Extended producer responsibility for packaging: who is affected and what to do
Source: gov.uk (2025-05-19)

How UK organisations that supply or import packaging should comply with extended producer responsibility (EPR) for packaging.

The way UK organisations responsible for packaging must carry out their recycling responsibilities has changed.

If you’re affected by extended producer responsibility (EPR) for packaging, you may need to report your packaging data and pay fees based on your data .

A separate guidance collection covers existing producer responsibility regulations (https://www.gov.uk/government/collections/producer-responsibility-regulations) – you may need to meet both sets of regulations depending on your situation.

Check if you need to take action

The regulations will apply to all obligated UK organisations that import or supply packaging.

You need to collect and report packaging data for a given year if all the following apply:
- you’re an individual business, subsidiary or group (but not a charity)
- you have an annual turnover of £1 million or more, based on your most recent annual accounts up to 7 April
- you were responsible for importing or supplying more than 25 tonnes of packaging to the UK market in the previous calendar year
- you carry out any of the packaging activities
If this guidance says you may need to take action, check the rest of the guidance on packaging data (https://www.gov.uk/guidance/how-to-collect-your-packaging-data-for-extended-producer-responsibility) - this will help you confirm whether you must record and submit your data, and what you must submit.

If you’re a small producer

A ‘small producer’ is an organisation that either:
- has an annual turnover of more than £1 million and up to £2 million and supplies more than 25 tonnes of packaging in the UK
- has an annual turnover of more than £1 million and supplies more than 25 tonnes and no more than 50 tonnes of packaging in the UK
Find out what you must do as a small producer (https://www.gov.uk/guidance/epr-for-packaging-what-you-must-do-as-a-small-producer).

Packaging definition

Packaging is any material that is used to cover or protect goods that are supplied. It makes handling and delivering goods easier and safer. It includes anything that’s designed to be filled at the point of sale, such as a coffee cup.

Find out more about what constitutes primary, secondary, tertiary and shipment packaging (https://www.gov.uk/guidance/how-to-collect-your-packaging-data-for-extended-producer-responsibility#packaging-class-data).

Packaging also makes goods look appealing for sale and may display a company’s logo or brand. ‘Goods’ could include raw materials or manufactured items.

There are detailed illustrations and examples in the ‘agreed positions and technical interpretations’ guidance, produced by the environmental regulators. It is currently stored on the National Packaging Waste Database (https://npwd.environment-agency.gov.uk/Public/Guidance.aspx?CategoryId=41fc1dbb-47a2-47fd-bb82-4938d83729e0&ReturnUrl=%2FPublic%2FNewsAndGuidance.aspx%3FReturnUrlId%3D64c793b7-1cf6-ed11-9f3b-98f2b327e115).

Packaging activities

You may need to act if you do any of the following:
- supply packaged goods to the UK market under your own brand
- place goods into packaging
- import products in packaging
- own an online marketplace
- hire or loan out reusable packaging
- supply empty packaging
Organisations that supply packaged goods to end users in the UK may need to collect ‘nation data’. You can find out more about this in the ‘check if you need to report nation data’ section.

Supplying goods to the UK market under your own brand

You may need to take action if packaged goods labelled with your own brand are supplied to the UK market. A brand includes any of the following:
- a name
- a trademark
- any distinguishing mark
For example, a UK confectionery company manufactures and packages sweets under their own brand. It sells these sweets to a UK supermarket. The supermarket goes on to sell the sweets to UK end users. In this instance, the confectionery company must take action.

However, the UK confectionery company would not need to take action if it produced and packaged sweets under the UK supermarket’s brand, which the supermarket then sold to UK end users. In this instance, the UK supermarket must take action.

You may also need to take action if you pay or license another company to do any of the following for you:
- produce branded packaged goods that will be sold under your brand name
- pack branded packaged goods that will be sold under your brand name
- place your branded packaged goods on the UK market
- import branded packaged goods for you
Placing goods into packaging

If you place goods into packaging you may need to take action. This could be goods you packaged for your own organisation or for another organisation.

Importing products in packaging

You may need to take action if your organisation imports products from outside the UK that are in packaging and goes on to supply these products to the UK market.

You may need to take action if you sell imported goods that are packed or filled by a UK third party on behalf of a company that is not established in the UK.

You may need to take action even if you discard packaging before selling the goods.

You do not need to take action if you import filled packaging that is:
- branded, and you’ve imported it on behalf of a brand owner that is established in the UK
- unbranded, and you go on to supply it to a ‘large’ organisation that applies its brand before supplying it on
The ‘check if you’re a large or small organisation’ section explains which organisations are classed as ‘large’.

You can check a list of large producers (https://www.gov.uk/government/publications/list-of-large-producers-on-the-report-packaging-data-service) who have submitted data to the regulators. The list will be regularly updated.

