Table of Contents
- Two Regulations, Two Different Goals
- Packaging EPR at a Glance
- Plastic Packaging Tax at a Glance
- Side-by-Side Comparison
- Who Needs to Comply with Each?
- Overlap Scenarios: When You Need Both
- Different Thresholds Explained
- Different Reporting Requirements
- How the Two Interact
- Worked Examples
- Common Misconceptions
Key Takeaways
- Packaging EPR and the Plastic Packaging Tax (PPT) are completely separate regulations with different purposes, thresholds, and reporting requirements.
- EPR covers all packaging materials and funds waste management costs. PPT applies only to plastic packaging and incentivises recycled content.
- EPR threshold: £1m turnover + 25 tonnes of all packaging. PPT threshold: 10 tonnes of plastic packaging manufactured or imported (no turnover threshold).
- Many businesses must comply with both — a company importing 15 tonnes of plastic packaging with turnover above £1 million is caught by both EPR and PPT.
- EPR is administered by PackUK via the RPD portal. PPT is administered by HMRC via tax returns.
UK businesses dealing with packaging now face two distinct regulatory regimes: the reformed Extended Producer Responsibility (EPR) scheme for packaging, and the Plastic Packaging Tax (PPT). While both relate to packaging and the environment, they have fundamentally different purposes, different administering bodies, different thresholds, and different compliance requirements. Confusing the two — or assuming compliance with one covers the other — is a common and potentially costly mistake.
This guide clearly explains how each regulation works, who needs to comply with each, and what happens when your business is caught by both.
Two Regulations, Two Different Goals
Packaging EPR: Funding Waste Management
The packaging EPR scheme exists to make businesses pay the full net cost of managing the packaging waste they place on the UK market. It covers all packaging materials — plastic, glass, paper and card, aluminium, steel, wood, fibre-based composites, and other materials. The fees collected fund local authority collections, sorting, recycling, and disposal.
EPR is an environmental regulation administered by DEFRA and enforced by the Environment Agency (and devolved equivalents). Fees are collected by the scheme administrator PackUK.
Plastic Packaging Tax: Incentivising Recycled Content
The Plastic Packaging Tax is a fiscal measure (a tax) designed to incentivise businesses to use recycled plastic in their packaging. It applies a per-tonne tax on plastic packaging that contains less than 30% recycled plastic content. If your plastic packaging contains 30% or more recycled content, it is exempt from the tax.
PPT is a tax administered and collected by HMRC (His Majesty’s Revenue and Customs). It has nothing to do with DEFRA, PackUK, or the RPD portal.
The two regulations operate entirely independently. Compliance with one does not satisfy the requirements of the other.
Packaging EPR at a Glance
| Aspect | Detail |
|---|---|
| What it covers | All packaging materials (8 types) |
| Who it applies to | Businesses with £1m+ turnover AND 25+ tonnes of packaging |
| What you pay | Disposal cost fees per tonne, varying by material |
| 2025-2026 fee range | £192/tonne (glass) to £461/tonne (fibre-based composite) |
| Administered by | DEFRA / PackUK |
| Reported via | RPD (Report Packaging Data) portal on GOV.UK |
| Reporting frequency | Half-yearly (large) or annually (small) |
| Purpose | Fund packaging waste collection, sorting, recycling, and disposal |
For a full explanation of EPR, see our comprehensive EPR guide.
Plastic Packaging Tax at a Glance
| Aspect | Detail |
|---|---|
| What it covers | Plastic packaging only |
| Who it applies to | Businesses that manufacture or import 10+ tonnes of plastic packaging per year |
| What you pay | £217.85 per tonne (2025-2026 rate) on plastic packaging with less than 30% recycled content |
| Exemptions | Packaging with 30%+ recycled content; packaging used as transport packaging for imports; certain medical and other exemptions |
| Administered by | HMRC |
| Reported via | HMRC Plastic Packaging Tax returns |
| Reporting frequency | Quarterly |
| Purpose | Incentivise use of recycled plastic in packaging |
Key PPT Concepts
30% Recycled Content Threshold: The central mechanism of PPT. If your plastic packaging contains 30% or more recycled plastic (by weight), it is exempt from the tax. This creates a strong financial incentive to switch to packaging with higher recycled content. Chemical recycling and mechanical recycling both count towards the 30% threshold.
