EPR for Brand Owners
Brand owners control packaging design decisions and carry EPR responsibility for all packaging on their branded products.
Brand owners are at the heart of EPR obligations. You specify the packaging for your products, and you are responsible for reporting and paying EPR fees on all packaging on branded goods sold in the UK.
This gives brand owners a unique advantage: you can design your packaging to minimise EPR costs. Decisions about materials, weights, and recyclability directly affect your EPR fee bill.
Packaging Design for EPR Optimisation
- Material choice — switching from plastic (£423/t) to paper/card (£196/t) more than halves per-tonne fees
- Lightweighting — reducing packaging weight directly reduces tonnage and fees
- Mono-material design — avoiding multi-material packaging reduces both fees and reporting complexity
- Recyclability — from 2026-2027, modulated fees will reward recyclable packaging
Brand owners who sell through retailers, distributors, or marketplaces are still the obligated producer for product packaging. The retailer is only responsible for packaging they add (carrier bags, gift wrap).
Your Key Obligations
- Report all packaging on branded products sold in the UK
- Track packaging specifications as part of product design
- Optimise packaging for EPR cost efficiency
- Prepare for modulated fees by improving recyclability
- Coordinate with contract manufacturers on packaging data
- Submit data to DEFRA and pay EPR fees
Common Questions
Am I responsible even if retailers sell my products?
Yes. As the brand owner, you are responsible for all packaging on your branded products. Retailers are only responsible for additional packaging they add (bags, gift wrap). Your product packaging remains your obligation.
How can I reduce EPR costs through design?
Key strategies: switch from plastic to paper/card where possible, lightweight your packaging, use mono-materials instead of multi-material laminates, and design for recyclability. Each of these directly reduces your EPR fees.
What if I use a contract manufacturer?
You are still the brand owner and obligated producer. Your contract manufacturer applies your packaging on your behalf. Get accurate packaging specifications from your CM and include all packaging in your EPR reporting.
How do modulated fees affect brand owners?
From 2026-2027, packaging that scores well on the Recyclability Assessment Methodology (RAM) will attract lower fees. Brand owners who invest in recyclable packaging design now will benefit when modulation starts.
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