Extended Producer Responsibility (EPR) legislation mandates that UK businesses cover the full waste management costs of their packaging.
EPR applies to companies involved in producing packaging that ultimately becomes household waste in the UK. This includes manufacturers, importers, retailers, and sellers of packaged goods, as well as packaging companies. Does this align with your business?
UK Packaging can assist you in understanding EPR regulations and their impact on your operations. We can also support you in optimising your packaging to control costs and improve sustainability.
The anticipated effect of EPR
£2bn
The projected additional cost of EPR for accountable UK businesses
7,000
The count of businesses already enrolled for EPR reporting
2025
The year EPR fees are scheduled to be implemented for responsible businesses
What is Extended Producer Responsibility?
Extended Producer Responsibility (EPR) is a newly introduced key legislation that will transfer the entire cost of handling household packaging waste from taxpayers to the businesses that introduce it into the UK market.
This reform updates the UK Packaging Waste Regulations, originally implemented in 1997. Although fees will not take effect until 2025, businesses are already legally required to gather relevant new data and submit reports to the designated EPR scheme administrator.
Does EPR apply to your business?
Your business has an annual turnover of at least £1m (as stated in your most recent annual accounts).
Your business handled more than 25 tonnes of packaging in the last calendar year.
Your company engages in any of the packaging activities outlined by the UK Government.
If your company is an independent business, subsidiary, or group (excluding charities) and meets these criteria, Extended Producer Responsibility may be applicable to you. Ensure you take the necessary steps!
Responsibilities of Large Producers
Any business that handles over 50 tonnes of packaging that has been placed on the UK market and has an annual turnover that exceeds £2m a year is classed as a ‘large producer’. These producers have greater responsibilities under EPR.
Registration
Large producers must register with the appropriate environmental regulator. This involves creating an account on the Report Packaging Data Service (RPD) and submitting your organisation details. Registration must be completed as soon as possible, as it can take up to 28 days for approval. You can also use a Compliance Scheme to register on your behalf.
Data Submission Deadlines
You are required to collect and report packaging data for a given year. The deadlines for reporting were:
- 1 October 2023: Report data for January to June 2023.
- 1 April 2024: Report data for July to December 2023.
- 1 October 2024: Report data for January to June 2024.
- 1 April 2025: Report data for July to December 2024.
PRN Element Changes
The Packaging Recycling Notes (PRNs) and Packaging Export Recycling Notes (PERNs) system has undergone changes. Large producers must now review their recycling obligations, which are calculated as a percentage of the packaging waste they report. You must fund an equivalent amount of recycling by purchasing PRNs and PERNs from accredited waste reprocessors and exporters. Only large organisations are required to obtain PRNs and PERNs for the packaging they place on the market.
Suggested Fees
Starting from October 2025, large producers will need to pay waste disposal costs. The fees are based on the amount of packaging waste reported and are intended to cover the costs of managing household packaging waste. The exact fees will be determined by the scheme administrator, PackUK, and will be communicated to obligated producers in due course.
Responsibilities of Small Producers
Under the UK Packaging Waste Regulations, a ‘small producer’ is any business that is:
Established in the UK
Performs a packaging producer activity
Has an annual turnover that exceeds £1m
Handles more than 25 tonnes of packaging and/or packaging materials
A business has handled packaging if it:
- Supplies (either directly or indirectly) packaging carrying its brand, name, trademark, or other distinctive mark
- Imports filled packaging that carries no distinctive markings denoting ownership
- Imports or manufactures empty packaging and supplies it for another business that is not a large producer to use
- Fills packaging which is not the responsibility of a large producer to report
- Leases out reusable packaging for others to use
- Imports packaging and discards it in the UK
- Is the first UK owner of packaging
- Operates an online marketplace through which foreign companies supply packaging or packaged goods to the UK market
- Sells packaged goods, even if they carry another obligated business’s branding, to UK consumers
Small producers must report, in April, the data they have collected on the type and amount of packaging they handled in the previous calendar year. The first report is now due by Q1 2025 when reporting of 2024 activities will take place.
Packaging data must be declared in kilograms (kg) by:
- Material
- Level (i.e. primary, secondary, tertiary, or e-commerce packaging)
- If it’s a drinks container
- If it’s likely to end up as waste in public bins
- If it’s likely to arise as waste in household bins or not
- If it’s designed to be reusable
To report data, small producers must first register for EPR via the new government portal ‘Report Packaging Data’.
Small producers may also be obligated to produce separate reports about where they supplied packaging in the UK.
Unlike large producers, small producers do not have to pay fees to regulators that will be spent on ensuring packaging waste is collected and recycled. Small producers will still need to pay a small fee to register with the environmental agency of the UK nation(s) they operate in.
Frequently Asked Questions about EPR
Here, we’ve provided answers to the top three most common questions we receive about EPR.
Extended Producer Responsibility (EPR) is a key piece of new legislation designed to shift the entire cost of managing household packaging waste from taxpayers to producers. It is a reform of the UK Packaging Waste Regulations, which were originally introduced in 1997. While fees will not take effect until 2025, businesses are already legally required to collect relevant data and report it to the designated EPR scheme administrator.
Under this scheme, producers will be charged to cover the full costs associated with household packaging waste management. Fees will be adjusted over time to encourage greater use of recycled packaging. Additionally, EPR levies will be collected alongside Packaging Waste Recycling Note (PRN or PERN) fees.
As of October 2024, the current illustrative fees indicate that plastic could be taxed up to £520 per tonne, while paper may be taxed up to £250 in the highest fee scenarios.
There are several key differences between EPR and the previous Packaging Waste Regulations. Currently, packaging waste responsibility is distributed across multiple points in the supply chain. However, under the new Extended Producer Responsibility regulations, a single producer will bear full responsibility. Additionally, the financial burden of managing packaging waste will shift from council tax-funded waste systems to the responsible producers. The funds collected through the EPR scheme will be allocated to local authorities by the scheme’s designated administrator.
How can you get ready for Extended Producer Responsibility?
If your business manages 50 tonnes of paper-based packaging, you could face charges of up to £10,000 under the current illustrative EPR fees. For businesses handling larger quantities, costs could reach millions.
Reduce the weight of your packaging
Since EPR fees are calculated based on tonnage, opting for lighter packaging can help lower your costs. Additionally, reducing packaging weight can decrease carbon emissions—an added environmental benefit!
Optimise packaging to use less material
Reducing the amount of packaging you introduce to the UK market ultimately lowers your overall tonnage. Smart, optimised packaging design allows you to achieve this without compromising product protection.
