EPR for Frozen Food Companies: Packaging Compliance Guide

Table of Contents

• EPR and Frozen Food
• Obligation Thresholds
• Frozen Food Packaging Types
• EPR Fee Implications
• Data Collection
• Reducing EPR Costs
• Key Takeaways

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Key Takeaways

• Frozen food companies with £1M+ turnover and 25+ tonnes of packaging must comply with packaging EPR.
• Printed cardboard sleeves and plastic bags are the two most common frozen food packaging formats, with very different EPR fee rates.
• Multi-layer plastic pouches used for frozen meals and vegetables attract high EPR fees due to their multi-material laminate construction.
• Cold chain transit packaging (insulated boxes, gel packs for D2C frozen deliveries) counts towards your EPR tonnage.
• Switching from plastic bags to cardboard boxes for frozen products can reduce EPR costs, though technical considerations around freezer performance apply.

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EPR and Frozen Food

The UK frozen food market is worth over £7 billion and uses a wide range of packaging types, from simple plastic bags for frozen vegetables to printed cardboard boxes for premium ready meals. Under packaging EPR, every frozen food manufacturer, importer, and brand owner must account for their packaging.

Frozen food packaging has specific technical requirements — it must withstand freezer temperatures, resist moisture, and protect against freezer burn — which can limit the scope for material changes. But there are still significant opportunities to optimise packaging and reduce EPR costs.

For EPR basics, see what packaging EPR is.

Obligation Thresholds

• Annual turnover of £1 million or more
• Handle 25 or more tonnes of packaging per year

Frozen food companies readily exceed these thresholds. A company producing 5 million bags of frozen vegetables at 5g per bag generates 25 tonnes from bags alone. Add transit packaging, outer cases, and pallet wrap, and the total tonnage is substantial.

See who needs to register.

Frozen Food Packaging Types

Primary Packaging

• Plastic bags (LDPE/PE) — frozen vegetables, chips, fish fingers
• Printed cardboard boxes — ready meals, ice cream, premium lines
• Multi-layer laminates — stand-up pouches for meals, sauces
• Plastic trays — ready meal trays (PP, CPET, or aluminium)
• Film lidding — peelable or pierceable film on trays
• Plastic tubs — ice cream containers (PP or HDPE)
• Paper wraps — wrapping items within boxes
• Foil trays — aluminium containers for cook-from-frozen products

Secondary Packaging

• Cardboard sleeves — multi-pack wraps
• Shrink wrap — bundling multi-packs
• Cardboard shelf-ready packaging — for retail freezer cabinets

Transit Packaging

• Corrugated cases — standard outer cases
• Stretch wrap — pallet wrap
• Pallet sheets — interlayer sheets

D2C/Cold Chain Packaging

• Insulated boxes — expanded polystyrene or wool-lined cardboard
• Gel packs — cooling elements (often plastic pouches with gel)
• Dry ice containers — for frozen delivery services
• Thermal liners — foil-lined bubble wrap or foam

EPR Fee Implications

Material	Fee per tonne (approx.)	Frozen Food Use
Plastic film (PE bags)	£360	Frozen veg bags, chip bags
Paper/card	£215	Boxes, sleeves
Plastic (PP trays)	£360	Ready meal trays
Multi-layer laminate	£461	Stand-up pouches
Aluminium	£230	Foil trays, lidding
EPS	£440+	Insulated shipping boxes
Corrugated card	£215	Transit cases

A frozen food manufacturer handling 300 tonnes of packaging might face annual EPR fees of £80,000 to £110,000, depending on the plastic-to-cardboard ratio.

See the EPR fees by material type guide.

Data Collection

Using Production Data

Frozen food manufacturers have precise production data:

1. Use production line records — exact counts of packs produced
2. Get packaging specs from suppliers — weights for bags, boxes, trays, films
3. Include every component — bag, label, clip/seal, tray, film, box, case
4. Track seasonal lines — Christmas products, summer ice cream ranges
5. Allocate to nations using distribution data

Contract Packing

If you use co-packers:

• Your brand, their facility: you typically hold the EPR obligation
• Get written confirmation of responsibility in your contract

For reporting guidance, see how to report packaging data to DEFRA.

Reducing EPR Costs

1. Lightweighting Bags and Film

Modern PE bag technology can achieve comparable performance with 10-15% less material. Work with your film supplier to specify the minimum gauge that meets your freezer performance requirements.

2. Switch Multi-Layer Pouches to Mono-Material

Multi-layer laminates (£461/tonne) are being replaced by mono-PE or mono-PP alternatives (£360/tonne) that still provide adequate barrier properties for frozen products. Frozen food is less demanding on barrier performance than ambient food because the low temperature inhibits spoilage.

3. Replace Plastic Trays with Cardboard

Several major frozen food brands have switched from plastic trays to cardboard trays for ready meals. The cardboard attracts lower EPR fees (£215 vs £360/tonne) and is more easily recycled.

4. Optimise Box Design

Printed cardboard boxes for frozen food can be specified in lighter board grades. Evaluate the minimum weight that maintains shelf appeal and freezer durability.

5. Reduce Transit Case Weight

Standard corrugated cases can be specified in lighter flute profiles. For frozen products that are rigid when frozen, lighter cases may provide adequate protection.

D2C Frozen Delivery Packaging

Direct-to-consumer frozen food delivery (meal kits, speciality ice cream, etc.) uses substantial insulated packaging:

• EPS boxes: Effective but attract the highest EPR fees (£440+/tonne)
• Wool-lined cardboard: Lower EPR fees and recyclable
• Straw-insulated boxes: Emerging alternative
• Gel packs: Classified as packaging and must be included in your data

If you offer D2C frozen delivery, optimise your insulated packaging to reduce both EPR costs and shipping costs.

Plastic Packaging Tax

Frozen food companies using plastic packaging with less than 30% recycled content must also pay the Plastic Packaging Tax at £210.82/tonne. This is separate from EPR fees.

Getting Started

1. Assess your obligation using the EPR compliance checklist
2. Compile packaging specs across all product lines
3. Register with a compliance scheme
4. Submit data to DEFRA
5. Evaluate material alternatives for cost savings

Use the EPR fee calculator and visit our pricing page.