Guide
Packaging waste producer responsibilities
Who must comply with Extended Producer Responsibility (EPR) for packaging, how to register and report data, and what disposal fees and recycling obligations apply. Covers small and large producer thresholds, compliance schemes, PRNs and PERNs, and how EPR interacts with Plastic Packaging Tax.
If your business handles, supplies, or imports packaging in the UK, you may be legally required to take responsibility for the packaging waste it creates. This is called Extended Producer Responsibility (EPR) for packaging.
EPR means that businesses which place packaging on the UK market must pay towards the cost of collecting, sorting, and recycling that packaging after consumers dispose of it. The scheme is UK-wide, administered by PackUK as the Scheme Administrator, and regulated by the environment agencies in each UK nation.
Whether you are obligated depends on your organisation's annual turnover and the tonnage of packaging you handle. There are two categories of obligated producer, each with different reporting and payment requirements.
Who is obligated
Your business is obligated under EPR if it meets both a turnover threshold and a packaging tonnage threshold. The regulations define two producer categories.
Large producers have an annual turnover of £2 million or more and handle more than 50 tonnes of packaging per year. They have the fullest set of obligations including twice-yearly data reporting, recycling obligations via PRNs and PERNs, and disposal fees.
Small producers have an annual turnover of more than £1 million and handle more than 25 tonnes (but no more than 50 tonnes) of packaging per year. They have lighter obligations: annual data reporting and disposal fees, but no recycling obligations.
If your turnover is £1 million or less, or you handle 25 tonnes or less of packaging, you are not obligated.
Group companies: If your business is part of a corporate group, you must add together the turnover and packaging tonnage for all group members that supply or import any packaging to determine whether the thresholds are met.
Online marketplaces: If you operate an online marketplace that enables non-UK sellers to supply packaged goods to UK consumers, you take on the producer obligations for that packaging. Online marketplace operators pay an additional registration surcharge.
What 'handling packaging' means
Packaging handling activities that count towards your obligations include:
- Manufacturing raw packaging materials (paper, card, plastic, glass, aluminium, steel, wood)
- Converting raw materials into packaging (for example, making boxes from cardboard)
- Filling packaging with goods (packing products into boxes, bottles, or wrapping)
- Selling packaged goods to the final consumer, including transit packaging and secondary packaging
- Importing packaged goods or unfilled packaging into the UK
If you perform more than one activity in the supply chain (for example, you both manufacture and fill packaging), each activity counts separately. The regulations assign obligations to each supply chain participant.
Small producer vs large producer obligations
Small producers
Small producers have a reduced set of obligations:
- Register with the environmental regulator (either directly or through a compliance scheme)
- Report packaging data annually: full-year data (January to December) by 1 April the following year
- Pay disposal fees towards the cost of household packaging waste collection and recycling
Small producers do not have recycling obligations and do not need to acquire PRNs or PERNs.
Large producers
Large producers have the full set of obligations:
- Register with the environmental regulator (either directly or through a compliance scheme)
- Report packaging data twice yearly: January to June data by 1 October, and full-year data (January to December) by 1 April the following year
- Meet recycling obligations by acquiring Packaging Recovery Notes (PRNs) for UK recycling or Packaging Export Recovery Notes (PERNs) for packaging exported for recycling, by 31 January the following year
- Pay disposal fees towards the cost of household packaging waste collection and recycling
Joining a compliance scheme
Rather than registering directly with the regulator and managing your obligations yourself, you can join an approved compliance scheme. The scheme handles registration, data reporting, and (for large producers) acquiring PRNs and PERNs on your behalf.
Compliance schemes charge fees that vary by packaging tonnage and materials. For many businesses, particularly those handling multiple packaging types, a compliance scheme is simpler than direct registration.
If you register directly, you must submit data through the Report Packaging Data (RPD) online service and purchase your own PRNs and PERNs from accredited reprocessors or exporters.
Disposal fees
From the 2025-26 obligation year, obligated producers must pay disposal fees towards the cost of local authority collection and recycling of household packaging waste. PackUK calculates and invoices these fees based on your reported packaging data.
In year 1 (2025-26), fees are flat base fees per tonne of household packaging placed on the market, varying by material type (for example, plastic, glass, aluminium, paper). These base fees reflect average handling and recycling costs and are not adjusted for recyclability.
