In 2007 the guidance on imported items put into bonded warehouses in the UK was reviewed by the Environment Agency, Scottish Environment Protection Agency and Northern Ireland Environment Agency.
They came to the conclusion that the obligated party would be the company who imported the goods into the UK and took first legal title of the packaging.
There are no exceptions or special cases with regard to imports placed into bonded warehouses – please see the following quote taken directly from the Environment Agency’s Agreed Positions document (Dec 2011)
“‘Import’ in the Packaging Regulations 2007 has its ordinary meaning. It is not linked to the payment of tax or duties nor to the nationality of the company that owns the goods. The regulations do not make a special allowance for imported products that are placed into bonded warehouses.
Our view is that the obligation should rest with the importer – the person who brought the goods into the UK.”