Check if you must comply with EPR for packaging
Find out if you have obligations as a supplier or importer of packaging or packaged goods under extended producer responsibility (EPR) for packaging – and if you’re a large or small producer.
What is a ‘producer’ under EPR for packaging
All businesses must check if they are a ‘producer of packaging’. A producer of packaging is an organisation that does any of these packaging activities:
- filled packaging being supplied under your own brand
- packing goods or filling packaging
- importing goods in packaging
- supplying unfilled packaging that you manufacture or import
- hiring or loaning out reusable packaging
- owning an online marketplace where filled or unfilled packaging is supplied in the UK from outside the UK
- selling filled packaging to an end user (consumer or business)
You can read further information on the packaging activities in Check what packaging to report, or definitions in part 2, chapter 1 of the regulations.
If another organisation imports, packs or sells your filled branded packaging
You’re still a producer of packaging if:
- you ask another organisation to import your filled branded packaging into the UK
- another organisation packs goods or manufactures goods that will be sold in the UK in your branded packaging
- you license another organisation to manufacture goods and supply them in your branded packaging in the UK
Check if you’re an ‘obligated producer’
You have obligations under EPR for packaging (this is called being an ‘obligated producer’) if you do any of the packaging activities and all the following apply:
- you’re an individual business, subsidiary or corporate group that’s established in the UK
- you supplied or imported more than 25 tonnes of packaging in the UK in the previous year
- your annual turnover worldwide was £1 million or more
If you’re reporting 2026 packaging data, calculate the amount of packaging you supplied or imported from 1 January 2025 to 31 December 2025.
If you’re reporting 2026 packaging data, you must get your annual turnover from the last accounts that were available before 7 April 2026.
If you publish or otherwise make available audited accounts each year, you must use these for the annual turnover figure. If you’re not required to submit audited accounts, use whatever accounts are available.
All producers must assess the packaging they supply or import to understand if they’re obligated or not.
When adding up the amount of packaging you’ve supplied or imported to understand if you’re obligated, only count the packaging once, even if you carry out more than one packaging activity on it.
Charities that supply or import filled or unfilled packaging in the UK are exempt from EPR for packaging requirements. This does not include subsidiaries of a charity that trade for profit.
What ‘packaging’ means
Packaging is any material that is used to contain, protect, handle, deliver or present goods supplied to an end user (business or consumer). It includes pallets, display units and anything that’s designed to be filled at the point of sale, such as a coffee cup. For the full definition read regulation 7.
There are detailed illustrations and examples about what constitutes packaging in the ‘agreed positions and technical interpretations’ guidance on the National Packaging Waste Database.
Check if your organisation is ‘established in the UK’
An organisation is ‘established in the UK’ for the purpose of the regulations if the registered office, head office or principal place of business is in the UK. This includes if the organisation is run out of domestic premises in the UK.
If the head office is outside the UK, the organisation is still established in the UK if it has any of the following:
- a branch in the UK
- a warehouse in the UK
- a PO box, returns address or any other postal address in the UK
Check if you’re obligated as a holding company or subsidiary
As a holding company, you must check if your corporate group is obligated under EPR for packaging as a large or small producer. You need the following figures for all the companies in the group that are established in the UK and supply or import any packaging:
- the total weight of filled or unfilled packaging supplied or imported into the UK
- the total annual turnover worldwide
If you’re reporting 2026 packaging data, calculate the amount of packaging you supplied or imported from 1 January 2025 to 31 December 2025.
If you’re reporting 2026 packaging data, you must get your annual turnover from the last accounts that were available before 7 April 2026.
Do not include the turnover of any companies in the group that do not supply or import packaging.
If these totals meet the criteria for a large producer, then each member of the group is a large producer, and if small, then each member is small. It does not matter whether they meet the criteria individually.
There are detailed examples about the group threshold test in the ‘agreed positions and technical interpretations’ guidance on the National Packaging Waste Database.
Check if you’re a large or small producer
If you’re an obligated producer, you’ll either be a ‘large producer’ or a ‘small producer’. Large producers have more obligations than small producers under EPR for packaging.
Table showing thresholds for small and large producers of packaging
| Packaging weight | £1 million or less annual turnover | From £1 million to £2 million annual turnover | More than £2 million annual turnover |
|---|---|---|---|
| Less than 25 tonnes | No obligation | No obligation | No obligation |
| From 25 tonnes to 50 tonnes | No obligation | Small producer | Small producer |
| More than 50 tonnes | No obligation | Small producer | Large producer |
If you’re reporting 2026 packaging data, calculate the amount of packaging you supplied or imported from 1 January 2025 to 31 December 2025.
If you’re reporting 2026 packaging data, you must get your annual turnover from the last accounts that were available before 7 April 2026.
When you’re not an obligated producer
In some cases, you may not be an obligated producer in relation to packaging – for example if you import or pack goods for a large producer and the packaging will carry their brand. In this case, the brand owner will be the obligated producer and must include the packaging in their threshold calculation.
For each packaging activity listed in the ‘What is a producer’ section (except selling), you should read guidance on what packaging to report as a large producer to find out who in the supply chain would be responsible for reporting the packaging. If you’re not responsible, then this packaging must not be included in your threshold calculation.
Packaging activity: selling
If you sell filled packaging to an end user, you must always include this packaging in your threshold calculation unless you’re already counting it under one of the other packaging activities.
If a different producer carries out an obligated packaging activity on this packaging, they must also include it in their threshold calculation.
Next steps for large producers
As a large producer, you must:
- register with your environmental regulator each year
- report packaging data every 6 months
- buy or otherwise acquire enough packaging waste recycling notes (PRNs) or packaging waste export recycling notes (PERNs) or both to meet your recycling obligations each year
- submit a certificate of compliance to show that you’ve met your recycling obligations each year
- pay a waste disposal fee for any household packaging to PackUK each year
- keep required data for 7 years
Large producers: find out what to do next.
Next steps for small producers
As a small producer, you must:
- register with your environmental regulator
- report packaging data every year
- keep required data for 7 years
Small producers: find out what to do next.
Reporting producers that are missing from the public register
Obligated producers should all have an entry on the public register of packaging producers.
If you suspect that an organisation is an obligated producer and they’re not on the register, report this to the appropriate regulator.
To report on a 24-hour telephone service, call 0800 80 70 60 for England, Scotland, Northern Ireland or 0300 065 3000 for Wales.
You can also report anonymously to Crimestoppers.
Get help or give feedback
If you have any questions, contact your environmental regulator or the EPR for packaging customer service team.
Check the contact details for regulators and administrators.
You can also give feedback about this guidance.
User panel
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