Manufacture or Import: PPT applies to businesses that manufacture plastic packaging in the UK or import plastic packaging into the UK. Retailers who buy pre-packaged goods from UK suppliers are generally not liable for PPT on that packaging — the manufacturer or importer is. However, if a retailer imports packaged goods from overseas, they are the importer of the packaging and may be liable.
10-Tonne Threshold: You are liable for PPT if you manufacture or import 10 or more tonnes of plastic packaging components in any 12-month period. There is no turnover threshold — even a small business by revenue can be caught if its plastic packaging volumes exceed 10 tonnes.
Side-by-Side Comparison
| Feature | Packaging EPR | Plastic Packaging Tax |
|---|---|---|
| Materials covered | All 8 packaging materials | Plastic only |
| Threshold | £1m turnover + 25t packaging | 10t plastic packaging (manufactured/imported) |
| Turnover threshold? | Yes (£1m) | No |
| Rate | £192 - £461/tonne (varies by material) | £217.85/tonne (flat rate) |
| Recycled content matters? | Not yet (from 2026-27 via modulation) | Yes — 30%+ recycled content = exempt |
| Administering body | DEFRA / PackUK | HMRC |
| Reporting portal | RPD (GOV.UK) | HMRC tax returns |
| Reporting frequency | Half-yearly or annually | Quarterly |
| Legal basis | Environment Act 2021 | Finance Act 2021 |
| Enforcement | Environment Agency | HMRC |
| Who pays | Producers handling packaging | Manufacturers and importers of plastic packaging |
Who Needs to Comply with Each?
EPR Only (Not PPT)
You comply with EPR only if:
- Your turnover exceeds £1 million AND you handle 25+ tonnes of packaging
- BUT you manufacture or import less than 10 tonnes of plastic packaging per year
Example: A food retailer with £3 million turnover handling 60 tonnes of packaging (mostly glass and cardboard, with only 3 tonnes of plastic). They are a large producer under EPR but below the PPT threshold.
PPT Only (Not EPR)
You comply with PPT only if:
- You manufacture or import 10+ tonnes of plastic packaging per year
- BUT your turnover is below £1 million OR you handle less than 25 tonnes of total packaging
Example: A specialist packaging manufacturer with turnover of £800,000 producing 15 tonnes of plastic packaging per year. Below the EPR turnover threshold but above the PPT tonnage threshold.
Both EPR and PPT
You must comply with both if:
- Your turnover exceeds £1 million AND you handle 25+ tonnes of total packaging (EPR threshold met)
- AND you manufacture or import 10+ tonnes of plastic packaging per year (PPT threshold met)
Example: A cosmetics company with £5 million turnover, handling 80 tonnes of packaging including 20 tonnes of plastic bottles, tubes, and films. Caught by both regulations.
Neither
You are exempt from both if:
- Your turnover is below £1 million and you handle less than 25 tonnes of packaging (not EPR obligated)
- AND you manufacture or import less than 10 tonnes of plastic packaging (not PPT liable)
Overlap Scenarios: When You Need Both
The overlap between EPR and PPT is significant. Many businesses — particularly those that import consumer goods packaged in plastic or manufacture plastic packaging in the UK — will find themselves subject to both.
Scenario 1: E-Commerce Brand Importing from Asia
A UK e-commerce business importing plastic-packaged products from China with £2 million turnover:
| Regulation | Threshold Test | Status |
|---|---|---|
| EPR | £2m turnover (above £1m) + 40 tonnes packaging (above 25t) | Obligated |
| PPT | 15 tonnes of plastic packaging imported (above 10t) | Liable |
EPR cost: 15 tonnes plastic x £423 + 20 tonnes paper/card x £196 + 5 tonnes glass x £192 = £6,345 + £3,920 + £960 = £11,225
PPT cost (if less than 30% recycled content): 15 tonnes x £217.85 = £3,268
Combined packaging regulation cost: £14,493
However, if the business switches its plastic packaging to contain 30% or more recycled content, the PPT liability drops to £0, saving £3,268 annually.
