B7.3.1.1 Packaging (Essential Requirements)


 The Packaging (Essential Requirements) Regulations [SI No. 1941]

These regulations aim to minimise the amount of waste packaging generated at source and ensure that packaging can be reused, recovered or recycled. They may apply if you:

  • Produce packaged products.
  • Design or specify packaging.
  • Import packaged goods or filled packaging into the UK.
  • Sell packaged goods or filled packaging.
  • Place packaging or packaged goods on the market.


The regulations apply regardless of your business’ turnover and the quantities of packaging produced, handled or filled. However, they do not apply if your packaging:

  • Was manufactured on or before 31 December 1994.
  • Was placed on the market on or before 31 December 1999.
  • Is made entirely from lead crystal.


The requirements are to:

  • Minimise packaging weight and volume.
  • Make sure packaging can be recovered. Some or all of the packaging must be able to either: be recycled, have energy recovered from it, or be composted or reused. This can be achieved by:
    • Producing packaging that is reusable by increasing its durability.
    • Ensuring packaging has a minimal impact on the environment after disposal.
    • Ensuring sure packaging is manufactured to contain minimum levels of hazardous substances.
    • Limiting the amount of cadmium, mercury, lead and hexavalent chromium, or any combination of these heavy metals to less than 100 parts per million (ppm) by weight.
  • Keep records as evidence that your packaging is compliant, for at least 4 years after the date the packaging was first placed on the market.


Some British standards will help to clarify the Essential Requirements. These may be used these to show that you comply with the regulations. The following standards are relevant:

  • BS13428:2004 – Source Reduction
  • BS13429:2004 – Reuse
  • BS13430:2004 – Material recovery and recycling
  • BS13431:2004 – Energy Recovery
  • BS13432:2000 – Composting and biodegradation


Partial exemptions

You can apply for a partial exemption from the Essential Requirements for plastic pallets, plastic crates and glass packaging. This allows the concentration of regulated heavy metals to exceed the limit of 100 parts per million (ppm) if other criteria are met.

Glass packaging containing regulated heavy metals and recycled materials is also partially exempt from the regulations. If recycled materials have been added to the glass packaging, the average heavy metal concentration of each item should not be more than 200ppm. This only applies if no regulated metals are introduced to the packaging during its manufacture.