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:

Annual turnover of £1 million or more — based on your organisation’s most recent financial year
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:

Register on DEFRA’s RPD portal — create an account and obtain your Organisation ID
Classify your producer size — determine whether you are a small or large producer
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
Set up data collection — establish processes to track packaging data throughout the year
Submit data by the deadline — large producers by 1 October (H1) and 1 April (H2); small producers by 1 April annually
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.

Not sure where you stand? Try our free compliance checker or browse the EPR glossary for definitions of key terms.

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

Who Needs to Register for Packaging EPR? A Complete Guide

Table of Contents