Extended Producer Responsibility — EPR — for packaging is now live in the UK. If your business puts packaging onto the UK market above the relevant thresholds, you have compliance obligations and you're paying fees that directly affect your packaging economics.
Here's a plain guide to what it actually involves.
What EPR Is
The principle of EPR is that the businesses that produce or supply packaging bear financial responsibility for that packaging's end-of-life — collection, sorting and recycling. Previously, the cost of dealing with packaging waste fell primarily on local authorities and consumers. Under EPR, it shifts to the businesses that put that packaging on the market.
In practice, this means eligible businesses must register with the scheme administrator, report the weight and type of packaging they supply, and pay fees based on that data. The fees fund the collection and recycling infrastructure.
Who's in Scope
The obligation falls on producers — defined broadly to include manufacturers, importers, brand owners and some online retailers depending on their role in the supply chain.
The threshold for large producers (full obligations including data reporting and fee payment) is:
- Annual turnover above £1 million, and
- Supply or import more than 25 tonnes of packaging per year
Small producers (turnover £1m+ but under 25 tonnes) have lighter-touch registration obligations but no fee payments yet.
Below £1 million turnover: currently exempt from all EPR obligations.
If you're close to either threshold, it's worth tracking your packaging tonnage carefully — the obligations kick in from the start of the year in which you cross them.
What You Have to Report
Data reporting covers packaging by material type: glass, paper and board, aluminium, steel, plastics, wood, and other materials. For each material, you report weight placed on market and weight that is household vs non-household packaging.
The distinction between household and non-household packaging matters because it affects the fee calculation. Packaging that ends up in household recycling streams (direct-to-consumer e-commerce boxes, consumer product packaging) attracts higher fees than packaging that stays in commercial waste streams (business-to-business transit packaging).
The Fee Structure
Fees are set per tonne of packaging by material type. They vary based on recyclability — packaging assigned a higher recyclability rating attracts lower fees, creating a direct financial incentive to improve recyclability.
The fee per tonne for plastic packaging is substantially higher than for paper and board. This reflects the higher cost of collecting and recycling plastics and the lower recovery rates compared to corrugated and cartonboard.
For most businesses, the main financial implication is for plastic packaging — plastic films, shrink wrap, bubble wrap, plastic mailers and trays. If your business uses significant quantities of these, the EPR fee adds a real cost that needs to be factored into packaging economics.
Practical Steps
If you haven't already started tracking your packaging data:
- Identify all packaging your business supplies — primary (product packaging), secondary (outer shipper boxes) and tertiary (pallet wrap, stretch film)
- Weigh or estimate the per-unit weight for each type and calculate annual tonnage
- Classify each item by material type and household/non-household
- Register with the appropriate compliance scheme (there are several accredited schemes — they handle the reporting and fee payment on your behalf in exchange for a fee)
The data reporting and fee payment process is managed through accredited compliance schemes rather than directly with government. Your packaging supplier or a compliance scheme operator can help you navigate this.