Fashion Packaging EPR Compliance
From polybags to tissue paper, fashion brands handle more packaging types than almost any other sector. Our platform makes tracking and reporting it simple.
Fashion EPR: What You Need to Know
The UK fashion industry is one of the sectors most affected by Extended Producer Responsibility regulations. Fashion businesses — from high-street retailers to independent DTC brands — typically handle a wide variety of packaging materials across their supply chain, making EPR compliance particularly complex.
Whether you are a clothing brand importing finished garments from overseas manufacturers, a UK-based fashion label shipping direct to consumers, or a wholesaler distributing to retailers, your packaging obligations depend on the role you play in the supply chain. The key question is: which obligated activities do you perform?
For most fashion brands, the primary obligation falls under "packing/filling" (putting products into packaging) and "selling" (selling packaged goods to consumers). If you import finished goods, you are also an "importer" and take responsibility for all packaging on those products — including the polybag the manufacturer used at the factory.
Fashion packaging is uniquely diverse. A single garment order might include a polybag, tissue paper, a swing tag, a branded sticker, a mailer bag, and a cardboard shipping box. Each of these is a separate packaging item that must be tracked by material type and weight. Our platform is designed to handle exactly this level of complexity, with pre-configured packaging templates for common fashion items.
One area that frequently catches fashion businesses out is the distinction between primary, secondary, and transit packaging. The polybag around a garment is primary packaging (it directly contains the product). A branded box containing multiple polybag-wrapped items is secondary packaging. The corrugated box used to ship from warehouse to store is transit packaging. DEFRA requires you to report each category separately.
If your fashion business has an annual turnover exceeding £1 million and you handle more than 25 tonnes of packaging per year, you are an obligated producer. Small producers (turnover £1-2 million AND more than 25 tonnes, or turnover above £1 million AND 25-50 tonnes) report annually with data due by 1 April. Large producers (turnover £2 million+ AND more than 50 tonnes) report every 6 months — H1 data due by 1 October, H2 data due by 1 April. Charities are exempt from EPR obligations.
Understanding the fee rates is essential for budgeting. For 2025-2026, the confirmed base fees per tonne are: plastic at £423 (relevant for polybags and mailer bags), paper and card at £196 (relevant for tissue paper, cardboard boxes, and swing tags), and wood at £280 (relevant for wooden hangers). A fashion brand using 10 tonnes of plastic polybags and 20 tonnes of cardboard would face annual EPR fees of approximately £8,150. From 2026-2027, fees will be modulated based on the Recyclability Assessment Methodology (RAM), meaning less recyclable packaging will attract higher charges.
All submissions are made via DEFRA's Report Packaging Data (RPD) portal, and the scheme is administered by PackUK. Our platform generates reports formatted exactly as the RPD system expects, so you can export and upload without any reformatting.
Common Fashion Packaging
These are the key packaging types you need to track and report for EPR compliance in the fashion sector.
Polybags
Clear plastic bags used to protect individual garments during storage and shipping. One of the most common packaging types in fashion. Typically LDPE (Low-Density Polyethylene), these must be reported under the plastic material category.
Cardboard Boxes
Corrugated shipping boxes used for wholesale and direct-to-consumer orders. Includes branded retail boxes and gift packaging. Report under paper/card material category.
Tissue Paper
Acid-free tissue paper used to wrap garments, often branded. Counts as primary packaging under EPR and must be reported by weight under paper/card.
Garment Tags & Labels
Swing tags, care labels, and branded packaging inserts. These all count towards your packaging weight. Report card tags under paper/card and plastic labels under plastic.
Mailer Bags
Plastic or paper mailing bags used for DTC e-commerce shipments. Often branded with logos. Increasingly available in compostable or recycled materials.
Hangers & Clips
Plastic or wooden hangers shipped with garments, plus clips and pins used for display or transit. Report by the appropriate material category (plastic or wood).
What You Need to Do
As a fashion business handling packaging, you have specific EPR obligations under the UK's Extended Producer Responsibility scheme. Here is what you need to track and report to stay compliant.
- Track and weigh all primary packaging (polybags, tissue, tags)
- Record transit/secondary packaging (shipping boxes, pallets)
- Submit data to DEFRA via the RPD portal (6-monthly for large, annual for small producers)
- Pay EPR fees based on packaging weight and material type
- Distinguish between packaging you supply and packaging you import
- Keep records for at least 7 years for audit purposes
Do you need to comply?
You are obligated if your business:
- • Has an annual turnover exceeding £1 million
- • Handles more than 25 tonnes of packaging per year
- • Performs any of the obligated activities (manufacturing, importing, selling, hiring)
Even small producers below these thresholds must register as small producers under the National Packaging Waste Database (NPWD).
Common Fashion Compliance Mistakes
Avoid these frequent pitfalls that catch out fashion businesses every year.
Ignoring polybag weight
Polybags seem lightweight individually, but at scale they add up to tonnes. Many fashion brands underreport because they don't weigh individual polybags. Use supplier spec sheets for accurate gram weights.
Forgetting tissue paper
Branded tissue paper is packaging under EPR rules. If you wrap garments in tissue before boxing, you need to report its weight. This catches out many luxury and mid-range fashion brands.
Missing transit packaging
The cardboard and plastic used in wholesale shipments from factories counts as transit packaging and must be reported separately from primary packaging. This includes pallet wrap and corner protectors.
Not tracking seasonal variations
Fashion is seasonal — your Q4 packaging volume during holiday sales may be 3-4x your Q1 volume. Report accurately per period rather than averaging across the year.
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