For packaging items not included in the following table, it is assumed to be obligated unless the producer can justify its exclusion reasonably, in discussion with the Environment Agencies. Some items may be used for a presentation/marketing function, and in reality are not likely to be kept after the initial use.

Item Obligated Comments
Barbecue foil trays (for disposable BBQ) No Integral part of product
Barrels and kegs Yes Obligated on first trip
Basket for presentation of goods Depends Presumption is that basket performs packaging (presentation, containment etc.) function and is obligated
Biodegradable packaging Yes For example, starch based material – still packaging (analogy with paper)
Blood bags No Not part of sales unit. Blood is neither bought nor sold in Great Britain
Boxed sets of books (boxes) No Providing it is the intention and likelihood that books will be stored in the box
Boxes containing tools No Usually for long term storage (for example, drill case)
Cash bags No Cash not goods, therefore since Regs talk about packaging around goods, cash is specifically excluded (Judgment late 2006)
Card boxes for calligraphy pens, model kits etc. Yes Not considered long term storage
Carrier bags Yes Unless sold to end user as a product (for example, bag for life)
Catalogues Depends If the catalogue is requested then associated packaging is obligated. If catalogue is unsolicited counted as junk mail, so not obligated
CDs-plastic film Yes Protective packaging function
CDs-cardboard sleeves No Usually long term storage
CDs-lyric books/inserts No Part of product
CDs-plastic (‘jewel’) cases for CD’s No Long term storage. However, the multi-pack case with the spindle, base and hard plastic cover would all be regarded as packaging. This is because it is not regarded as long term storage
CDs – plastic (‘jewel’) case for goods other than CDs (for example, iron on patches) Yes Protection function – once patches are removed, case usually discarded
CD cases for promotional goods Depends Need to consider type of CD: If for time limited offer (for example, internet access), yes obligated
Ceramic pot containing biscuits Depends Presumption is that pot performs packaging (presentation, containment etc.) function and is obligated. If producer can show clear intent and likelihood for use as long term –term storage, not obligated
Cheese rinds/wax No Excluded by amendment directive 2004/12/EC
Coat hangers Depends If supplied with goods or option to have hangar is given, then obligated. Hangers sold as a product are not obligated.
Collectors toys – boxes No Product intended to be kept with box for lifetime. Labels still obligated
‘Cool packs’ Depends Reusable plastic ‘ice packs’ are product. Single trip ‘cool packs’ made up of foam pads, liquid and cardboard sleeve packaging and perform protection function
Cores, reels, spools Depends See Freight (road, rail ship and air) containers
Cosmetics in mock cases Yes Unlikely case would be kept after product consumed
Crayons-paper sleeves No Part of product
Credit/bank card packaging No Not considered to be goods
Cups (plastic) supplied with bottles/cans/packaged drinks No No packaging function
Cups – disposable, in which drinks are provided (for example, tea/coffee) Yes
Cut out templates on card boxes (for example, mask on cereal box) Yes Part of box performing packaging function
Display stands No Unless being used for a packaging function prior to being used for display (for example, for transport of goods)
Dosage delivery caps (for example, medical) Yes But only if an integral part of the container for example, forms part of the closure
Dunnage (packaging around goods in holds of ships) No Usually old, re-used bits of wood etc
Dunnage (bearers and sticks in timber trade) Yes
Envelopes for greeting cards No Product
Film-canisters Yes
Film-rolls containing the film No Product
Fire extinguishers No Product
First Aid kit boxes No Long term storage
Fumigant canisters Yes Canister performs a packaging function
Games boxes No Long term storage
Gas Cylinders Depends Commercial and industrial cylinders not obligated. Camping gas containers and aerosols obligated
Gift Voucher envelopes No As card envelopes, product
Glass containing wax beads and candle wick Depends Presumption is that glass performs packaging (presentation, containment etc.) function and is obligated.
Glue Yes Declare separately when applied at conversion or pack/fill stage, but not at manufacturing stage. At other stages, it will be included in the overall weight of the packaging material
Grow bags No Considered integral part of the product
Haggis skin Yes Packaging
Hat boxes No Long term storage
IBCs Yes Analogy with pallet containing packaged goods
IBC liners Yes
Inhaler –Plastic holder No Product
Inhaler-Cartridge Yes Packaging
Inhaler (asthma or nasal) – whole unit disposable Yes All packaging
Ink Yes Declare separately when applied at conversion or pack/fill stage, but not at manufacturing stage. At other stages, it will be included in the overall weight of the packaging material
Jars (designed to be tumblers after use) Yes

After use is irrelevant. Presumption is that glass performs packaging (presentation containment etc.) function and is obligated.

