Table of Contents
- Why Toy Manufacturers Need to Act on EPR
- Do You Meet the EPR Threshold?
- Common Packaging in the Toy Industry
- How EPR Fees Apply to Toy Packaging
- Reporting Obligations for Toy Brands
- Practical Steps to Reduce EPR Costs
- Key Takeaways
Key Takeaways
- Toy manufacturers handling 25+ tonnes of packaging with £1M+ turnover must register for packaging EPR and report data to DEFRA.
- Blister packs, window boxes, and polystyrene inserts are among the most common — and most costly — packaging types in the toy industry.
- Switching to mono-material cardboard packaging can significantly reduce your EPR fees compared to plastic-heavy designs.
- Nation data reporting is required, meaning you must track where your packaging ends up across England, Scotland, Wales, and Northern Ireland.
- Non-compliance penalties can reach up to £250,000, making early action essential.
Why Toy Manufacturers Need to Act on EPR
The UK’s Extended Producer Responsibility (EPR) regime for packaging places direct financial responsibility on businesses that produce, import, or sell packaged goods. For toy manufacturers, this is a significant shift. If your business creates packaging — from the colourful retail box to the plastic blister insert inside — you are likely caught by these rules.
The toy industry is particularly exposed because of its reliance on mixed-material packaging. A single action figure can arrive in a cardboard box with a plastic window, a polystyrene tray, cable ties, and a printed instruction sheet. Under EPR, every one of those components must be weighed, classified, and reported.
If you are unfamiliar with the fundamentals, start with our guide on what packaging EPR is and whether it affects your business.
Do You Meet the EPR Threshold?
You are obligated under packaging EPR if your business meets both of the following criteria:
- Annual turnover of £1 million or more
- Handle 25 or more tonnes of packaging per year
“Handling” includes manufacturing, importing, selling, or hiring out packaged goods. Most toy manufacturers of any meaningful size will meet these thresholds comfortably.
If you are below these thresholds, you are currently exempt, though it is wise to monitor your volumes. Our post on who needs to register for packaging EPR covers the full criteria.
Small vs Large Producer
| Criteria | Small Producer | Large Producer |
|---|---|---|
| Turnover | £1M–£2M | Over £2M |
| Tonnage | 25–50 tonnes | Over 50 tonnes |
| Reporting | Annual | Six-monthly |
| Nation data | Not required | Required |
| Fees | Reduced | Full rate |
Most established toy brands will fall into the large producer category. For a deeper comparison, see our small vs large producer guide.
Common Packaging in the Toy Industry
Toy packaging is notoriously complex. Here are the most common materials you will need to track:
- Corrugated cardboard — outer shipping boxes and retail display boxes
- Printed cardboard — retail boxes with lithographic printing
- Plastic film — shrink wrap, bag packaging for smaller items
- PET blister packs — clear plastic windows in retail boxes
- Expanded polystyrene (EPS) — protective inserts and trays
- Cable ties and twist ties — small plastic components securing items to backing cards
- Paper inserts — instruction manuals, sticker sheets, promotional material
Each material type attracts different EPR fee rates. Plastic and fibre-composite packaging is considerably more expensive than paper or cardboard.
How EPR Fees Apply to Toy Packaging
EPR fees are modulated by material type and recyclability. For the 2025-2026 period, the approximate rates are:
| Material | Fee per tonne (approx.) |
|---|---|
| Paper/card | £215 |
| Plastic (recyclable) | £360 |
| Plastic (non-recyclable) | £440+ |
| Glass | £192 |
| Steel | £210 |
| Aluminium | £230 |
| Fibre-based composite | £461 |
| Wood | £215 |
For toy manufacturers, the heavy use of plastic blister packs and polystyrene pushes costs higher than for businesses using simpler packaging. A brand shipping 100 tonnes of mixed plastic-and-cardboard packaging could face an annual EPR bill of £30,000 to £40,000.
For a full breakdown of fees by material, see our EPR fees by material type guide.
Reporting Obligations for Toy Brands
What You Must Report
All obligated producers must submit packaging data through DEFRA’s Report Packaging Data (RPD) service. You will need to report:
- Total weight of each packaging material you handle (in tonnes)
- The activity type — manufacturing, importing, selling, etc.
- Packaging category — primary (touches the product), secondary (groups products), transit (shipping)
- Nation data (large producers only) — where your packaging ends up across the four UK nations
How to Collect the Data
For toy manufacturers, data collection often starts at the product design stage. Your product specifications should include weights for every packaging component. If you do not have this data readily available, you will need to conduct a packaging weight audit.
A practical approach:
- List every SKU in your product range
- Break down each SKU’s packaging into individual components
- Weigh each component or use specification sheets from your packaging supplier
- Classify each component by material type and packaging category
- Multiply by sales volumes to calculate total tonnage
For step-by-step reporting guidance, see how to report packaging data to DEFRA.
Practical Steps to Reduce EPR Costs
The good news for toy manufacturers is that packaging redesign can yield substantial EPR savings. Here are proven strategies:
1. Eliminate Blister Packs Where Possible
Blister packs are one of the most expensive packaging types under EPR because they are often non-recyclable mixed plastic. Consider:
- Printed cardboard boxes with no plastic window
- Paper-based window film (cellulose-based alternatives exist)
- “Try me” holes in cardboard instead of clear windows
Several major toy brands have already moved away from blister packs, and consumers increasingly prefer plastic-free packaging.
2. Switch to Mono-Material Designs
Multi-material packaging (e.g., cardboard with a plastic window) attracts higher fees because it is harder to recycle. Switching to 100% cardboard packaging reduces both your material fee rate and your environmental impact.
3. Reduce Packaging Weight
Every gram matters when you are paying per tonne. Consider:
- Thinner cardboard grades where structural integrity allows
- Removing unnecessary internal packaging (twist ties, plastic trays)
- Right-sizing boxes to reduce void fill
4. Optimise Transit Packaging
Your shipping boxes represent a significant portion of total packaging tonnage. Using right-sized transit packaging and reducing void fill cuts both EPR costs and shipping costs.
5. Work with Your Packaging Supplier
Share your EPR cost data with your packaging supplier. Many suppliers now offer “EPR-optimised” packaging designs that minimise material weight and maximise recyclability.
Seasonal Considerations
The toy industry is heavily seasonal, with a large proportion of sales occurring in Q4 (October-December). This affects your EPR data collection in two ways:
- Your packaging tonnage is concentrated in a few months, which can make annualised estimates inaccurate if based on non-peak months
- New product launches for Christmas may introduce new packaging designs mid-year, requiring updated weight data
Plan your data collection to capture the full seasonal cycle, and update your records whenever you introduce new packaging.
WEEE Overlap for Electronic Toys
If your toys contain batteries or electronic components, you may also have obligations under the Waste Electrical and Electronic Equipment (WEEE) regulations. This is a separate compliance regime from packaging EPR. See our WEEE compliance guide for details.
Similarly, toys containing batteries must comply with the battery regulations.
Getting Started
If you are a toy manufacturer that has not yet addressed packaging EPR, the steps are straightforward:
- Check if you are obligated — review your turnover and packaging tonnage against the thresholds
- Audit your packaging — catalogue every component across your product range
- Register with a compliance scheme or register directly with the Environment Agency
- Submit your data through the RPD portal by the relevant deadline
- Pay your EPR fees when invoiced by PackUK
Our EPR compliance checklist walks you through the full process, and our EPR fee calculator can help you estimate your likely costs.
For help tracking your packaging data across your product range, explore our packaging tools and pricing.