Packaging EPR Explained

Extended Producer Responsibility (EPR) for packaging is a UK environmental regulation that requires businesses to pay the full cost of managing the packaging they produce, import, or sell once it becomes waste. It was introduced to shift the financial burden of packaging waste management from local councils and taxpayers to the businesses that create the waste. The reformed scheme, managed by DEFRA and enforced by the Environment Agency, aims to incentivise businesses to use less packaging, choose more recyclable materials, and move towards a circular economy. Data reporting began in January 2024, with fee payments starting from April 2025.

Your business is obligated under packaging EPR if it meets two thresholds simultaneously: an annual turnover exceeding £1 million, and handling more than 25 tonnes of packaging per year. You must also perform at least one of the six obligated activities — manufacturing, converting, packing/filling, selling, importing, or hiring/lending packaging. If you meet both thresholds, you must register and report your packaging data. Use our free compliance checker at /check to find out in under two minutes whether your business is obligated.

Small producers are businesses with a turnover between £1 million and £2 million that handle more than 25 tonnes of packaging, or businesses with a turnover above £1 million that handle between 25 and 50 tonnes. They report annually with data due by 1 April. Large producers are businesses with a turnover exceeding £2 million and handling more than 50 tonnes of packaging per year. They report every six months — H1 data (January to June) is due by 1 October, and H2 data (July to December) is due by 1 April. Large producers face more detailed reporting requirements and must provide nation-level data showing where their packaging is sold or discarded.

For 2025-2026, the confirmed base disposal cost fees per tonne are: plastic £423, paper and card £196, glass £192, aluminium £266, steel £259, wood £280, fibre composite £461, and other materials £392. These are base rates — from 2026-2027 onwards, DEFRA will introduce modulated fees based on the Recyclability Assessment Methodology (RAM), meaning packaging that is harder to recycle will attract higher charges. You can estimate your total fees using our pricing calculator at /pricing.

The six obligated activities are: (1) Manufacturing — producing empty packaging or packaging materials; (2) Converting — modifying packaging from one type to another, such as printing on blank boxes; (3) Packing/filling — putting products into packaging for sale; (4) Selling — selling packaged goods under your own brand to the end consumer; (5) Importing — bringing packaged goods or empty packaging into the UK from abroad; and (6) Hiring or lending — supplying reusable packaging such as pallets, crates, or transit containers to other businesses. Most SMEs fall under the packing/filling, selling, or importing categories.

DEFRA requires you to report packaging across four categories: primary packaging (directly contains or protects the product at the point of sale, such as a bottle or bag), secondary packaging (groups multiple primary packages together, such as a multipack sleeve or branded gift box), transit or tertiary packaging (used to transport goods in bulk, such as corrugated shipping boxes, pallet wrap, or edge protectors), and shipment packaging (used specifically for e-commerce deliveries direct to consumers, such as mailer bags and parcel boxes). Each category must be reported separately by material type and weight.

The Environment Agency has enforcement powers for EPR non-compliance. Penalties can include formal warnings, variable monetary penalties, compliance notices, and in serious cases, prosecution. Missing a deadline or submitting inaccurate data can result in fines that are often far more costly than the compliance fees themselves. The Environment Agency is also empowered to issue enforcement undertakings and publish details of non-compliant businesses. It is far cheaper and simpler to comply on time than to deal with enforcement action.

Yes. If you import packaged goods or empty packaging into the UK, you are classified as an importer under EPR regulations and take full responsibility for all packaging on those products — including any packaging applied by the overseas manufacturer. This means you must account for primary packaging (such as polybags around garments), secondary packaging (such as retail boxes), and transit packaging (such as shipping cartons and pallet wrap). Many businesses underestimate their obligations here because they do not realise they are responsible for packaging they did not create themselves.