If producer can show clear intent and likelihood for glass to be kept and used, not obligated (beware of ‘gimmicky’ items not likely to be kept)

Jewellery/watch boxes Yes (see comments) In exceptional circumstances where box is specifically designed and bespoke, it may be considered as long term storage and not packaging.
Junk Mail No Not regarded as goods and therefore associated packaging not obligated. If an item ordered is a sales unit (for example, paid for catalogue) , this is regarded as goods and associated packaging is obligated
Kebab skewer No Part of Product/sales unit
Knives and forks – disposable No No packaging function
Labels Depends See label, above for table
Laundry/dry cleaning packaging Yes Pack/Fill and sell
Lighters – disposable No Whether refillable or not
Lipstick tubes Yes
Liquid correction fluid brush Yes Integral part of a packaging component
Lolly stick No Part of product/sales unit
Manicure set case Depends If intent is for long term storage, not packaging
Mascara brush Yes Where it forms part of the lid, not where sold as a product in isolation
Masterbatch Depends No obligation for manufacturers. Converters account for pigment as part of overall weight of plastic packaging produced and supplied.
Match boxes Yes
Meat packaging -absorbent paper Yes Forms part of sale unit
Mobile phone top up card packaging Yes Card is a sales unit and therefore packaging is obligated
Nozzles (for sealant dispensers) Yes If also forming the function of a closure
Pencil cases/purses with sweets No Pencil cases/purses are product
Pallet nails Yes The converter will declare the weight used. Pack/fillers and sellers will not be expected to determine the individual weight of the nails, but take the overall weight of the pallet.
Party poppers No Container, card top and string are all considered to be part of the product
PC games/software boxes No Considered long term storage
Pens-disposable No Product
Petri dishes containing agar No Product
Photograph wallets No Long term storage
Outer envelopes containing photograph wallets Yes Whether postal or collected
Plant ID labels Yes Presentation function
Plant pots Yes Except when biodegradable and intended to be planted with the plant, or when sold containing a plant intended to stay in the pot for example, a house/patio plant
Plates-disposable No Product where supplied separately
Postal packaging Depends Usually no. If they contain goods, the packaging is obligated. Envelopes for junk mail, statements etc. are not packaging since they do not form part of a sales unit
Pre-packed sandwich cake cartons Yes Performs protection/presentation functions
Presentation packs Yes Contains products
Printer cartridges No Part of product
Promotional leaflets/poster/freebies and associated packaging Yes Packaging around promotional goods supplied is regarded as packaging
Razor handle holders No Regarded as long term packaging
Razor blade holders Yes The plastic tray holder containing the razor blades is packaging
Removal boxes No Not normally part of a sales unit
Re-used packaging Depends Yes if imported. No where on second and subsequent trips, but obligated on first trip
Roll cages Yes Same as pallets, unless internal supply
Roll on deodorant Yes
Room deodorisers (plastic outer for re-filling) No Durable, part of product
Saline bags Yes Sales unit containing product
Santa Claus cards (replies from Royal Mail) – associated packaging No Not considered goods
Sausage skins No Part of product
Security tags on CD’s Depends Tags which do not perform any packaging functions are not obligated. If they act as a closure (for example, label on CD opening), they are obligated
Silica gel bags (desiccants) Yes Protection function, therefore obligated
Skip bags (pre paid) No Not part of a sales unit
Spectacle cases No Long term storage
Spoons/leaflets with medicines No No packaging functions
Sterile medical packaging Yes Protection function, therefore packaging. The FACT that it’s sterile does not remove the potential for being obligated.
Stillages (for example, metal open crates used in the automotive industry) Yes Transit packaging on first trip (not a road/rail/ship container
Storm matches – boxes Yes Match box performs packaging functions
Sunglasses – tags and labels (for example, UV rating; care instructions etc) Yes Presentation packaging function
Tea bags No (but see comments) Integral part of product, including string in drawstring teabags. String, label and staple attached to ordinary teabags are obligated
Tea lights – foil cups No Integral part of product
Toner cartridges No Part of product
Toys in boxes and trays (for example, small figures) Yes Boxes and trays considered to be disposed after opening
Totes (plastic crates) Yes For first trip only. Not obligated if only used for internal transfer.
Trays – bread Yes When supplied (including hiring and lending – service provider) with goods (on first trip only)
Trays – disposable food tray Yes Protects and presents food
Tray – durable food tray No No packaging function
Urine bags No Not part of sales unit. Urine is neither bough nor sold in Great Britain.
Vending toys (‘egg’ container) Yes
Video card boxes No Long term storage
Water filter cartridges (containing membrane) No Part of product
Wooden bucket with shower goods No Intention is for long term storage
Wrapping paper Depends No when sold as a product. Yes and when used to wrap goods for supply

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