Table of Contents
- Why Your Producer Category Matters
- The Two Thresholds: Turnover and Tonnage
- Small Producer Criteria
- Large Producer Criteria
- Quick Classification Flowchart
- Reporting Frequency Differences
- Fee Calculation: Do Small Producers Pay Less?
- Obligation Differences Beyond Fees
- Real-World Classification Examples
- What Happens If Your Category Changes?
- Common Mistakes in Self-Assessment
- Key Takeaways
Key Takeaways
- Two thresholds determine your status: annual turnover (£1m-£2m = small, £2m+ = large) and packaging tonnage (25-50t = small, 50t+ = large).
- Small producers report annually by 1 April; large producers report every 6 months (1 October and 1 April).
- Fee rates are identical for both categories — the difference is in reporting frequency, data granularity, and audit scrutiny.
- Your category is assessed each year — a growing business may move from small to large producer status.
- Charities are exempt regardless of turnover or tonnage.
Why Your Producer Category Matters
When the UK’s reformed packaging Extended Producer Responsibility (EPR) scheme came into full effect with fee payments beginning in April 2025, it introduced a two-tier classification system for obligated businesses. Whether your business is classified as a “small producer” or a “large producer” has significant practical implications for how often you report, how much administrative burden you face, and how closely regulators scrutinise your data.
Getting your classification right is not optional. Submitting data on the wrong schedule, or failing to submit at all because you misunderstood which category you fall into, can result in enforcement action from the Environment Agency. This guide explains exactly how the classification works, what the practical differences are, and how to determine where your business sits.
If you are not yet sure whether you are obligated at all, start with our comprehensive guide to packaging EPR, which explains the basic thresholds and obligated activities.
The Two Thresholds: Turnover and Tonnage
Your EPR producer category is determined by two factors assessed together:
- Annual turnover — Your organisation’s total annual turnover in the most recent financial year
- Annual packaging tonnage — The total weight of packaging your business handles, supplies, or imports in a calendar year
Both factors must be considered together to determine your category. Neither turnover alone nor tonnage alone is sufficient. The interaction between these two thresholds creates three possible outcomes: not obligated, small producer, or large producer.
Turnover Definition
For EPR purposes, turnover means the total annual revenue of the legal entity (or group of companies under common ownership) that is the obligated producer. This is not limited to revenue from packaged goods — it is total organisational turnover. A business turning over £3 million, of which only £500,000 comes from products involving packaging, still counts as having £3 million turnover for EPR classification purposes.
Where a business is part of a group, the group turnover may apply. DEFRA guidance states that if multiple subsidiaries are part of the same corporate group and meet the combined thresholds, the parent entity may need to register as the obligated producer or ensure each subsidiary registers individually.
Tonnage Definition
Packaging tonnage includes all packaging your business handles across all obligated activities — not just the packaging you manufacture or design. This includes:
- Packaging on products you sell under your own brand
- Packaging you use to pack or fill products
- Packaging on goods you import into the UK
- Transit and distribution packaging you place on the market
- Shipment packaging used for e-commerce orders
Many businesses underestimate their tonnage because they only count their branded consumer packaging and forget about transit packaging, void fill, packing tape, and other materials that also count.
Small Producer Criteria
You are classified as a small producer if you meet either of the following combinations:
Combination 1:
- Annual turnover between £1 million and £2 million
- AND you handle more than 25 tonnes of packaging per year
Combination 2:
- Annual turnover above £1 million (including above £2 million)
- AND you handle between 25 and 50 tonnes of packaging per year
In practical terms, this means you are a small producer if your turnover is in the £1-2 million range with more than 25 tonnes, OR if you handle between 25 and 50 tonnes of packaging regardless of how far above £1 million your turnover sits.
A business with £5 million turnover but only 30 tonnes of packaging is still classified as a small producer because the tonnage falls in the 25-50 tonne band.
Large Producer Criteria
You are classified as a large producer if you meet both of the following:
- Annual turnover of £2 million or more
- AND you handle more than 50 tonnes of packaging per year
Both conditions must be met. A business with £10 million turnover but only 40 tonnes of packaging is a small producer (not large), because the tonnage threshold for large producer status is 50 tonnes.
