Table of Contents
- Classification Criteria
- Reporting Obligations
- Nation Data Requirements
- Fee Differences
- Changing Classification
- Edge Cases and Complications
- Key Takeaways
Key Takeaways
- Small producers (£1M-£2M turnover, 25-50t) have simplified obligations: annual reporting, no nation data, reduced fees.
- Large producers (£2M+ turnover OR 50+ tonnes) face full obligations: six-monthly reporting, nation data, full fees.
- Exceeding EITHER threshold makes you a large producer — you can be a large producer based on turnover alone even with low tonnage.
- Group company turnover is aggregated — if your parent company and subsidiaries together exceed £2M, all obligated entities are large producers.
- Changing from small to large producer mid-year triggers additional reporting requirements from the start of the next compliance year.
Classification Criteria
Your producer classification determines the level of your EPR obligations:
| Criteria | Small Producer | Large Producer |
|---|---|---|
| Annual turnover | £1M–£2M | Over £2M |
| Annual packaging | 25–50 tonnes | Over 50 tonnes |
| Both required? | Must meet both ranges | Either metric exceeding triggers large |
Important Rules
- Either metric can trigger large producer status: If your turnover is £5M but you handle only 30 tonnes, you are a large producer (because turnover exceeds £2M)
- Group turnover applies: Calculate turnover across your corporate group, not just one legal entity
- Both metrics must be met for obligation: You must exceed BOTH £1M turnover AND 25 tonnes to be obligated at all
For a broader comparison, see our small vs large producer guide.
Reporting Obligations
Small Producers
| Requirement | Small Producer |
|---|---|
| Reporting frequency | Annual |
| Data submission | Once per year via RPD portal |
| Packaging data | Total tonnage by material type |
| Activity classification | Required |
| Packaging category | Primary/secondary/transit |
| Nation data | Not required |
| Submission deadline | April (for previous calendar year) |
Large Producers
| Requirement | Large Producer |
|---|---|
| Reporting frequency | Six-monthly (H1 and H2) |
| Data submission | Twice per year via RPD portal |
| Packaging data | Detailed tonnage by material type |
| Activity classification | Required |
| Packaging category | Primary/secondary/transit |
| Nation data | Required (England, Scotland, Wales, NI split) |
| Submission deadlines | April (H2) and October (H1) |
For submission guidance, see how to submit RPD data.
Nation Data Requirements
The biggest practical difference between small and large producers is nation data.
What Large Producers Must Do
For each material type and packaging category, split the tonnage across:
- England — approximately 84% of UK population
- Scotland — approximately 8%
- Wales — approximately 5%
- Northern Ireland — approximately 3%
This requires tracking where your packaging ends up geographically — using delivery data, customer locations, or population-based estimates.
For detailed methodology, see how to calculate nation data.
What Small Producers Avoid
Small producers submit total UK tonnage only. No geographic split is required, which significantly simplifies data collection.
Fee Differences
Fee Rates
Both small and large producers pay EPR fees based on the same per-tonne material rates. However:
- Small producers may pay reduced overall fees due to simplified cost allocation
- Large producers pay full rates with nation-specific cost weighting
Fee Payment
| Aspect | Small Producer | Large Producer |
|---|---|---|
| Invoice frequency | Annual | May be more frequent |
| Fee calculation | Based on annual data | Based on six-monthly data |
| Nation weighting | Default UK average | Specific to your distribution |
Compliance Scheme Fees
Compliance scheme membership fees may also differ:
- Small producer membership: Typically £200-£500/year
- Large producer membership: Typically £500-£2,000+/year
Changing Classification
Growing from Small to Large
If your turnover exceeds £2M or your tonnage exceeds 50 tonnes:
- You become a large producer from the start of the next compliance year
- Six-monthly reporting begins immediately
- Nation data collection must start
- Full fee rates apply
Planning Ahead
If you are approaching the large producer thresholds:
- Start collecting nation data now — retroactive nation data is difficult to compile
- Set up six-monthly reporting processes
- Budget for higher compliance costs
- Consider upgrading your data collection systems
Shrinking from Large to Small
If your turnover drops below £2M and tonnage below 50 tonnes:
- You may revert to small producer status
- Annual reporting resumes
- Nation data is no longer required
- Notify your compliance scheme or the Environment Agency
Edge Cases and Complications
Group Companies
The turnover test applies to the entire corporate group. If your parent company, subsidiaries, and associated companies together exceed £2M, every obligated entity within the group is classified as a large producer.
Example: Three subsidiaries each with £800K turnover:
- Individual turnover: £800K each (below £1M — would each be exempt individually)
- Group turnover: £2.4M (above £2M — if any individual entity also handles 25+ tonnes, they are a large producer)
Joint Ventures and Franchises
- Franchisors: May be classified based on the entire franchise system’s turnover
- Joint ventures: Classification depends on the legal structure and who holds the packaging obligation
- Associated companies: Connected companies’ turnovers are usually aggregated
Seasonal Businesses
If your packaging tonnage fluctuates significantly:
- Use the full calendar year figure for classification
- A seasonal peak does not change your classification mid-year
- If you exceed 50 tonnes in a year, you are a large producer for the following year
New Businesses
New businesses should estimate their first full year’s turnover and tonnage:
- If estimates exceed the thresholds, register from the start
- Re-assess at year-end based on actual figures
- Adjust classification for the following year if needed
Getting Started
- Calculate your group turnover — include all connected companies
- Estimate your annual packaging tonnage — see how to estimate packaging tonnage
- Determine your classification based on both metrics
- Set up appropriate reporting based on your classification
- Monitor your thresholds annually for potential changes
Use the EPR fee calculator and check the EPR compliance checklist. Visit our pricing page.