Amazon, eBay and online sellers

Selling through Amazon, eBay, Etsy, OnBuy or your own website doesn't change the basic test. If your business is established in the UK, supplied more than 25 tonnes of packaging in the previous year and has worldwide turnover of £1 million or more, you're an obligated producer. Use the threshold grid to see whether you're small or large.

Your packaging activities as an online seller

Online sellers usually do one or more of these GOV.UK packaging activities:

• Supplying under your brand: filled packaging carrying your brand, even if a manufacturer or importer packs it for you.
• Packing or filling: putting goods into unbranded packaging, such as plain boxes or mailers.
• Importing: bringing in goods in packaging, for example from overseas factories, where you're responsible for the import.
• Selling: selling filled packaging to the end user. GOV.UK says this packaging must always be counted in your threshold calculation unless you've already counted it under another activity.

Boxes, mailers and bubble wrap count

Packaging means anything used to contain, protect, handle, deliver or present goods. GOV.UK's reporting guidance calls packaging on goods sent to consumers shipment packaging, a kind of tertiary packaging. It names goods sold online and gives cardboard boxes, carrier bags, bubble wrap and mail bags as examples. Count it as well as the product packaging.

Does Amazon or eBay report it for me?

Only in one case. Under regulation 20 of the 2024 regulations, an online marketplace operator is the producer for packaging on items sold through its marketplace by non-UK suppliers and received in the UK. GOV.UK tells marketplace operators not to use this activity for goods from UK organisations.

So if you're a UK-established seller, the marketplace does not take on your packaging. You count it yourself.

Selling on your own website

Running your own shop, for example on Shopify, isn't the 'online marketplace' activity. That only covers websites or apps that let non-UK businesses sell into the UK. You report your packaging under your other activities.

Extra points for online sellers

• Bags in England: small producers must collect data on plastic and paper bags supplied in England, following the Environment Agency's regulatory position statement.
• Nation data: GOV.UK's large-producer guidance says you must record nation data if you sell filled packaging direct to an end user.
• Selling only to end users: large producers whose only packaging activity is selling filled packaging to end users have until 1 April 2027 to apply to register for 2027.

Quick answers

Do Amazon and eBay sellers need to comply with packaging EPR?

Yes, if the seller is established in the UK, supplied more than 25 tonnes of packaging in the previous year and has worldwide turnover of £1 million or more. The same thresholds apply as for any other business.

Does Amazon report packaging EPR data for my products?

Only for non-UK sellers. Under regulation 20 of the 2024 regulations, an online marketplace operator is the producer for packaging on goods sold by non-UK suppliers and received in the UK. UK-established sellers count their own packaging.

Do delivery boxes and mailers count towards packaging EPR?

Yes. GOV.UK calls packaging on goods sent to consumers shipment packaging, and gives cardboard boxes, carrier bags, bubble wrap and mail bags as examples.