With regard to Shared Producer Responsibility, if a product or packaging is imported, there are certain points that define which company is obligated.

The first organisation to come into contact with any imports as they arrive into the United Kingdom, or takes the first legal title of the imports, is obligated for any activities carried out on the imports before they arrived into the UK.

This is known as a rolled-up obligation. With reference to the Shared Producer Responsibility – which details that each stage in the packaging chain picks up part of the overall obligation – any company that imports will take on the obligation for any activities that were carried out on packaging before it entered the UK.


A company imports cardboard cases to fill them with their products before selling them on to a wholesaler. This means that the company are importing the cardboard at the Pack/Fill stage. As such, they take on the obligation for all activities carried out on the cardboard before the Pack/Fill stage too. These would be as follows: Raw Material Manufacturing – 6% and Conversion – 9%. This means before any activities have been carried out on the packaging, the company are obligated for 15% of the packaging as their rolled-up obligation. The company are still obligated for any further activities carried out on the packaging also.

Imported then Exported

Any packaging that is imported and subsequently exported is treated differently: It does not need to be taken into account. This is because it doesn’t become waste in the UK. This only applies, however, where it is the same packaging that is imported and then exported. This does not apply if there is merely a similar tonnage of imports and exports but different items/materials.

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