How to Record Tertiary Packaging for UK EPR: Your Options Explained

If your business supplies goods using pallets, shrink wrap, trays, or other outer packaging, then you’re dealing with what’s known as tertiary packaging — and under the UK’s Extended Producer Responsibility (EPR) regulations, you’ll need to report it.

But how exactly should you record it?

The good news is that the regulations offer flexibility. You don’t have to measure every piece of tape. What’s required is a method that’s accurate as far as reasonably possible, documented, and repeatable — one that reflects the packaging you actually use in practice.

There are four main approaches, all of which are supported by PackTotal. Each has its place depending on how your warehouse operates, and we’ve outlined them below to help you choose the one that fits best.

1. Order-Based Tracking

How it works: You record packaging based on the type of order. For example, a large wholesale shipment might always use a pallet and shrink wrap, while a smaller parcel goes into a box. This approach relies on predefined packing rules linked to order size or weight.

Ideal for: Warehouses with standardised packing procedures or automated picking systems.

Why it’s compliant: Regulators accept this method as long as it’s clearly documented and applied consistently. You’ll need to keep a record of the rules and show that they reflect your actual processes.

In PackTotal: You can configure rule-based logic that automatically assigns packaging based on order characteristics.

2. Stocktake / Usage Tracking

How it works: Instead of estimating what each order uses, you calculate your packaging use by tracking stock levels over time:

• Opening stock + purchases – closing stock = packaging consumed

Ideal for: Businesses with manual packing processes, multiple packing types, or limited systems integration.

Why it’s compliant: This method is considered direct measurement. As long as stock records are accurate and verifiable, it provides a clear audit trail of actual packaging use.

In PackTotal: You can enter weekly or monthly consumption figures, and PackTotal will calculate the associated packaging weights automatically.

3. Product or BOM-Based Tracking

How it works: You assign standard packaging configurations to each product or product group (e.g. “Product X always ships on 1 pallet with 20 metres of shrink wrap”). These assumptions are based on your Bill of Materials (BOM) or internal specs.

Ideal for: Manufacturers and suppliers with consistent, repeatable packing specifications.

Why it’s compliant: As long as the BOM reflects real-world practice — and is reviewed periodically — this approach is accepted under the EPR regulations. You’ll need to document your assumptions.

In PackTotal: Packaging can be defined per product or component, and reused across multiple SKUs to avoid duplication.

4. Integrated Tracking per Sale

How it works: This is the most precise method. Your system records the actual packaging used for each order, typically via an integrated ERP, WMS, or despatch system. For example, the system might record: “Order 1234 used 1 pallet, 2 corner protectors, and 1.5kg stretch film.”

Ideal for: Businesses with advanced systems and real-time tracking capabilities.

Why it’s compliant: This is the most precise approach available, and it’s encouraged by regulators where feasible. It provides the clearest evidence that your reports reflect actual packaging usage.

In PackTotal: You can import or enter this data directly or use API links to external systems if available.

Which Method Should I Use?

There’s no one-size-fits-all answer. The best method for you depends on:

• How consistent your packing processes are
• What data you already collect
• What systems you use

Each method is compliant, as long as it’s applied consistently and supported by records.

And if your processes change? No problem. You can switch methods as needed — just keep a note of what you changed and when.

PackTotal Makes It Easy

Whichever approach you use, PackTotal is built to support it. From simple rule-based setups to detailed per-despatch tracking, the system offers flexible options to match your operational reality. You can:

• Apply allocation rules per order
• Record consumption figures from stocktakes
• Link packaging to products and BOMs
• Import packaging records per despatch

It’s all backed by clear audit trails and reporting tools designed with EPR in mind.

Many businesses start with one method and refine it over time — PackTotal makes that evolution smooth. You can begin simply and build toward more detailed tracking without losing data or retraining your team. We’ve designed the system to help you stay compliant and work efficiently.

If you’re planning to implement or upgrade your packaging data processes using PackTotal, we’ll work with you to make sure the method you choose fits your setup and meets regulatory expectations.

Interested in seeing how PackTotal can help?
Contact our team — we’ll be happy to show you what’s possible.