Quick Classification Flowchart
Use this table to quickly identify your category:
| Annual Turnover | Packaging Tonnage | Classification |
|---|---|---|
| Below £1 million | Any amount | Not obligated |
| £1m - £2m | Below 25 tonnes | Not obligated |
| £1m - £2m | 25 - 50 tonnes | Small producer |
| £1m - £2m | Above 50 tonnes | Small producer |
| Above £2m | Below 25 tonnes | Not obligated |
| Above £2m | 25 - 50 tonnes | Small producer |
| Above £2m | Above 50 tonnes | Large producer |
Note that a business with turnover between £1 million and £2 million is always classified as a small producer once it meets the 25-tonne threshold, regardless of how much packaging it handles. You cannot be a large producer unless your turnover exceeds £2 million.
Reporting Frequency Differences
The most immediately noticeable difference between small and large producers is how often you must submit packaging data to DEFRA’s Report Packaging Data (RPD) portal.
Large Producer Reporting (Half-Yearly)
Large producers submit data twice per year on a 6-monthly cycle:
| Reporting Period | Data Coverage | Submission Deadline |
|---|---|---|
| H1 | January - June | 1 October (same year) |
| H2 | July - December | 1 April (following year) |
This means large producers must have systems in place to track packaging data on an ongoing basis. Waiting until year-end to compile your data is not practical when your first submission is due in October.
Small Producer Reporting (Annual)
Small producers submit data once per year:
| Reporting Period | Data Coverage | Submission Deadline |
|---|---|---|
| Full year | January - December | 1 April (following year) |
While this is less frequent, small producers must still collect and maintain accurate records throughout the year. The data requirements are the same — material type, weight, packaging category, and activity type.
For a complete rundown of all deadlines, see our EPR compliance deadlines guide.
Fee Calculation: Do Small Producers Pay Less?
A common misconception is that small producers benefit from reduced fee rates. This is not the case. The per-tonne fee rates are identical for both small and large producers:
| Material | Fee per Tonne (2025-2026) |
|---|---|
| Aluminium | £266 |
| Fibre-based composite | £461 |
| Glass | £192 |
| Paper and card | £196 |
| Plastic | £423 |
| Steel | £259 |
| Wood | £280 |
| Other | £259 |
The reason small producers typically pay lower total fees is simply because they handle less packaging. A small producer handling 30 tonnes of cardboard pays 30 x £196 = £5,880. A large producer handling 200 tonnes of the same material pays 200 x £196 = £39,200. The rate is the same — the quantity differs.
For a detailed walkthrough of fee calculations with worked examples, see our EPR fee calculation guide.
Fee Payment Timing
Large producers may receive fee invoices from PackUK after each half-yearly submission, meaning payments are spread across the year. Small producers receive a single annual invoice after their April submission. The exact invoicing schedule is determined by PackUK, the scheme administrator.
Obligation Differences Beyond Fees
Data Granularity
Both small and large producers must report packaging by material type, weight, packaging category, and activity type. However, large producers face additional scrutiny on data quality. The Environment Agency is more likely to audit large producer submissions and may request supporting evidence such as purchase orders, supplier invoices, and weighing records.
Nation Data Reporting
Large producers must report the nations (England, Scotland, Wales, Northern Ireland) where their packaging is supplied or discounted. This “nation data” is used to allocate EPR fees to the correct devolved administrations. Small producers also report nation data, but may use simplified estimation methods such as population-based apportionment rather than actual sales data.
Audit and Verification
DEFRA has indicated that large producers are subject to more rigorous verification of their data submissions. This may include:
- Desk-based audits comparing reported data against industry benchmarks
- Requests for supporting documentation (packaging specifications, supplier invoices, weighing records)
- On-site inspections in cases of suspected under-reporting
Small producers are not exempt from auditing, but the frequency and intensity of scrutiny is generally lower.
Compliance Scheme Membership
Under the reformed EPR scheme, compliance schemes (the organisations that previously managed producer obligations) no longer handle data submission or fee collection — this is now done centrally through PackUK and the RPD portal. Both small and large producers submit data directly.
Real-World Classification Examples
Example 1: Growing E-Commerce Brand
Turnover: £1.8 million | Packaging tonnage: 35 tonnes
This business falls into the small producer category. Turnover is between £1-2 million and tonnage exceeds 25 tonnes. They report annually, with full-year data due by 1 April.
Estimated annual fees (assuming 25 tonnes paper/card and 10 tonnes plastic): (25 x £196) + (10 x £423) = £4,900 + £4,230 = £9,130
Example 2: Mid-Size Food Manufacturer
Turnover: £4.5 million | Packaging tonnage: 120 tonnes
This business is clearly a large producer. Turnover exceeds £2 million and tonnage exceeds 50 tonnes. They must report every 6 months.
