Who Needs to Register for Packaging EPR? A Complete Guide

Table of Contents

• The Two Thresholds You Must Meet
• What Counts as an Obligated Activity?
• Small vs Large Producer Classification
• Who Is Exempt from Packaging EPR?
• Common Scenarios: Am I Obligated?
• What Happens If You Should Register But Do Not
• How to Register and Get Started

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The Two Thresholds You Must Meet

The question “do I need to register for packaging EPR?” comes down to two clear thresholds. Your business is an obligated producer if it meets both of the following criteria:

1. Annual turnover of £1 million or more — based on your organisation’s most recent financial year
2. Handling 25 or more tonnes of packaging per year — across all packaging activities combined

Both conditions must be satisfied. If your turnover is £5 million but you handle only 15 tonnes of packaging, you are not obligated. Similarly, a business handling 200 tonnes of packaging but turning over only £800,000 falls outside the scheme.

The turnover threshold is based on your organisation’s total annual turnover, not just revenue from activities involving packaging. The tonnage threshold covers all packaging your business handles, supplies, imports, or places on the UK market — not just packaging you manufacture yourself.

Use our free compliance checker tool to find out your status in 60 seconds.

What Counts as an Obligated Activity?

Meeting the thresholds alone is not enough. You must also perform at least one obligated activity relating to packaging. DEFRA defines five key activities:

1. Packing or Filling

You put products into packaging before they are sold. This is the most common activity and covers everything from putting garments into polybags to filling bottles with cosmetics.

2. Importing Products in Packaging

You bring packaged goods into the UK from overseas. When you import, you take on EPR responsibility for all packaging on those products — including packaging applied by the overseas manufacturer.

3. Selling Goods Under Your Own Brand

Your brand name appears on the packaging of products you sell to consumers. This covers retailers selling own-brand ranges and DTC brands selling direct.

4. Supplying Empty Packaging

You sell or distribute empty packaging materials to other businesses. This includes packaging manufacturers and distributors.

5. Hiring or Loaning Reusable Packaging

You rent out or lend reusable packaging such as pallets, crates, or transit containers.

Many businesses perform multiple activities simultaneously. A fashion brand might import finished garments (importing), place them into branded mailer bags (packing/filling), and sell them direct to consumers (selling). Each activity creates separate reporting obligations under the DEFRA RPD portal.

Small vs Large Producer Classification

If you are obligated, you fall into one of two categories with different reporting requirements:

Small producers meet one of these criteria:

• Annual turnover between £1 million and £2 million AND handling more than 25 tonnes of packaging
• Annual turnover above £1 million AND handling between 25 and 50 tonnes of packaging

Small producers report annually, with full-year data due by 1 April of the following year.

Large producers have:

• Annual turnover of £2 million or more AND handling more than 50 tonnes of packaging

Large producers report every six months — H1 data (January to June) due by 1 October, and H2 data (July to December) due by 1 April. Read our detailed comparison in Small vs Large Producer EPR.

Who Is Exempt from Packaging EPR?

Several categories of organisation are exempt from EPR obligations:

• Charities are exempt regardless of their turnover or packaging volumes
• Businesses with turnover below £1 million are not obligated
• Businesses handling fewer than 25 tonnes of packaging per year are not obligated
• Businesses that do not perform any obligated activity are not captured by the scheme

It is important to note that even if you are not currently obligated, your status may change as your business grows. If your turnover crosses the £1 million threshold or your packaging volumes exceed 25 tonnes, you become obligated for the following reporting period.

Common Scenarios: Am I Obligated?

Scenario 1: Online Retailer

A DTC clothing brand with £1.5 million turnover ships 30 tonnes of packaging per year (shipping boxes, polybags, tissue paper, mailer bags). Result: Obligated as a small producer. They report annually by 1 April.

Scenario 2: Food Importer

A speciality food importer turns over £3 million and imports products with 80 tonnes of packaging (glass jars, cardboard cases, plastic shrink wrap). Result: Obligated as a large producer. They report every six months.

Scenario 3: Small Bakery

A local bakery with £600,000 turnover uses 40 tonnes of packaging (cake boxes, bags, labels). Result: Not obligated — turnover is below the £1 million threshold, despite exceeding the tonnage threshold.

Scenario 4: Wholesale Distributor

A distribution company with £4 million turnover handles transit packaging (pallets, stretch wrap, corrugated cases) totalling 200 tonnes. Result: Obligated as a large producer. Transit packaging counts towards the tonnage threshold.

What Happens If You Should Register But Do Not

The penalties for non-compliance are significant. The Environment Agency has powers including:

• Warning letters for initial breaches
• Compliance notices requiring corrective action within a deadline
• Civil penalties and variable monetary penalties for repeated or serious non-compliance
• Criminal prosecution for the most severe cases, which can result in unlimited fines

Enforcement actions are published publicly, meaning non-compliance carries reputational risk alongside financial penalties. The Environment Agency has stated that enforcement will be proportionate but firm, particularly for businesses that make no effort to comply.

How to Register and Get Started

If you have determined that your business is obligated, here is what you need to do:

1. Register on DEFRA’s RPD portal — create an account and obtain your Organisation ID
2. Classify your producer size — determine whether you are a small or large producer
3. Audit your packaging — identify every packaging type you handle, its material, weight, and category. Our guide on how to weigh packaging for EPR explains the methodology
4. Set up data collection — establish processes to track packaging data throughout the year
5. Submit data by the deadline — large producers by 1 October (H1) and 1 April (H2); small producers by 1 April annually
6. Pay your EPR fees — calculated based on your packaging tonnage by material type. See our EPR fee calculator guide for worked examples

Our platform handles steps 2 through 6 automatically. Enter your packaging data through guided forms, and we calculate your obligations and generate DEFRA-ready reports — no spreadsheets, no consultants, no guesswork.

