What is Packaging EPR and Does It Affect Your Business?

What Exactly is EPR?
Who Needs to Comply?
Small vs Large Producers
What Activities Make You Obligated?
What Do You Need to Report?
The Fee Structure: How Much Will It Cost?
How PackUK Administers the Scheme
Key Takeaways

Key Takeaways

You are obligated if your annual turnover is £1 million or more AND you handle 25 or more tonnes of packaging per year.
Small producers pay reduced fees and report annually; large producers report every 6 months.
EPR fees for 2025-2026 range from £192/tonne (glass) to £461/tonne (fibre-based composite).
Charities are exempt from EPR obligations.
The scheme is administered by PackUK and data is submitted via DEFRA’s Report Packaging Data (RPD) portal.

What Exactly is EPR?

Extended Producer Responsibility (EPR) for packaging is one of the most significant environmental regulations to affect UK businesses in recent years. The principle is straightforward: businesses that place packaging on the UK market must pay for its collection, sorting, recycling, and disposal. Rather than local councils and taxpayers bearing the full cost of managing packaging waste, EPR shifts that financial responsibility to the producers who create it.

The UK’s packaging EPR scheme has been substantially reformed since 2024. While producer responsibility for packaging has existed in some form since the late 1990s, the reformed scheme — which came into full effect with fee payments beginning in April 2025 — is far more comprehensive. It covers more businesses, requires more granular data, and introduces fees designed to incentivise sustainable packaging choices.

The scheme is managed by DEFRA (the Department for Environment, Food and Rural Affairs) and enforced by the Environment Agency in England, Natural Resources Wales, the Northern Ireland Environment Agency, and SEPA in Scotland.

Who Needs to Comply?

You are considered an “obligated producer” if your organisation meets both of these thresholds:

Annual turnover of £1 million or more
Packaging handled of 25 tonnes or more per year

Both conditions must be met. A business turning over £5 million but handling only 10 tonnes of packaging is not obligated. Equally, a business handling 100 tonnes of packaging but with turnover below £1 million falls outside the scheme.

It is important to note that charities are exempt from EPR obligations regardless of their turnover or packaging volumes.

The 25-tonne threshold covers all packaging your business handles, supplies, or imports — not just the packaging you manufacture. This includes packaging on products you buy in from suppliers and resell, packaging used in your fulfilment operations, and packaging on goods you import from overseas.

Small vs Large Producers

The EPR scheme distinguishes between two categories of obligated producer, each with different reporting frequencies and obligations:

Small producers are businesses that meet one of these criteria:

Annual turnover between £1 million and £2 million AND handle more than 25 tonnes of packaging per year
Annual turnover above £1 million AND handle between 25 and 50 tonnes of packaging per year

Large producers are businesses with:

Annual turnover of £2 million or more AND handle more than 50 tonnes of packaging per year

The distinction matters because it determines your reporting frequency. Large producers must submit data every 6 months (half-yearly), while small producers report once per year. Large producers also face greater scrutiny and may be subject to more frequent audits.

What Activities Make You Obligated?

The regulations define several “obligated activities.” If your business performs any of these and meets the turnover and tonnage thresholds, you have EPR obligations:

Supplying packaged goods under your own brand — If you sell products in packaging bearing your brand name, you are responsible for that packaging.
Placing goods into packaging — The act of packing or filling, such as putting products into boxes, bags, or containers before sale.
Importing products in packaging — If you bring packaged goods into the UK from overseas, you take on EPR responsibility for all packaging on those products.
Owning an online marketplace — Operators of online marketplaces where third-party sellers offer packaged goods have specific obligations under the scheme.
Hiring or loaning reusable packaging — Businesses that supply reusable packaging on a hire or loan basis are also captured.

Many businesses perform multiple obligated activities. For example, a fashion brand might import finished garments (importing), place them into branded mailer bags (packing/filling), and sell them to consumers (selling). Each activity creates separate reporting obligations.

What Do You Need to Report?

Obligated producers must submit data about their packaging through DEFRA’s Report Packaging Data (RPD) portal. The data required includes:

Material type — plastic, glass, aluminium, steel, paper and card, wood, fibre-based composite, or other
Packaging weight in tonnes
Packaging category — primary (consumer-facing packaging that directly contains the product), secondary (grouping or multipack packaging), tertiary (transit and distribution packaging), or shipment packaging
Activity type — which of the obligated activities you perform for each packaging item

Reporting Deadlines

The submission deadlines differ depending on whether you are a large or small producer:

Large producers report on a 6-monthly cycle:

H1 data (January to June) must be submitted by 1 October of the same year
H2 data (July to December) must be submitted by 1 April of the following year

Small producers report annually:

Full year data must be submitted by 1 April of the following year

All submissions are made via the RPD portal, which is DEFRA’s online system for packaging data collection.

The Fee Structure: How Much Will It Cost?

EPR fees are calculated per tonne of packaging, with different rates for each material type. The confirmed base fees for 2025-2026 (Year 1) are:

Material	Fee per Tonne
Aluminium	£266
Fibre-based composite	£461
Glass	£192
Paper and card	£196
Plastic	£423
Steel	£259
Wood	£280
Other	£259

These fees cover the full net cost of managing each packaging material, including collection from households, sorting at materials recovery facilities, recycling, and disposal of non-recyclable fractions.

Worked Example

Consider a mid-sized e-commerce business that handles the following packaging annually:

30 tonnes of cardboard boxes (paper and card): 30 x £196 = £5,880
5 tonnes of plastic mailer bags (plastic): 5 x £423 = £2,115
2 tonnes of void fill (plastic): 2 x £423 = £846

Total annual EPR fees: £8,841

What About 2026-2027 (Year 2)?

