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) |
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| 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 | |||