Estimated annual fees (assuming 60 tonnes glass, 40 tonnes paper/card, 15 tonnes plastic, 5 tonnes steel): (60 x £192) + (40 x £196) + (15 x £423) + (5 x £259) = £11,520 + £7,840 + £6,345 + £1,295 = £27,000
Example 3: Borderline Case — Importer
Turnover: £2.3 million | Packaging tonnage: 48 tonnes
Despite having turnover above £2 million, this business is a small producer because the tonnage is below 50 tonnes. They report annually. If their packaging volumes grow by just 3 tonnes, they will become a large producer and need to switch to half-yearly reporting.
Example 4: Multi-Site Retailer
Turnover: £8 million | Packaging tonnage: 22 tonnes
This business is not obligated despite having significant turnover. With only 22 tonnes of packaging, they fall below the 25-tonne minimum threshold. However, they should re-assess each year — a slight increase in packaging volumes could bring them into scope.
What Happens If Your Category Changes?
Businesses grow, and packaging volumes fluctuate. It is entirely possible for a business to move between categories from one year to the next. The regulations require you to assess your classification annually based on the most recent data.
Moving from Small to Large Producer
If your business crosses both the £2 million turnover and 50-tonne packaging thresholds, you become a large producer for the following reporting year. This means:
- You must switch from annual to half-yearly reporting
- You will need to submit H1 data by 1 October, which you may not have been tracking on a half-yearly basis
- You may face increased audit scrutiny in your first year as a large producer
Practical tip: If your business is approaching either threshold, start tracking your packaging data on a half-yearly basis now. This makes the transition seamless if and when you cross the boundary.
Moving from Large to Small Producer
If your turnover drops below £2 million or your tonnage drops below 50 tonnes, you may revert to small producer status. You should notify the regulators through the RPD portal and switch to annual reporting for the following year.
Falling Below the Minimum Threshold
If your turnover drops below £1 million or your tonnage drops below 25 tonnes, you are no longer obligated. You should de-register through the RPD portal. However, be aware that if your volumes recover, you will need to re-register.
Common Mistakes in Self-Assessment
1. Ignoring Group Turnover
If your business is a subsidiary of a larger group, the group’s combined turnover may be used for the threshold assessment. A subsidiary with £800,000 turnover that is part of a £10 million group could be obligated based on the group turnover.
2. Underestimating Packaging Tonnage
Businesses frequently under-count their packaging by forgetting to include:
- Transit and distribution packaging (pallet wrap, strapping, corner protectors)
- Packing tape and labels
- Void fill and cushioning materials
- Packaging on goods purchased for resale
- Import packaging
If you are close to the 25 or 50-tonne threshold, a thorough audit of all packaging — including items you might not think of as “packaging” — is essential. Our guide on how to weigh and record your packaging covers this in detail.
3. Using Net Revenue Instead of Turnover
The threshold is based on total annual turnover (gross revenue), not net profit or revenue from packaged goods only. A business with £2.5 million turnover and thin margins is assessed on the full £2.5 million.
4. Assuming “Small” Means “No Obligations”
Small producers have the same fundamental obligations as large producers — they must register, collect accurate packaging data, submit it through the RPD portal, and pay fees. The differences are in reporting frequency and audit intensity, not in whether you need to comply at all.
Next Steps
Determining your producer category is the first step towards EPR compliance. Once you know whether you are a small or large producer, you need to:
- Register on DEFRA’s RPD portal as an obligated producer
- Audit your packaging to identify all materials, weights, and categories
- Set up data collection processes to track packaging throughout the year
- Submit data by the correct deadlines for your category
- Pay fees when invoiced by PackUK
Our platform handles steps 2 through 5 automatically. Enter your packaging data through guided forms, and we calculate your obligations, generate DEFRA-ready reports, and send you deadline reminders based on your producer category.
Not sure which category your business falls into? Use our free compliance checker to find out in 60 seconds. For a complete walkthrough of every step, see our EPR compliance checklist. For definitions of terms like RPD, PackUK, and fee modulation, see our EPR glossary.
You can also learn more about who needs to register, understand how to report your data to DEFRA, or explore our packaging sector guides for industry-specific advice.
Start your free trial to see how we simplify EPR compliance for both small and large producers.