Owning an online marketplace

Under EPR for packaging, you’re classed as carrying out the ‘owning an online marketplace’ activity if you operate a website or app that allows non-UK businesses to sell their goods into the UK. If you own an online marketplace, you may need to take action.

If your organisation owns a website or app that sells goods from UK organisations only, this is not classed as carrying out the ‘owning an online marketplace’ activity. However, you should check if you carry out any of the other packaging activities.

Hiring or loaning out reusable packaging

If you hire or loan out reusable packaging, you may need to take action.

For example, some organisations hire or loan out wooden pallets to other organisations for transporting goods. The wooden pallets are returned after use and loaned out again.

Supplying empty packaging

You may need to take action if you manufacture or import empty packaging and then supply it to a business that is not classed as a large organisation, or supply this packaging to a large producer that does not fill the packaging.

You can find out what the criteria are for a large organisation in the ‘check if you’re a large or small organisation’ section.

What you may need to do

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 is based on:
- your annual turnover
- how much packaging you supply or import each year
Check if you’re a large or small organisation

You’re classed as a small organisation if either of the following apply:
- your annual turnover is between £1 million and £2 million and you’re responsible for supplying or importing more than 25 tonnes of packaging in the UK
- your annual turnover is over £1 million and you’re responsible for supplying or importing between 25 tonnes and 50 tonnes of packaging in the UK
You will be classed as a large organisation if both of the following apply:
- you have an annual turnover of £2 million or more
- you’re responsible for supplying or importing more than 50 tonnes of packaging in the UK
For 2024 data:
- base your annual turnover on your business turnover up to 7 April 2024
- base your packaging weight on the amount you supplied or imported in the 2023 calendar year
For 2025 data:
- base your annual turnover on your business turnover up to 7 April 2025
- base your packaging weight on the amount you supplied or imported in the 2024 calendar year
If you’re a small organisation

To comply with the regulations, you should have recorded data about the packaging you supplied or imported into the UK in 2024 and reported this data by 1 April 2025.

Find out what period you must collect data on and the deadlines for reporting (https://www.gov.uk/guidance/packaging-data-check-reporting-periods-and-submission-deadlines)

If you’re a large organisation

To comply with the regulations, you may need to:
- record data about the empty packaging and packaged goods you supply or import in the UK - find out what period you must report on and the deadlines for reporting (https://www.gov.uk/guidance/packaging-data-check-reporting-periods-and-submission-deadlines)
- create an account for your organisation (https://www.gov.uk/guidance/report-packaging-data)
From 2025, you may need to do the following, based on your 2024 data:
- pay a waste management fee
- pay scheme administrator costs
- pay a registration charge to the environmental regulator
- get PRNs or PERNs to meet your recycling obligations
- report data about packaging you supplied or imported – this includes packaging around raw materials
Your waste management fee will initially be calculated based on packaging you’ve reported as ‘household packaging’. Find out more about what’s classed as household packaging (https://www.gov.uk/guidance/how-to-collect-your-packaging-data-for-extended-producer-responsibility#household-and-non-household-packaging).

The deadline for reporting depends on which nation your organisation is based in. Find out more about the deadlines for reporting (https://www.gov.uk/guidance/packaging-data-check-reporting-periods-and-submission-deadlines).

If you miss the deadline, you may need to pay a late fee.

You’ll need to report data every 6 months.

You may also need to collect and report nation data. Find out more about nation data (#check-if-you-need-to-collect-nation-data).

PRNs and PERNs

A PRN (packaging waste recycling note) or PERN (packaging waste export recycling note) is evidence that packaging waste has been recycled.

You can get PRNs from accredited reprocessors. Reprocessors are responsible for recycling packaging waste. You can also get PERNs from accredited exporters.

By getting PRNs and PERNs, you work towards meeting your recycling obligations.

Recycling obligations will apply from 2025 onwards based on your 2024 data.

Period you must report on

There are different reporting periods depending on what year you will be reporting for, and whether you will be reporting as a small or large producer.

Find out more about reporting periods and deadlines (https://www.gov.uk/guidance/packaging-data-check-reporting-periods-and-submission-deadlines).

If you’re a parent company, group or subsidiary

Parent companies and their subsidiaries can comply with EPR for packaging in different ways. They can comply as:
- a whole group – the parent group creates an account and reports packaging data on behalf of each subsidiary that supplies packaging
- individual subsidiaries – each subsidiary that supplies packaging creates an account and reports independently
- a mix of the other ways – the parent company reports on behalf of some parts of the group, while other subsidiaries report for themselves
If the parent group is reporting on behalf of some or all of its subsidiaries, you’ll need separate packaging data for each subsidiary. Check the guidance on creating your packaging data file (https://www.gov.uk/government/publications/packaging-data-how-to-create-your-file-for-extended-producer-responsibility) for more information.

