EPR for Franchisees
In franchise systems, EPR responsibility depends on who is the legal entity performing obligated activities — often the franchisor, but not always.
Franchise businesses create a unique EPR question: who is the obligated producer — the franchisor or the franchisee?
The answer depends on the franchise structure:
- If the franchisor supplies packaging to franchisees — the franchisor is typically the obligated producer for that packaging
- If franchisees source their own packaging — each franchisee is responsible for the packaging they source and use
- Mixed models — some packaging is franchisor-supplied (branded items) while some is franchisee-sourced (local supplies)
The key question is: who is performing the obligated activity? If the franchisor is selling packaged goods to franchisees, the franchisor is the seller. If the franchisee is packing/filling products at their location, the franchisee is the packer.
Most franchise systems centralise EPR reporting through the franchisor to ensure consistent compliance across the network. This is typically more efficient than each franchisee registering individually.
Your Key Obligations
- Determine whether franchisor or franchisee is the obligated producer
- Identify which packaging is centrally supplied vs locally sourced
- Agree a single reporting approach across the franchise network
- Track packaging volumes per franchisee location
- Submit data via the franchisor or individual registration
- Pay EPR fees proportionate to actual packaging volumes
Common Questions
Is the franchisor always responsible for EPR?
Not necessarily. Responsibility depends on who performs the obligated activities (selling, packing, importing). In most franchise systems, the franchisor handles centrally-supplied packaging and franchisees handle locally-sourced packaging.
Can the franchise group register as a single entity?
Yes. If the franchise operates under a single parent company, they can register once and report aggregated data. Independent franchisees (separate legal entities) may need individual registrations.
What about packaging from the franchisor's approved suppliers?
If the franchisor mandates specific packaging from approved suppliers but the franchisee places the order and pays, the franchisee may be the obligated producer. The legal relationship determines responsibility.
Do I need to comply individually as a small franchisee?
If your individual franchise location has turnover under £1 million or handles under 25 tonnes of packaging, you may be below the EPR threshold. However, check with your franchisor — they may include you in their group registration.
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