GeiG Environmental Packaging Policy (EPR) – v1.1

1.0 Purpose
1.1 We set minimum and improving standards for packaging that protect products while minimising environmental impact and meeting UK Extended Producer Responsibility (EPR) obligations.
1.2 We cross-link to: Environmental / WEEE / RoHS Declaration (v1.1); Supplier Code of Conduct (v1.1); Conflict Minerals & Cobalt (v1.1); Export & Trade Compliance (v1.0); Accessibility Statement; Privacy Policy; Customer Service & Complaints Policy; Product Safety & Certification Statement.
1.3 Governing law and jurisdiction: England & Wales.

2.0 Scope
2.1 This policy covers all GeiG-branded consumer and business products, accessories, spares, and promo packs placed on the UK market.
2.2 It applies to primary, secondary, and transport packaging across design, sourcing, manufacturing, fulfilment, retail, returns, and warranty logistics.
2.3 It binds GeiG staff, contract manufacturers, packaging suppliers, logistics partners, refurbishers, and recyclers.

3.0 Definitions
3.1 “EPR” means UK packaging producer responsibility obligations applicable to GeiG as brand owner/packer/filler.
3.2 “Recyclable” means widely kerbside-collected and recoverable without specialist separation (UK context).
3.3 “Mono-material” means a single polymer or fibre grade designed for simple sorting and recycling.

4.0 Compliance Obligations
4.1 We shall register, classify, and report under UK packaging EPR and pay applicable fees in line with our producer role(s).
4.2 We shall comply with Packaging (Producer Responsibility) Regulations (as amended), the UK Plastic Packaging Tax, and UK single-use plastic restrictions.
4.3 We shall maintain conformity with RoHS, REACH, and WEEE where relevant and cross-refer to the Environmental / WEEE / RoHS Declaration (v1.1).
4.4 We shall retain auditable records for at least 6 years, aligned to the Supplier Code of Conduct (v1.1).

5.0 Design Principles
5.1 We shall prevent waste first: eliminate unnecessary components, air, and weight without compromising protection.
5.2 We shall prefer recyclable, mono-material fibre-based solutions for primary and secondary packs.
5.3 We shall avoid mixed laminates and metallised films unless demonstrably recyclable at UK scale.
5.4 We shall favour mechanical closures; use tear-strips; minimise adhesives and plastic tapes.
5.5 We shall validate protection via suitable drop/edge/crush tests for courier handling.
5.6 We shall design re-ship capability to enable low-waste returns.
5.7 We shall support inclusive opening and clear instructions, with digital leaflets aligned to the Accessibility Statement (WCAG 2.2 AA).
5.8 We shall right-size for common parcel tiers to reduce volumetric emissions.

6.0 Materials Standards
6.1 Fibre boards: average ≥90% recycled content (fixed) with virgin fibre only from FSC®/PEFC sources where needed.
6.2 Void fill: paper-based, maximised recycled content; plastic void fill prohibited unless a documented, time-bound derogation is approved.
6.3 Plastics: mono-polymer only where unavoidable; no oxo-degradables; carbon-black discouraged unless NIR-detectable.
6.4 Cushioning: expanded foams (e.g., EPS) avoided where fibre/moulded pulp alternatives meet performance; any exception requires an end-of-life pathway.
6.5 Inks/finishes: kraft/brown board as the default aesthetic; printing kept minimal; water-based inks preferred; metallic foils/spot-UV avoided unless proven recyclable at scale.
6.6 Restricted materials: we adopt legal restrictions; no additional bans beyond law unless mandated by a risk assessment and approved by the policy owner.

7.0 Labelling & Customer Information
7.1 We shall use OPRL on consumer packaging; exemptions are not permitted without written approval from the policy owner.
7.2 We shall direct customers to the Environmental / WEEE / RoHS Declaration (v1.1) and Customer Take-Back Instructions.
7.3 We shall provide QR codes to consolidated digital leaflets and disposal guidance.

8.0 EPR Data & Reporting
8.1 We shall maintain a Packaging Bill of Materials (pBOM) per SKU, with weights (g), materials, recycled content %, and recyclability class.
8.2 We shall submit biannual EPR reports covering obligated packaging by material and supply-chain activity.
8.3 We shall retain substantiation (supplier declarations, specs, test reports) for at least 6 years.
8.4 We shall reconcile filings to sales/fulfilment data and commission checks where proportionate.

