Extended Producer Responsibility (EPR) for Packaging: UK Business Guide

What Is Extended Producer Responsibility for Packaging?

Extended Producer Responsibility (EPR) is a policy principle that requires the parties placing products on the market to take financial responsibility for the end-of-life management of those products. For packaging, this means businesses that supply packaged goods to UK consumers must fund the collection, sorting, and recycling of that packaging when it enters the household waste stream.

Under the previous system, local authorities bore most of the cost of collecting and processing household packaging waste – subsidised by general taxation. Producers contributed only partially, through obligations to fund a set percentage of packaging recycling via the purchase of Packaging Recovery Notes (PRNs). EPR replaces this with a system in which producers pay fees calculated to cover the full net cost of household packaging waste management, with that money flowing to local authorities and infrastructure.

The scheme is one of three interconnected packaging reforms introduced by the UK government, alongside the Simpler Recycling regulations on business waste separation and the planned Deposit Return Scheme (DRS) for drinks containers.

The Legislation

The EPR for packaging scheme is established by the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (SI 2024/1332). The Regulations came into force on 1 January 2025 and are made under the Environment Act 2021. They apply across all four UK nations – England, Wales, Scotland, and Northern Ireland.

The 2024 Regulations revoke and replace the Packaging Waste (Data Reporting) Regulations 2023 (and their devolved equivalents), which had introduced the data collection and reporting framework as a precursor to full EPR. The substantive obligations of the 2024 Regulations took effect from 1 January 2025, with transitional provisions bridging from the prior regime.

A subsequent Producer Responsibility Obligations (Packaging and Packaging Waste) (Amendment) Regulations 2025 has also been published to refine certain provisions.

The scheme is administered by PackUK, a body initially hosted by the Department for Environment, Food and Rural Affairs (Defra) and appointed jointly by the four UK nations. PackUK is responsible for setting producer fees, distributing funds to local authorities, and overseeing scheme operation.

Does EPR for Packaging Apply to Your Business?

EPR applies to businesses that both:

1. Have a turnover of £1 million or more, and
2. Supplied or handled more than 25 tonnes of packaging in the previous calendar year

Businesses below either threshold have no obligations under the Regulations. The two criteria must both be met – a high-turnover business handling only small quantities of packaging, or a low-turnover business handling large quantities, falls outside the scheme.

Large vs Small Producers

Within the threshold, businesses are classified as either large or small – and the obligations differ significantly:

Both thresholds must be met simultaneously. A business with £3 million turnover that handled only 30 tonnes of packaging is classified as a small producer (not large), because it falls below the 50-tonne threshold for large producers.

Which Packaging Activities Trigger Obligations?

A business is a “producer” under the Regulations if it carries out one or more of the following activities in relation to packaging:

• Filling or packing – placing goods into packaging before supplying them to the UK market
• Importing – bringing packaged goods into the UK from outside the UK
• Branding – supplying goods in packaging that carries your brand, even if another business fills or packs them
• Selling – placing goods in packaging and supplying them in your own name (including online)
• Supplying empty packaging – selling or supplying empty packaging to end-users (e.g. businesses or consumers who will use it themselves)
• Operating an online marketplace – facilitating the sale of packaged goods by non-UK sellers to UK consumers
• Hiring or loaning reusable packaging – supplying reusable packaging (crates, pallets, containers) on a hire or loan basis to UK businesses

Most businesses in manufacturing, food production, retail, hospitality, and distribution will fall into one or more of these categories.

Household vs Non-Household Packaging

One of the most important distinctions in EPR is between household and non-household packaging:

• Household packaging is packaging that, when discarded, typically enters the household waste collection stream – including packaging sold directly to consumers, or used by businesses in sectors where consumers regularly take packaging home (hospitality, retail, food service).
• Non-household packaging is packaging used in business-to-business supply chains that never enters household waste.

Producers are required to assess and report both household and non-household packaging separately, using the nation-specific data collection framework where packaging is supplied directly to UK end-users.

Obligations for Large Producers

Large producers (£2m+ turnover, 50+ tonnes) face the most comprehensive set of obligations:

Registration

Large producers must register with the EPR for packaging online service administered by their relevant environmental regulator. Registration must be completed before packaging data is submitted.

2025 registration fee: £2,620

Late registration attracts an additional fee of £332.

Data Reporting

Large producers must collect and submit packaging data every 6 months:

• First half-year report: data on packaging handled between 1 January and 30 June, submitted by 1 October
• Second half-year report: data on packaging handled between 1 July and 31 December, submitted by 1 April the following year

Data must include the material type, weight, and household/non-household status of all packaging handled, as well as nation-specific data where applicable.

