You would need to check that you aren’t performing any other activity that would bring you into obligation. Its not just importing, but also, for example brand ownership, online sales, first UK owner, or filling packaging etc. Please refer to the guidance.Â
You may have to submit data if they are a ‘small producer’ i.e. they supply more than 25 tonnes of packaging.
Defra state Small organisations should:
There are other considerations to bear in mind, such as how turnover is calculated, deadlines, and group or subsidiary roles.