From Year 2 onwards, fees will be modulated based on recyclability. DEFRA’s Recyclability Assessment Methodology (RAM) will assess how easy each type of packaging is to recycle. Packaging that is harder to recycle — such as multi-material laminates or black plastic trays — will attract higher fees, while easily recyclable mono-material packaging will benefit from lower rates. Exact Year 2 fees have not yet been confirmed.

How PackUK Administers the Scheme

The EPR scheme is administered by PackUK, the scheme administrator appointed by DEFRA. PackUK is responsible for:

Collecting packaging data from obligated producers via the RPD portal
Calculating fee obligations based on reported packaging data
Invoicing producers and collecting EPR fees
Distributing payments to local authorities to fund waste collection and recycling infrastructure
Monitoring compliance and referring non-compliant businesses to the Environment Agency

Businesses do not pay fees directly to DEFRA or local councils. Instead, PackUK acts as the intermediary, collecting data and fees from producers and distributing funds to the organisations responsible for managing packaging waste.

Common Misconceptions About Packaging EPR

Many businesses hold misconceptions about the scheme that can lead to non-compliance or wasted effort. Here are the most frequent ones.

”We do not manufacture packaging, so we are not affected”

This is the most common misconception. EPR obligations are not limited to packaging manufacturers. Any business that packs products into packaging, imports packaged goods, or sells products under its own brand is performing an obligated activity. A retailer that buys pre-packaged goods from a UK supplier and sells them under its own label is obligated for all packaging bearing its brand. Understanding who needs to register is the essential first step.

”Our packaging supplier handles EPR for us”

Your packaging supplier may be obligated for the empty packaging they supply to you. However, once you fill that packaging with a product, you take on a separate obligation for the packing/filling activity. Both parties can be obligated for different activities relating to the same packaging item. EPR obligations cannot be contracted out — you cannot pay a supplier to take on your obligations.

”We are a small business so EPR does not apply to us”

The thresholds are £1 million turnover and 25 tonnes of packaging. Many businesses that consider themselves “small” comfortably exceed these thresholds. A business with 10 employees could easily turn over £2 million and handle 40 tonnes of packaging. The assessment is based on objective financial and tonnage data, not subjective business size.

”Biodegradable packaging is exempt from EPR”

There is no exemption for biodegradable, compostable, or plant-based packaging. All packaging materials are captured by the EPR scheme regardless of their end-of-life properties. In fact, some biodegradable materials may attract higher modulated fees from 2026-2027 if they are not compatible with existing recycling infrastructure — compostable plastics, for example, can contaminate conventional plastic recycling streams.

The History of Packaging Producer Responsibility in the UK

Packaging producer responsibility is not new in the UK. Understanding the history provides context for why the reformed scheme is more comprehensive and costly.

The Original PRN System (1997-2024)

The UK first introduced packaging producer responsibility in 1997 through the Producer Responsibility Obligations (Packaging Waste) Regulations. Under this system, obligated producers purchased Packaging Recovery Notes (PRNs) and Packaging Export Recovery Notes (PERNs) from accredited reprocessors and exporters.

PRNs functioned as certificates proving that packaging waste had been recycled. Producers purchased enough PRNs to meet their share of the national recycling targets. PRN prices fluctuated based on supply and demand — when recycling capacity was tight, prices spiked, sometimes dramatically.

The PRN system was widely criticised for several reasons:

Producers paid only a fraction of the true cost of managing packaging waste
Local authorities bore most of the collection costs, funded by council tax
PRN price volatility made budgeting difficult for businesses
There was limited incentive for producers to design more recyclable packaging

The Reformed Scheme (2024 Onwards)

The reformed EPR scheme, detailed in the government consultation, addresses these shortcomings by requiring producers to pay the full net cost of managing packaging waste. This represents a step change in financial responsibility — estimated at a tenfold increase in costs for many producers compared to the old PRN system.

The reformed scheme also introduces fee modulation from Year 2 (2026-2027), creating a direct financial link between packaging design decisions and EPR costs. Producers using easily recyclable packaging will pay less than those using hard-to-recycle formats.

What Businesses Should Do Right Now

If you are new to packaging EPR, here are the immediate actions to take:

Check your obligation status — confirm whether your turnover and tonnage exceed the thresholds using our free compliance checker
Classify your producer size — determine whether you are a small or large producer based on the turnover and tonnage bands
Audit your packaging — identify every packaging type your business handles, its material, and its weight. Our guide on what counts as packaging will help you catch items you might miss
Register on the RPD portal — create your account on DEFRA’s Report Packaging Data portal and obtain your Organisation ID
Set up data collection — establish processes to track packaging data throughout each reporting period rather than scrambling at deadline time
Know your deadlines — mark the key submission dates in your calendar and set reminders well in advance

How EPR Compliance Helps

Our platform simplifies the entire process. Enter your packaging data through guided forms, and we calculate your obligations and generate DEFRA-ready reports automatically. No spreadsheets, no consultants, no guesswork.

We support all eight material types, all packaging categories (primary, secondary, tertiary, and shipment), and both large and small producer reporting schedules. Our obligation calculator uses the confirmed 2025-2026 fee rates to give you an accurate cost estimate, and our deadline tracker ensures you never miss a submission window.

Not sure if your business is obligated? Use our free compliance checker tool to find out in 60 seconds. You can also browse our EPR glossary for definitions of all the key terms mentioned in this guide, or work through our step-by-step EPR compliance checklist.

For sector-specific guidance, explore our guides for fashion, beauty, food and drink, and e-commerce businesses. If you are unsure what counts as packaging or need help understanding packaging categories, we have detailed guides covering those topics too.

Start your free trial today and see how easy EPR compliance can be.