Scenario 2: UK Manufacturer
A UK manufacturer producing consumer goods in plastic packaging with £8 million turnover:
| Regulation | Threshold Test | Status |
|---|---|---|
| EPR | £8m turnover + 200 tonnes packaging | Obligated (large producer) |
| PPT | 80 tonnes of plastic packaging manufactured | Liable |
This business faces both EPR fees on all 200 tonnes of packaging (across all material types) and PPT on the 80 tonnes of plastic packaging it manufactures (unless that packaging contains 30%+ recycled content).
Scenario 3: Retailer Buying From UK Suppliers
A retailer purchasing pre-packaged goods from UK suppliers with £5 million turnover:
| Regulation | Threshold Test | Status |
|---|---|---|
| EPR | £5m turnover + 100 tonnes packaging handled | Obligated (large producer) |
| PPT | 0 tonnes manufactured or imported — all sourced from UK suppliers | Not liable |
This retailer is caught by EPR (as a seller of packaged goods) but not by PPT (because the UK suppliers who manufactured the plastic packaging are the ones liable for PPT). The retailer does not manufacture or import the plastic packaging — they buy pre-packaged goods from domestic suppliers.
Different Thresholds Explained
The threshold differences between EPR and PPT are one of the most confusing aspects for businesses:
EPR: Two-Part Threshold
EPR requires both conditions to be met:
- Annual turnover of £1 million or more
- Handling 25+ tonnes of packaging (all materials combined)
The tonnage threshold covers all packaging types, not just plastic. A business handling 30 tonnes of cardboard with zero plastic is EPR obligated (if turnover exceeds £1 million) but has no PPT liability.
PPT: Single Threshold, No Turnover Test
PPT has a single threshold:
- Manufacture or import 10+ tonnes of plastic packaging components in a 12-month rolling period
There is no turnover requirement. A micro-business with £100,000 turnover that imports 12 tonnes of plastic packaging components is PPT liable.
Importantly, PPT applies to the manufacture or import of plastic packaging, not to the handling or selling of products that happen to be in plastic packaging. A retailer selling products in plastic packaging manufactured by someone else in the UK is not the PPT taxpayer — the manufacturer is.
Different Reporting Requirements
EPR Reporting
- Portal: RPD on GOV.UK
- Data required: Material type, weight, packaging category (primary/secondary/tertiary/shipment), activity type, nation data
- Format: CSV file upload with specific column structure
- Frequency: Half-yearly (large producers) or annually (small producers)
- Deadlines: 1 October (H1) and 1 April (H2/annual)
- Fees paid to: PackUK
PPT Reporting
- Portal: HMRC online services
- Data required: Weight of plastic packaging manufactured/imported, recycled content percentage, exempt packaging quantities, exports
- Format: HMRC tax return (online form)
- Frequency: Quarterly
- Deadlines: PPT returns are due within 60 days of the end of each quarter
- Tax paid to: HMRC
The quarterly PPT reporting cycle is more frequent than EPR’s half-yearly or annual schedule. Businesses subject to both must maintain packaging data systems that can serve both reporting requirements.
How the Two Interact
While EPR and PPT are legally separate, there are important interactions:
Recycled Content and Future EPR Modulation
From 2026-2027, EPR fees will be modulated based on recyclability through DEFRA’s Recyclability Assessment Methodology (RAM). This means that the packaging characteristics that matter for PPT (recycled content) will also start to influence EPR fees, though through different mechanisms.
PPT rewards recycled input content (30% threshold). EPR modulation will assess end-of-life recyclability (how easily the packaging can be recycled after use). A plastic bottle with 30% recycled content is PPT exempt, and — being widely recyclable — may also attract lower modulated EPR fees. But the two assessments are separate.
Double Payment Concern
Some businesses worry they are paying twice for the same packaging — PPT to HMRC and EPR fees to PackUK. In a sense, they are: PPT is a tax on the input material, while EPR is a fee for end-of-life waste management. They address different parts of the packaging lifecycle.
However, DEFRA has indicated that it may consider the interaction between PPT and EPR fees to avoid disproportionate cost burdens on plastic packaging relative to other materials. The exact mechanism for this has not been confirmed.
Data Synergies
The good news is that data collected for one regulation can often support the other. If you track plastic packaging weights and material specifications for PPT, much of that data is directly usable for EPR reporting. A unified packaging data management system can serve both requirements.
