Key Takeaways

Small producers have turnover of £1M-£2M and/or handle 25-50 tonnes of packaging — they face reduced obligations compared to large producers.
Small producers report annually (not six-monthly) and do not need to submit nation data.
Registration is through a compliance scheme or directly with the Environment Agency.
Small producer fees are typically lower than large producer fees, with simplified reporting requirements.
Monitor your turnover and tonnage — if you exceed the large producer thresholds, your obligations increase significantly.

What Is a Small Producer?

Under UK packaging EPR, you are classified as a small producer if you meet BOTH of these criteria:

Criteria	Small Producer	Large Producer
Annual turnover	£1M–£2M	Over £2M
Annual packaging tonnage	25–50 tonnes	Over 50 tonnes

Important: If your turnover exceeds £2M OR your tonnage exceeds 50 tonnes, you are a large producer regardless of the other metric.

If your turnover is below £1M and your tonnage is below 25 tonnes, you are exempt and do not need to register.

For full threshold details, see who needs to register for packaging EPR and our small vs large producer guide.

Benefits of Small Producer Status

Small producers enjoy several advantages:

Obligation	Small Producer	Large Producer
Reporting frequency	Annual	Six-monthly
Nation data	Not required	Required
Data detail	Simplified	Full detail
Fees	Reduced rates	Full rates
Compliance complexity	Lower	Higher

Registration Process

Step 1: Confirm Your Eligibility

Calculate your annual turnover (including all group companies)
Estimate your annual packaging tonnage using our packaging weight audit guide
Verify you fall within the small producer thresholds

Step 2: Choose Your Registration Route

Option A: Through a Compliance Scheme

Join a registered compliance scheme
The scheme handles your registration with the Environment Agency
They provide guidance on data collection and reporting
Annual membership fee applies

Option B: Direct Registration

Register directly with the Environment Agency (or SEPA/NRW/NIEA)
You handle all compliance activities yourself
Lower cost but more responsibility

Step 3: Gather Required Information

You will need:

Company registration number
Registered office address
Contact details for your compliance lead
SIC code(s) for your business activities
Estimated annual turnover
Estimated annual packaging tonnage
Packaging activity types (manufacturer, importer, seller, etc.)

Step 4: Complete Registration

Through your chosen route:

Submit the registration form with required information
Pay the registration fee
Receive your registration confirmation and unique number

Step 5: Set Up Data Collection

Begin tracking your packaging data:

Create a packaging register
Start weighing and classifying packaging
Set up a system for ongoing data collection

See how to set up packaging data collection.

Reporting Requirements

What Small Producers Report

Small producers submit a simplified annual data report including:

Total packaging tonnage by material type
Packaging activity types (which activities you perform)
Packaging categories (primary, secondary, transit)
No nation data required

What You Do NOT Need to Report

Geographic distribution across UK nations
Six-monthly interim data
Detailed product-level packaging breakdowns

Submission Deadline

Annual data is typically due by April for the previous calendar year. Check the current year’s specific deadline in our EPR compliance deadlines guide.

Data Format

Submit through DEFRA’s Report Packaging Data (RPD) service. For format details, see the DEFRA RPD CSV format guide.

Fees for Small Producers

Small producers pay reduced EPR fees compared to large producers. The exact fees depend on:

Your total packaging tonnage
The material mix of your packaging
The current fee rates set by PackUK

Estimating Your Fees

Use the EPR fee calculator to estimate your likely costs. As a rough guide, a small producer handling 30 tonnes of mixed packaging might pay £5,000-£10,000 in annual EPR fees.

Compliance Scheme Fees

If you use a compliance scheme, you will also pay:

An annual membership fee (typically £200-£500)
Possibly a per-tonne service charge
Data handling fees (varies by provider)

When You Outgrow Small Producer Status

Monitoring Your Thresholds

Track your turnover and tonnage annually. If either metric crosses the large producer threshold:

Metric	Small → Large Trigger
Turnover exceeds £2M	You become a large producer
Tonnage exceeds 50 tonnes	You become a large producer

What Changes

When you become a large producer:

Reporting becomes six-monthly instead of annual
Nation data is required — you must track geographic distribution
Full data detail is needed
Full fee rates apply

Planning Ahead

If you are approaching the large producer thresholds:

Start collecting nation data in advance
Set up systems for more detailed reporting
Budget for higher fees
Consider whether your data collection processes are robust enough

Getting Started

Verify your eligibility as a small producer
Choose a compliance scheme or register directly
Complete registration with required information
Set up data collection for your packaging
Submit your annual report by the deadline

Check the EPR compliance checklist and visit our pricing page for compliance tools.

How to Register as a Small Producer for Packaging EPR

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