• Example: Company A undertakes contract packing for Company B. Company B provides Company A with 100 tonnes of their own brand packaging, retaining ownership of this packaging. Company A is not obligated because they do not own the packaging. Company B needs to pick up the obligation for this packaging.

Activity Raw material manufacturer Converter Packer / Filler Seller Importer	Example A manufacturer of sheet steel to be made into packaging A manufacturer of steel cans A company filling cans with food A retailer selling canned goods to the end users A wholesaler importing canned goods from Europe

Remember: You may fall into more than one category.

When working out if you handle 50 tonnes of packaging, include:

• imports of packaging or packaging materials
• special producer packaging

• packaging that you throw away (unless imported)
• any packaging that is exported by you or your customer
• packaging that has been used once before (e.g. reusable crates)
• packaging that you do not legally own (e.g. pallet rental)
• production residues (process waste)

As with the turnover threshold, businesses which are sites or subsidiaries of an organisation must combine their tonnage handled. If this combined tonnage exceeds 50 tonnes then all parts of an organisation must register, even if individually they handle less than 50 tonnes. Companies can either register separately or as a single group.

• Example: Companies A, B and C are part of a group operating in Great Britain. Companies A, B and C handle 15, 40 and 20 tonnes of packaging respectively. The combined tonnage for the group exceeds the threshold and this means all three companies could be obligated. Companies A, B and C could either register separately, or as a single group.