9.0 Plastic Packaging Tax (PPT)
9.1 We shall eliminate taxable plastic where practicable; where unavoidable we shall ensure ≥30% certified recycled content.
9.2 We shall collect supplier recycled-content certifications and chain-of-custody evidence.

10.0 Supplier & Manufacturing Controls
10.1 Suppliers shall sign Schedule A: Packaging Requirements and attest to this policy, recycled content, and substance compliance.
10.2 Suppliers shall provide advance Product Change Notifications for packaging (≥90 days) aligned to our Supplier Code of Conduct (v1.1).
10.3 We allow document reviews, spot audits, and unannounced inspections to verify compliance.
10.4 Non-conformities require a corrective action plan within 10 working days and timely closure, or escalation per the Supplier Code of Conduct (v1.1).

11.0 Logistics & Operations
11.1 We shall use recyclable paper-based tapes and minimise plastic straps where performance allows.
11.2 We shall standardise palletisation for stability with minimal wrap; reusable bands/covers may be deployed on intra-UK lanes subject to performance.
11.3 Channel-specific SIOC/“Frustration-Free” requirements are not applicable at present; we shall revisit if channel rules change.
11.4 Returns shall re-use original packs where feasible and segregate damaged materials for recycling.

12.0 Reuse, Repair & Take-Back
12.1 We shall pilot B2B reusable transit/flight cases and service-swap containers; scope, lanes, and SKUs to be defined by Operations.
12.2 We shall publish Customer Take-Back Instructions and align end-of-life handling to WEEE obligations.
12.3 We shall encourage charger/accessory reuse across models to reduce packaging and e-waste.

13.0 Eco-Design Targets & KPIs
13.1 We shall set annual targets for: total packaging weight per device (g), % mono-material packs, % plastic elimination, and recycled content %.
13.2 We shall drive year-on-year reduction in packaging weight and plastic components, without increasing damage/DOA.
13.3 We shall track packaging changes against damage/DOA metrics to prevent protection trade-offs.
13.4 We shall publish a brief annual Packaging Summary at /legal/ linking to this policy and to the Environmental / WEEE / RoHS Declaration (v1.1).

14.0 Testing & Verification
14.1 We shall conduct transit testing (ISTA-appropriate profiles) for new or materially changed packs.
14.2 We shall keep test reports and corrective actions in the pBOM dossier.

15.0 Claims & Communications
15.1 We shall ensure environmental claims are specific, evidenced, and compliant with the CMA Green Claims Code.
15.2 We shall avoid unqualified “biodegradable/compostable” claims unless UK-relevant certification and disposal routes are in place.

16.0 Governance & Review
16.1 Policy owner: Ian Mugray (Head of Operations).
16.2 Review cycle: at least annually, or earlier if law, OPRL rules, or PPT thresholds change.
16.3 Material deviations require written Director approval and a time-bound exit plan.

17.0 Training & Awareness
17.1 We shall train design, buying, and fulfilment teams on EPR data capture, material choices, OPRL use, and this policy.
17.2 We shall brief suppliers on updates and provide exemplars of compliant designs.

18.0 Non-Compliance & Remedies
18.1 We may suspend purchasing, require CAPs, or terminate suppliers for repeated or critical breaches, aligned to the Supplier Code of Conduct (v1.1).
18.2 We shall notify regulators where legally required.

19.0 Data Protection
19.1 We shall process packaging and supplier data per the Privacy Policy and retain only what is necessary for EPR and audit purposes.

20.0 Contact
20.1 Contact: support@geig.co.uk.
20.2 Postal: 27 Old Gloucester Street, London, WC1N 3AX, United Kingdom.
20.3 Company No: 11125670.
20.4 Web chat: 24/7 via geig.co.uk.

21.0 Version Control
21.1 Version: 1.1.
21.2 Effective date: 30 September 2025.
21.3 Linked policies: Environmental / WEEE / RoHS Declaration (v1.1); Supplier Code of Conduct (v1.1); Conflict Minerals & Cobalt (v1.1); Export & Trade Compliance (v1.0); Accessibility Statement; Privacy Policy; Customer Service & Complaints Policy; Product Safety & Certification Statement.

22.0 UK-Only Scope
22.1 This policy and associated EPR filings apply to the United Kingdom only; no additional country EPR filings are in scope at this time.