Tertiary packaging and the new UK EPR rules: What warehouses need to report in 2026 and beyond

Stretch film, strapping, shrink hoods and pallet boxes might never reach customer’s hands, but that doesn’t put them outside the scope of EPR. For warehouse and logistics teams, these materials can represent a significant, and often overlooked, part of their packaging footprint, with accurate reporting now more important than ever.

So where does tertiary packaging sit within the UK EPR framework, and what does that mean for the teams responsible for moving and protecting goods? In this guide, we’ll break down what tertiary packaging needs to be reported, the data warehouses need to capture, how material choices can affect costs, and the practical steps teams can take now to prepare for the next reporting window.

Where tertiary packaging sits under EPR

Under UK EPR, packaging is broadly categorised as primary, secondary or shipment/transit packaging. Tertiary packaging falls into the shipment/transit category, covering materials used to protect and secure goods during storage and transport.

That means everyday warehouse materials such as stretch film, strapping, shrink hoods and pallet boxes can be in scope. The fact that packaging is used internally or within B2B supply chains does not automatically exempt it from reporting.

It’s also important to distinguish between household and non-household destinations, as this affects how packaging is classified and counted for EPR purposes. For warehouses, understanding where packaging is supplied and ultimately discarded is therefore just as important as tracking how much is used.

What warehouses actually need to report

For warehouse teams, getting EPR reporting right starts with capturing the right data. Key information includes:

• Packaging weights by material: Record the weight of materials such as stretch film, steel, polyester or PET strapping, corrugated packaging and shrink hoods.
• Single-use vs reusable: Keep these separate, for example, distinguish reusable pallet boxes from single-use stretch wrap.
• Nations data: Track where packaging is supplied and where it is discarded.
• Reporting frequency: Large organisations generally report twice a year, while smaller organisations report annually.

Why material choice on the pallet now has a cost attached

Under EPR, the material used to protect and secure goods can affect the fees a business pays. The RAG/RAM assessment and bonus-malus system considers how easily different packaging materials can be recycled, with this approach also relevant to tertiary packaging.

For warehouses, this means materials such as certain plastic stretch films and strapping may fall into amber or red categories, potentially resulting in higher modulated fees.

More recyclable alternatives, including paper strapping, honeycomb wrap and corrugated pallet boxes, may qualify for lower fees where they achieve a more favourable assessment.

The result is that material choice is no longer just a question of performance and price. The packaging selected for every pallet can also have an impact on EPR costs.

The reporting gap most warehouses don't realise they have

For many warehouses, the challenge isn’t knowing that packaging needs to be reported, it’s having the right data to hand. Tertiary packaging is often treated as “just for shipping”, meaning usage can be overlooked or recorded less consistently than customer-facing packaging.

Common gaps include:

• Inconsistent usage records: Stretch film consumption, strapping volumes and pallet box reuse may be recorded differently across sites, shifts or departments, making it difficult to build a reliable picture of total usage.
• Spend rather than weight: Packaging is often tracked through purchasing data or cost rather than the actual weight of material used. However, EPR reporting requires accurate packaging weight by material type.
• Reusable packaging not separated: Returnable pallet boxes and other reusable items need to be distinguished from single-use materials such as stretch wrap, so these figures can be captured correctly.
• Limited material-level data: Without knowing exactly what materials are being used, and in what quantities, it becomes harder to assess reporting requirements and understand potential EPR costs.
• Last-minute data gathering: If records aren’t captured as part of everyday warehouse processes, teams can end up reconstructing months of packaging usage at reporting time, increasing the risk of inaccurate or under-reported data.

Practical steps for warehouse teams ahead of the next reporting window

Getting ahead of EPR reporting doesn’t need to mean a major overhaul. A few practical changes to how tertiary packaging is tracked can make the next reporting period much easier to manage.

• Audit materials by weight: Review the tertiary packaging currently in use and record actual weights, rather than relying solely on purchasing spend or number of units.
• Separate single-use and reusable packaging: Keep materials such as stretch wrap separate from reusable items like returnable pallet boxes.
• Review material choices: Check pallet wrap, strapping and other transit packaging against their RAM ratings and consider whether alternative materials could reduce future EPR costs.
• Make data capture part of the process: Build packaging data collection into routine warehouse operations, so accurate figures are available throughout the year rather than having to reconstruct them at reporting time.

How Swiftpak helps warehouses get ahead of reporting

With EPR making material choice, usage and reporting increasingly important, having the right tertiary packaging strategy in place can help warehouses stay ahead.

Swiftpak supplies a wide range of tertiary packaging solutions, from pallet wrap and strapping to corrugated and paper-based alternatives. Our team can help you assess your current packaging, identify lower-impact options and make more informed choices with EPR requirements in mind.

Want to get ahead of your next reporting period? Talk to the Swiftpak team about auditing your current tertiary packaging and identifying opportunities to improve both reporting and material efficiency.