Group Structures and Subsidiaries

EPR obligations are assessed at the organisation level, not the group level. However, businesses that are part of a corporate group must carefully consider how obligations apply across the structure.

Parent and Subsidiary Companies

Each legal entity within a group is assessed individually against the turnover and tonnage thresholds. A subsidiary with its own Companies House registration is treated as a separate organisation. If the subsidiary meets both thresholds independently, it must register and report in its own right.

However, DEFRA’s guidance requires businesses to consider whether packaging activities are genuinely carried out by the subsidiary or by the parent company. If a parent company controls packaging decisions — such as specifying packaging types, procuring packaging materials, or managing fulfilment — the parent may be the obligated party rather than the subsidiary.

Franchise Operations

Franchise models create additional complexity. In most cases:

• The franchisor is obligated for branded packaging they specify or supply to franchisees
• Individual franchisees are assessed against the thresholds based on their own turnover and packaging volumes
• Service packaging filled at franchise locations (such as takeaway containers) may fall to the franchisor if they supply the empty packaging

If you operate a franchise, review the DEFRA EPR guidance carefully to determine where obligations sit within your specific structure.

Joint Ventures

Where two or more businesses jointly handle packaging through a shared entity, the joint venture entity itself may be the obligated producer — provided it is a separate legal entity meeting the thresholds.

Sector-Specific Considerations

Different industries encounter EPR registration in different ways. Here are some sector-specific nuances:

Hospitality and Food Service

Restaurants, cafes, and takeaway businesses that use branded packaging are performing an obligated activity (packing or filling). A restaurant chain with £3 million turnover using 30 tonnes of branded takeaway containers, coffee cups, and carrier bags is obligated as a large producer. Note that fibre-based composite items like paper cups with plastic lining attract the highest fee rate at £461/tonne.

Construction and Manufacturing

Businesses in construction and manufacturing often overlook transit packaging obligations. If your company uses pallets, stretch wrap, and corrugated cases to distribute products, that transit packaging counts towards your 25-tonne threshold. A building materials supplier might handle 100+ tonnes of transit packaging annually without realising it triggers EPR obligations.

Healthcare and Pharmaceuticals

Pharmaceutical companies and medical device manufacturers handle significant volumes of packaging, including blister packs, glass vials, cardboard cartons, and patient information leaflets. All of these are reportable packaging. The sterile packaging requirements in healthcare often mean multi-material packaging with higher associated EPR fees.

Agriculture

Agricultural businesses that pack fresh produce — fruit punnets, vegetable bags, crate liners — are performing a packing/filling activity. Large-scale agricultural operations can easily exceed the 25-tonne threshold through high-volume, lightweight packaging alone.

How to Prepare If You Are Approaching the Thresholds

If your business is currently below the turnover or tonnage thresholds but growing, take these proactive steps:

1. Track your packaging volumes now — even before you are obligated, start recording the types and weights of packaging you handle. This gives you baseline data when you cross the threshold.

2. Monitor your annual turnover — if your turnover is approaching £1 million, begin planning for EPR compliance at least six months before you expect to cross the threshold.

3. Understand the data requirements — familiarise yourself with the RPD portal and the CSV format DEFRA requires. Being prepared means you can register and submit data promptly once obligated.

4. Review your packaging supply chain — identify all sources of packaging in your operations, including packaging on imported goods and packaging used by third-party fulfilment providers. Many businesses underestimate their tonnage because they overlook transit and shipment packaging.

5. Budget for EPR fees — use our fee calculator guide to estimate what your fees would be at current packaging volumes. This helps you build EPR costs into your financial planning before they become mandatory.

Frequently Asked Questions

Does EPR apply if I only sell services, not physical products?

If your business is purely service-based with no physical products, you are unlikely to have EPR obligations. However, if your service involves any packaging — for example, a cleaning company providing products in branded bottles, or a catering business using takeaway containers — those items are packaging that could contribute to your tonnage threshold.

What if my turnover fluctuates around the £1 million threshold?

The assessment is based on your most recent completed financial year. If your turnover was £1.1 million last year, you are obligated for the current reporting period — even if this year’s turnover drops below £1 million. You should reassess at the start of each reporting period based on the latest available financial data.

Do I need to register if I only use transit packaging?

Yes. Transit packaging (pallets, stretch wrap, corrugated cases) counts towards the 25-tonne threshold and triggers obligations if you are also performing an obligated activity such as packing/filling or supplying empty packaging. There is no exemption for transit-only packaging. The packaging categories guide explains how transit packaging fits into the reporting framework.

What about packaging I receive but do not place on the market?

Packaging that arrives at your premises on incoming goods — such as packaging on raw materials from domestic suppliers — is typically the responsibility of the party further up the supply chain who packed or imported those goods. You only need to report packaging that you handle, supply, import, or place on the market as part of your obligated activities.

Not sure where you stand? Try our free compliance checker or browse the EPR glossary for definitions of key terms. You can also view our pricing plans to find the right plan for your business, or explore sector-specific guidance for beauty, food and drink, and e-commerce businesses.

Start your free trial today and take the complexity out of EPR compliance.