The landscape of waste management in the UK is undergoing its most significant transformation in decades. For years, producer responsibility focused largely on recycling targets, but the introduction of Extended Producer Responsibility (EPR) shifts the financial burden of managing packaging waste from local authorities and taxpayers directly onto the producers.
If your organisation handles packaging, the way you carry out your environmental responsibilities has changed. Understanding whether you are affected—and what actions you must take—is no longer just a matter of corporate social responsibility; it is a legal requirement. For a broader look at the current legal landscape, see our guide on UK Business Recycling & Compliance.
Who is Affected by EPR?
The new regulations apply to all obligated UK organisations that import or supply packaging. Your level of responsibility depends on two main factors: your annual turnover and the tonnage of packaging you handle.
The Thresholds for Action
You must collect and report packaging data if your business meets all of the following criteria:
- You are an individual business, subsidiary, or group.
- Your annual turnover is £1 million or more (based on your most recent accounts).
- You were responsible for importing or supplying more than 25 tonnes of packaging to the UK market in the previous calendar year.
- You carry out specific “packaging activities” (such as branding, packing, or importing).
A Note on Charities: While charities are generally exempt from the fees associated with packaging waste, they may still need to register and report data if they act as a reprocessor or exporter.
Defining Your Organisation: Small vs. Large
Under EPR, the “size” of your organisation dictates your level of reporting and financial obligation.
You are a small producer if your turnover is between £1m and £2m and you supply over 25 tonnes of packaging, OR your turnover is over £1m and you supply between 25 and 50 tonnes.
The Task: Small producers must register for 2026 by April 2026 and are primarily required to record and report data annually. Registration fees are £1,303 (or £696 if using a compliance scheme).
You are a large producer if your annual turnover is £2 million or more AND you supply or import more than 50 tonnes of packaging.
The Task: Large producers face stricter requirements. You must report data every six months. For 2026, you are responsible for paying registration fees (£2,842 for direct registrants), waste disposal fees, and meeting recycling obligations via PRNs/PERNs.
What Counts as a “Packaging Activity”?
EPR casts a wide net over the supply chain. You may be obligated if you carry out any of the following:
- Supply branded goods: If you sell products under your own name or trademark.
- Pack goods: If you put unbranded goods into packaging for another business.
- Import: If you bring products in packaging from outside the UK to sell domestically.
- Own an Online Marketplace: If you operate a platform allowing non-UK businesses to sell to UK consumers (marketplaces pay an additional £2,885 fee).
- Service Providers: If you hire out or loan reusable packaging (like pallets).
Key Steps to Compliance
You must record the weight and material type of every piece of packaging. This includes identifying if it is primary (sales), secondary (grouping), tertiary (transport), or shipment (mail order). You must also distinguish between household and non-household waste.
Specific organisations must report “nation data”—where in the UK (England, Scotland, Wales, or Northern Ireland) packaging is supplied or discarded to track regional recycling performance.
From April 2026, fees are adjusted based on the recyclability of your materials (the RAG system):
- Green Rating: Highly recyclable materials receive a 9% discount.
- Amber Rating: Standard materials are charged at the base fee rate.
- Red Rating: Hard-to-recycle materials incur a 20% surcharge in 2026.
Lowering Your Costs
The EPR system incentivises sustainable design. Your waste disposal fees are “modulated,” meaning they are lower for easy-to-recycle materials. Businesses that switch to mono-materials or remove unnecessary plastic layers will see a direct reduction in regulatory costs.
Pro Tip: Many businesses join a Compliance Scheme to handle registration, data reporting, and PRN procurement. While they cannot pay your disposal fees, they reduce the risk of reporting errors and late fees (£386 penalty).
