The EPR (extended producer responsibility) regulations require producers of packaging to be responsible for the full net costs of managing the packaging lifecycle, including disposal and recycling.
While these changes may not impact all producers, those handling and supplying packaging to consumers and businesses could be affected. Packaging regulations impact many NFU members, including egg packers, dairy processors, and the horticulture sector.
The first EPR payment year has been deferred for a year until October 2025, a year later than the original date of 1 October 2024.
Further information and definitions can be found on: GOV.UK | Extended producer responsibility for packaging: who is affected and what to do.
Key updates on EPR
- Publication of updated packaging illustrative base fees. You can access the latest set of illustrative base fees on GOV.UK | Extended producer responsibility for packaging: illustrative base fees.
- Small organisations were initially preparing for an April 2024 submission deadline. This deadline was for submitting packaging data related to packaging placed on the market in 2023. However, the data reporting deadline has been shifted to April 2025, aligning with 2024 placed on market data.
- It was announced in July 2023 that the first EPR payment year will be deferred to 1 October 2025, a year later than the original date of 1 October 2024.
Are you impacted?
You may be impacted if you:
- supply packaged goods to the UK market under your own brand
- package goods for another UK organisation
- use ‘transit packaging’ to protect goods during transport so they can be sold to UK consumers
- import products in packaging
- own an online marketplace
- hire or loan out reusable packaging
- sell empty packaging.
What are the requirements?
You may need to:
- collect and report data on the packaging you supply or import
- pay a waste management fee
- pay scheme administrator costs
- pay a charge to the environmental regulator
- get packaging waste recycling notes (PRNs) or packaging waste export recycling notes (PERNs) to meet your recycling obligations
- report information about which nation in the UK packaging is supplied in and which nation in the UK packaging is discarded in – this is called ‘nation data’.
What you need to do depends on whether you’re classed as a ‘small’ or ‘large’ organisation.
This will be based on your annual turnover and how much packaging your handle and supply each year. The definitions of these can be found below.
UK Packaging EPR – who it affects
Organisations placing 25 tonnes of packaging onto the UK market who also have a minimum turnover of £1 million, are required to report under EPR and are defined as ‘Packaging Producers’ in the new regulations.
Small organisations
You are classed as a ‘small organisation’ if either of the following apply:
- your annual turnover is over £1 million
- and you’re responsible for supplying or importing between 25 tonnes and 50 tonnes of empty packaging or packaged goods in the UK.
Small organisation EPR obligations are as follows:
- You will report data once a year.
- You will not be obligated to pay a Local Authority Waste Management fee.
Large organisations
You will be classed as a ‘large organisation’ if both of the following apply:
- you have an annual turnover of £2 million or more (based on your most recent set of audited accounts)
- you are responsible for supplying or importing more than 50 tonnes of packaging or packaged goods in the UK.
Large organisation EPR obligations are as follows:
- You will report data at least twice a year.
- Pay for disposal costs for the packaging waste that goes into household collection and street bins.
- Meet recycling obligations (met by acquiring PRNs/PERNs).
- 'Nation data’ – report where packaging is disposed, by nation within the UK.
Packaging data – what you need to collect
Your data submission must include the weight of:
- individual materials in the packaging you handle and supply
- materials used in your ‘primary,’ ‘secondary,’ ‘shipment,’ and ‘transit’ packaging
- packaging likely to become household or non-household waste
- packaging likely to end up in street bins.
The scheme administrator will use your 2023 data to calculate your waste management fees for the financial year 2024 to 2025.
The regulator will use your 2023 data to calculate the amount of PRNs and PERNs you must buy to cover your recycling obligations for the 2024 calendar year.
Deadlines
Fees will be incurred from 1 April each year based on packaging supplied by the registered producers for the preceding calendar year.
Small organisation:
- Should have collected their 2023 packaging data but they do not have to report it.
- They should collect their 2024 data and submit it by 1 April 2025.
Large organisation:
In England, Scotland and Northern Ireland you should submit by:
- 1 October 2023 to report for January to June 2023.
- 1 April 2024 to report for July to December 2023.
- 1 October 2024 to report for January to June 2024.
- 1 April 2025 to report for July to December 2024.
You will need to submit your nation data for the 2024 calendar year by 1 December 2025.
Check if you are required to report on 'nation data' at: GOV.UK | Extended producer responsibility for packaging: who is affected and what to do.
Modulated fees for different materials
In 2025, modulated fees based on packaging recyclability will be introduced.
The fees vary depending on the material used, with higher costs for materials that are harder to recycle. These fees are reviewed annually and aim to incentivise the use of recyclable materials across the supply chain.
Revised illustrative base fees
These are estimates published ahead of the EPR implementation to give businesses a sense of what the actual fees could be. The latest set of illustrative fees helps businesses prepare, but they don't yet reflect the modulated fees that will be in place in 2025.
To prepare businesses for the implementation of the packaging EPR scheme, the four UK administrations have now published the second in a series of illustrative base fees.
The illustrative fees have decreased across all materials when compared to the first set of illustrative base fees released in mid-August 2024. The size of the ranges has also decreased across all the materials (except for wood, which represents less than 1% of packaging on the market).
You can access the latest set of illustrative base fees at: GOV.UK | Extended producer responsibility for packaging: illustrative base fees.
Reporting tools and support
Defra’s interactive obligation checker has been updated to help businesses assess their obligations. Defra also introduced improvements to the online reporting system to streamline data submission, particularly for small businesses.
A new helpdesk service is now available for businesses with technical queries regarding packaging data reporting.
Does my location matter?
You may have to submit data about which country in the UK your packaging has been sold, hired, loaned or gifted in.
More information on whether you have to submit nation data is available at: GOV.UK | Extended producer responsibility for packaging: who is affected and what to do.