Waste Disposal Fees

From October 2025, large producers receive invoices from PackUK for waste disposal fees based on their 2024 household packaging data. These fees are calculated on a per-tonne-of-material basis, with rates varying by material type.

Year 1 (2025-26): Flat base fees per tonne, reflecting average handling and recycling costs across material types. Current fee rates for all materials are published on GOV.UK.

Year 2 onwards (2026-27): Fees will be modulated by recyclability using the Recyclability Assessment Methodology (RAM). See the Recyclability Assessment Methodology section below.

Packaging Recovery Notes (PRNs) and PERNs

Large producers must also obtain Packaging Recovery Notes (PRNs) or Packaging Export Recovery Notes (PERNs) to demonstrate that packaging waste equivalent to their obligations has been recycled or exported for recycling. PRNs are purchased from accredited reprocessors; PERNs from accredited exporters.

Nation Data

Large producers that supply packaging directly to UK end-users, or to small or non-obligated businesses, must also report nation-specific data – breaking down packaging by the UK nation in which it was supplied. This determines how fee revenue is allocated across England, Scotland, Wales, and Northern Ireland.

Obligations for Small Producers

Small producers (£1m-£2m turnover, 25-50 tonnes) have a lighter set of obligations:

Registration

2025 registration fee: £1,216 (plus £332 if registered late).

Annual Data Reporting

Small producers report packaging data once per year, by 1 April, covering the previous calendar year.

PRNs and PERNs

Small producers must still obtain PRNs or PERNs to fulfil their recycling obligations – these cannot be waived.

No Waste Disposal Fees

Small producers are not required to pay waste disposal fees to PackUK. This is a significant financial distinction from large producers.

Recyclability Assessment Methodology (RAM)

From the 2026-27 fee year (based on 2025 data), waste disposal fees for large producers will be modulated based on the recyclability of their household packaging. The Recyclability Assessment Methodology (RAM) assigns each type of packaging a red, amber, or green (RAG) rating:

• Green: Widely collected and recycled; attracts lower fees
• Amber: Recyclable but with lower collection rates or market demand; standard fees
• Red: Difficult or costly to recycle; attracts higher fees

Guidance on RAG ratings for specific packaging types is published by GOV.UK and updated periodically.

Packaging Recovery Notes (PRNs) and PERNs

Packaging Recovery Notes (PRNs) and Packaging Export Recovery Notes (PERNs) are certificates issued by accredited reprocessors and exporters respectively. They evidence that a tonne of a given packaging material has been recycled or exported for recycling. All obligated producers – large and small – must purchase sufficient PRNs/PERNs to demonstrate compliance with their recycling targets.

PRNs and PERNs are traded on an open market, and their price fluctuates with supply and demand. Producers can purchase them directly or through a compliance scheme.

EPR does not replace the PRN/PERN system – both obligations run concurrently.

Compliance Schemes

Rather than managing EPR obligations independently, businesses can join a compliance scheme – an approved body that handles registration, data collection, reporting, and PRN/PERN procurement on behalf of members.

However, compliance schemes have a critical limitation under EPR: they cannot pay waste disposal fees on behalf of large producers. These fees must be paid directly by the producer to PackUK. Compliance schemes can assist with everything else – but the financial liability for disposal fees sits with the producer itself.

Closed Loop Recycling

Large producers operating their own closed-loop collection and recycling system for food-grade plastic packaging may be eligible to participate in the closed loop recycling scheme. This allows producers to offset the weight of packaging they collect and recycle themselves against their household packaging obligations.

To qualify, packaging must:

• Be made from food-grade plastic (such as PET ready-meal trays)
• Be collected by the producer (or on their behalf) separately from other waste
• Be sent to a single accredited reprocessor and recycled back into food-grade material

Participation requires payment of a £2,548 annual charge to PackUK. This is a flat charge, not a per-tonne fee.

Key Dates

How EPR Relates to Other Packaging Legislation

EPR for packaging does not sit in isolation – it is part of a broader regulatory framework governing how packaging is produced, recovered, and recycled:

• The UK Packaging Waste Regulations established the original producer responsibility framework in 1997 (updated 2007). The 2024 EPR Regulations build on and significantly extend that framework.
• The Plastic Packaging Tax (in force from April 2022) applies to plastic packaging components with less than 30% recycled content – a separate obligation that can apply concurrently with EPR fees.
• The Simpler Recycling regulations require businesses to separate packaging and other recyclable waste streams for separate collection – complementing EPR by improving the quality and quantity of packaging material entering the recycling system.

Together, these three instruments form the core of the UK government’s packaging reform programme.