If you’re part of a group of companies

If you’re part of a group of companies, add up the turnover and weight of packaging supplied or imported for all members of the group that supply or import any packaging at all. If these totals meet the criteria for a small or for a large organisation, then each of these members must comply with EPR for packaging. It does not matter whether they meet the criteria individually.

When calculating a total, do not include the turnover of any parts of the group that do not supply or import packaging. These parts of the group do not need to report packaging data.

If you’re complying as an individual subsidiary

Create an account (https://www.gov.uk/guidance/report-packaging-data) and report packaging data as an individual subsidiary, rather than as part of your parent company.

If you supply or import any packaging at all, you must report packaging data, regardless of your annual turnover.

If you’re complying as a parent company for part of the group

If some of your subsidiaries are going to report independently and some as part of the group, you can create an account as a parent company for part of the group and report on that part’s behalf.

Do not include any subsidiaries that are creating an account independently.

Every subsidiary that supplies or imports any packaging at all must report its packaging data, regardless of its annual turnover.

More information and examples

There are detailed illustrations and examples in the ‘agreed positions and technical interpretations’ guidance, produced by the environmental regulators. It is currently stored on the National Packaging Waste Database (https://npwd.environment-agency.gov.uk/Public/Guidance.aspx?CategoryId=41fc1dbb-47a2-47fd-bb82-4938d83729e0&ReturnUrl=%2FPublic%2FNewsAndGuidance.aspx%3FReturnUrlId%3D64c793b7-1cf6-ed11-9f3b-98f2b327e115).

Check if you need to collect nation data

Nation data is information about which nation in the UK packaging is supplied in and which nation in the UK packaging is discarded in.

If your organisation must act under EPR for packaging, you must submit nation data if you also do any of the following:
- supply filled or empty packaging directly to customers in the UK, where they are the end user of the packaging
- supply empty packaging to UK organisations that are either not legally obligated, or are classed as a small organisation
- hire or loan out reusable packaging
- own an online marketplace where organisations that are based outside the UK sell their empty packaging and packaged goods to UK users
- import packaged goods into the UK for your own use and discard the packaging
You will need to submit your nation data for the 2025 calendar year by 1 April 2026.

Nation data should show where in the UK you’ve supplied packaging to a person or business who’s gone on to discard it.

Supplying packaging includes:
- selling
- hiring
- loaning
- gifting
This also includes packaging that you’ve imported and then discarded.

If you miss the deadline, you may need to pay a late fee.

Reporting nation of sale data and self-managed organisation waste for 2024 to 2026

The environmental regulators have issued a statement on nation of sale data and data about self-managed organisation waste.

This only applies to nation of sale data and data about self-managed organisation waste. It does not apply to any other data you must collect for EPR for packaging.

Read the regulatory position statement (https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-pepr-producer-data-requirements-rps-330) to understand how this affects your data submission.

Collecting and reporting your packaging data

Your data submission must include the information about the:
- packaging activity – this is how you supplied the packaging
- packaging type – for example, if the packaging is household or non-household
- packaging class - whether the packaging is primary, secondary, shipment or tertiary
- packaging material and weight
Find out more about how to collect your packaging data (https://www.gov.uk/guidance/how-to-collect-your-packaging-data-for-extended-producer-responsibility).

Information about fees

There is separate guidance that expains fees and recycling obligations (https://www.gov.uk/guidance/extended-producer-responsibility-for-packaging-recycling-obligations-and-waste-disposal-fees).

Illustrative base fees for EPR (https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-illustrative-base-fees) are available. The illustrative fees are a first estimate, based on the best available evidence to date, and are not final figures.

Your fee will be lower if you use packaging that is easier to recycle. Find out more about the recyclability assessment methodology (https://www.gov.uk/guidance/recycling-assessment-methodology-how-to-assess-your-packaging-waste), including how to report recyclability and how fees will be modulated.

You will also have to pay a registration fee when you register your organisation (https://www.gov.uk/guidance/extended-producer-responsibility-for-packaging-register-and-pay-the-fee).

Getting help from a third party (compliance scheme)

Compliance schemes are third parties that help organisations meet the EPR for packaging requirements.

Compliance schemes can:
- pay your registration fees on your behalf
- report your packaging data
- get PRNs or PERNs to meet your recycling obligations
A compliance scheme cannot register your organisation on the service and you will have make your waste management payments yourself.

If you choose to work with a compliance scheme, you should make sure they appear on the compliance scheme public register (http://npwd.environment-agency.gov.uk/PublicRegisterSchemes.aspx).

Get help and give feedback

If you have any questions, contact the packaging team.

Email: xxx@xxx.xx (mailto:xxx@xxx.xx)

Defra is looking for waste and packaging professionals to join a user panel to help improve our services. Find out more information and how to take part in resources and waste research sessions (https://defragroup.eu.qualtrics.com/jfe/form/SV_byGvZLurq3CMkGG).