From year 2 (2026-27 onwards), fees will be modulated based on how recyclable your packaging is, using a Red/Amber/Green (RAG) rating system. Packaging rated Green (easily recyclable) will pay less; packaging rated Red (difficult to recycle) will pay more. This is designed to incentivise businesses to design packaging for recyclability.
PackUK uses disposal fee income to make payments to local authorities to cover the cost of managing household packaging waste.
PRNs and PERNs
Large producers must acquire evidence that their packaging waste has been recycled. This evidence takes the form of:
- Packaging Recovery Notes (PRNs) - issued by UK-based accredited reprocessors who recycle packaging waste
- Packaging Export Recovery Notes (PERNs) - issued by accredited exporters who send packaging waste abroad for recycling
You must acquire sufficient PRNs and PERNs for the previous compliance year by 31 January. The number required depends on the tonnage and type of packaging you handle, and the recycling target for each material set by government.
If you use a compliance scheme, the scheme acquires PRNs and PERNs on your behalf.
How EPR interacts with Plastic Packaging Tax
EPR for packaging and Plastic Packaging Tax (PPT) are separate obligations that can both apply to the same business. They are administered by different bodies and have different thresholds.
EPR is an environmental regulation administered by the environment agencies (EA, SEPA, NRW, DAERA) covering all packaging materials. PPT is a tax administered by HMRC that applies specifically to plastic packaging containing less than 30% recycled content.
If your business both handles packaging generally (triggering EPR) and manufactures or imports plastic packaging with less than 30% recycled content (triggering PPT), you must comply with both regimes independently. Meeting your EPR obligations does not satisfy your PPT requirements, and vice versa.
How to comply
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1. Check whether you are obligated
Review your annual turnover and the tonnage of packaging your business handles, supplies, or imports. If your turnover exceeds £1 million and you handle more than 25 tonnes of packaging per year, you are likely obligated. Remember to aggregate group company figures.
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2. Determine your producer category
If your turnover is £2 million or more and tonnage exceeds 50 tonnes, you are a large producer. If turnover is between £1 million and £2 million with tonnage between 25 and 50 tonnes, you are a small producer. Your category determines your reporting frequency and whether you have recycling obligations.
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3. Register with the environmental regulator or join a compliance scheme
Register through the Report Packaging Data (RPD) service, or join an approved compliance scheme which will register on your behalf. Registration must be completed before the first reporting deadline. Online marketplace operators register separately and pay an additional surcharge.
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4. Collect and report your packaging data
Record data on all packaging you handle, supply, or import, broken down by material type and whether it is household or non-household packaging. Large producers report twice yearly (by 1 October and 1 April). Small producers report annually (by 1 April).
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5. Meet your recycling obligations (large producers only)
Acquire sufficient PRNs and PERNs to meet your material-specific recycling targets. Purchase these from accredited reprocessors or exporters, or have your compliance scheme acquire them on your behalf. Deadline is 31 January following the obligation year.
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6. Pay disposal fees
PackUK will calculate and invoice your disposal fees based on the tonnage of household packaging you reported. Pay by the deadline stated on your invoice. From 2026-27 onwards, fees will be modulated based on packaging recyclability.
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7. Check whether Plastic Packaging Tax also applies
If you manufacture or import 10 or more tonnes of plastic packaging in any 12-month period, you must also register for Plastic Packaging Tax with HMRC. This is a separate obligation from EPR.
Penalties for non-compliance
Failure to register, report data, or meet your recycling obligations is a criminal offence. The environmental regulator can issue:
- Civil penalties for late or inaccurate data reporting
- Enforcement notices requiring you to take specific actions to comply
- Criminal prosecution for persistent or deliberate non-compliance, with unlimited fines on conviction
The regulators publish a public register of obligated producers. Failure to appear on the register when you should be obligated is itself a compliance risk, as your customers and supply chain partners may check the register.
What to do next
If you are not sure whether your business meets the thresholds, start by reviewing your turnover and estimating the total tonnage of packaging your business handles. HMRC and the environment agencies provide guidance on what counts as packaging and how to measure tonnage.
If you are already obligated, check that your registration is current and that you have submitted all required data returns. Review the reporting deadlines for the current year to avoid late submissions.
If you also handle plastic packaging, separately assess whether you need to register for Plastic Packaging Tax with HMRC.