registered for EPR purposes as a large producer, so you submit your own EPR returns and pay EPR fees.

EPR only needs to be paid once on each product, so if you declare a company-wide exemption to PB Group, we will remove the EPR levy (in full) from your future orders, by default, so you don’t pay twice.

If you need us to re-apply the EPR levy for a future order, or a specific product in a future order, just let us know and we can do that for you.

Item in an Order

A one-off exemption for specific product(s) in an order 

If you order a number of products from PB Group together and some – but not all – of these products are exempt from EPR, then we can remove the EPR levy on those specific products, once an EPR declaration has been made.

You are an online retailer who delivers to customers in the UK and Ireland. You purchase printed mailing bags from PB Group for your deliveries. These bags are ordered with different designs – including return instructions – and so they are listed as separate items in your order. You must pay EPR on your mailing bags for UK customers, but your mailing bags for Irish customers will be exported outside of the UK, so these are exempt from EPR.

Order

A one-off exemption for an entire order

If you place an order with PB Group where all of the products are exempt from EPR, then you can get an exemption on that entire order, subject to a declaration being made on that order. PB Group will then remove the EPR levy from all products in that order.

You are a packaging re-seller and the majority of your customers are UK-based, which means your orders are usually subject to EPR. You receive a large order from a company in France and so you place an order with PB Group to fulfill that order. That whole order is exempt from EPR, subject to declaration, as it is destined for outside of the UK.

PB Packaging Group Ltd, Lyon Way, Greenford, Middlesex, UB6 0AQ | Company No. 00698834 | Vat Reg: GB 226 5049 73