Worked Examples
Example 1: Subject to Both
Business: Online beauty retailer importing products from South Korea Turnover: £3 million Packaging: 12 tonnes plastic (bottles, tubes, jars), 8 tonnes paper/card (boxes, inserts), 5 tonnes glass — total 25 tonnes
| Regulation | Assessment | Cost |
|---|---|---|
| EPR | £3m turnover + 25 tonnes = obligated (small producer, tonnage 25-50t) | Plastic: 12t x £423 = £5,076; Paper/card: 8t x £196 = £1,568; Glass: 5t x £192 = £960; Total: £7,604 |
| PPT | 12 tonnes plastic imported (above 10t), less than 30% recycled content assumed | 12t x £217.85 = £2,614 |
| Combined | £10,218 |
Savings opportunity: If the business negotiates with its Korean suppliers to use plastic packaging with 30%+ recycled content, the PPT liability drops to zero, saving £2,614 per year.
Example 2: EPR Only
Business: Brewery Turnover: £2.5 million Packaging: 50 tonnes glass (bottles), 15 tonnes paper/card (labels, cases, multipacks), 2 tonnes aluminium (caps) — total 67 tonnes, with less than 1 tonne of plastic
| Regulation | Assessment | Cost |
|---|---|---|
| EPR | £2.5m turnover + 67 tonnes = obligated (large producer) | Glass: 50t x £192 = £9,600; Paper/card: 15t x £196 = £2,940; Aluminium: 2t x £266 = £532; Total: £13,072 |
| PPT | Less than 1 tonne of plastic manufactured/imported (below 10t) | Not liable |
Example 3: PPT Only
Business: Plastic packaging manufacturer (contract manufacturer for other brands) Turnover: £600,000 Packaging manufactured: 25 tonnes of plastic packaging (bottles, trays, films for clients)
| Regulation | Assessment | Cost |
|---|---|---|
| EPR | £600k turnover (below £1m) = not obligated | Not obligated |
| PPT | 25 tonnes plastic packaging manufactured (above 10t) | 25t x £217.85 = £5,446 (assuming less than 30% recycled content) |
Note: The brands that use this manufacturer’s packaging are likely EPR obligated (if they meet the thresholds), but the manufacturer itself is not EPR obligated due to turnover below £1 million.
Common Misconceptions
”If I pay EPR fees on plastic, I don’t need to pay PPT”
Wrong. EPR and PPT are entirely separate obligations. Paying EPR fees does not exempt you from PPT, and paying PPT does not exempt you from EPR fees. If you meet the thresholds for both, you comply with and pay for both.
”PPT replaces EPR for plastic packaging”
Wrong. PPT does not replace any part of EPR. EPR covers all packaging materials (including plastic) and funds waste management. PPT is a separate tax that incentivises recycled content specifically in plastic packaging.
”I’m too small for EPR, so I’m too small for PPT”
Not necessarily. PPT has no turnover threshold. A business with £500,000 turnover importing 15 tonnes of plastic packaging is PPT liable despite being below the EPR turnover threshold.
”PPT applies to all plastic packaging my business handles”
Wrong. PPT applies only to plastic packaging you manufacture in the UK or import into the UK. If you buy products in plastic packaging from a UK supplier, the supplier (or their upstream manufacturer) is the PPT taxpayer, not you.
”Recycled content exempts me from both regulations”
Partially correct for PPT, incorrect for EPR. Using 30%+ recycled content in your plastic packaging exempts it from PPT. However, it has no impact on your EPR obligations for 2025-2026 — you still pay EPR fees on all packaging regardless of recycled content. This may change when EPR fee modulation is introduced from 2026-2027, but the details have not been confirmed.
Next Steps
If your business handles packaging, you need to assess your obligations under both regulations:
- Check your EPR status using our EPR eligibility guide — focus on the £1 million turnover and 25-tonne packaging thresholds
- Check your PPT status — do you manufacture or import 10+ tonnes of plastic packaging per year?
- Set up unified data tracking — collect packaging data that serves both EPR and PPT reporting requirements
- Explore recycled content options — switching to 30%+ recycled content plastic eliminates PPT liability and may reduce future modulated EPR fees
Our platform tracks packaging data across all material types, making it simple to manage EPR compliance while maintaining the data you need for PPT returns. For details on how EPR fees will evolve, read our guides on modulated fees and the waste hierarchy.
Start your free trial and manage both your EPR and PPT obligations from one place.