EPR for packaging: what you must do as a ‘small producer’
Source: gov.uk (2025-06-19)

How small producers register and what they must record, report and pay under the extended producer responsibility (EPR) for packaging regulations

If your organisation works with packaging, you may need to register with the regulator, pay a fee and report data about the packaging.

‘Works with packaging’ means doing one of these things:
- supplying packaged goods to the UK market under your own brand
- placing goods into packaging
- importing products in packaging
- selling empty packaging
- hiring or loaning reusable packaging
- running an online marketplace
Throughout the GOV.UK guidance, all these activities are covered by ‘supplying packaging’.

Who this guidance is for

This guidance introduces EPR for packaging to small producers.

Small producers are often called ‘small organisations’ in the rest of the EPR for packaging guidance. These terms are used to mean the same thing.

‘Small producer’ has a specific meaning in EPR for packaging. It is not related to how many people you employ.

What a ‘small producer’ is

A ‘producer’ is generally a business or other organisation that supplies packaging.

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
Businesses over these thresholds are ‘large producers’ and they have different rules and reporting requirements. Check the rest of the guidance if you need information for large producers (https://www.gov.uk/government/collections/extended-producer-responsibility-for-packaging-report-packaging-data)

What information you must collect and report

As a small producer, you must keep records about:
- your ‘packaging activities’ - for example selling, filling or importing packaging
- the ‘class’ of any packaging - for example, packaging for a single sales unit like a crisp packet or packaging for grouping several sales units, like a box for holding many packets of crisps
- what your waste packaging is made of - the ‘packaging material’
- the weight of each packaging material that you’re reporting, in kilograms
Each of the first 3 has a fixed set of categories and codes that you’ll use to report. You must understand these before recording and reporting.

You must record all of your drinks containers as ‘household drinks containers’.

You do not need to split plastic into ‘rigid’ and ‘flexible’ packaging material - you just need to report it as ‘plastic’.

Only use these codes in your reporting:
- SP (small organisation packaging - all)
- HDC (household drinks containers)
Find out about:
- packaging activities (https://www.gov.uk/guidance/how-to-collect-your-packaging-data-for-extended-producer-responsibility#report-packaging-activity-data)
- packaging classes (https://www.gov.uk/guidance/how-to-collect-your-packaging-data-for-extended-producer-responsibility#report-packaging-class-data)
- packaging material (https://www.gov.uk/guidance/how-to-collect-your-packaging-data-for-extended-producer-responsibility#report-packaging-material-and-weight-data)
‘Packaging activities’ are complicated. For example, responsibility for a piece of packaging may change depending on whether you sell it to a large producer or another small producer. Check the guidance (https://www.gov.uk/guidance/how-to-collect-your-packaging-data-for-extended-producer-responsibility#report-packaging-activity-data) then contact the helpdesk (#getting-help) if you are unsure about what to report.

When you must report this data

You must report this data once a year. The annual deadline is 1 April.

You report about waste packaging that you produced in the previous calendar year.

You’d report packaging data for January to December 2025 by April 2026.

There is guidance that gives more detail about reporting dates and deadlines for both large and small producers (https://www.gov.uk/guidance/packaging-data-check-reporting-periods-and-submission-deadlines), and what to do if you miss a reporting deadline.

Who you’re reporting to

Each of the 4 nations of the United Kingdom has its own regulator. You’ll be reporting to and monitored by the regulator for your nation.

The regulators are:
- Environment Agency (England)
- Natural Resources Wales
- Scottish Environment Protection Agency
- Northern Ireland Environment Agency
How to report this data

You must report the data using the report packaging data (RPD) service.

This service may be renamed later in 2025 when it becomes a more general EPR for packaging account.

Only certain people from an organisation can create an account:
- the director or company secretary
- a partner
- a member of a limited liability partnership
Sole traders can create accounts for themselves.

Create an account on the report packaging data service (https://www.gov.uk/guidance/report-packaging-data)

The environmental regulators will have to approve your account. This will make you an ‘approved person’ and it will be your legal responsibility to make sure that the data your organisation submits is as accurate as reasonably possible.

More people can be invited to manage your data once you create an account. They’ll be ‘delegates’ and will also have legal responsibilities.

Registering your organisation

Once you’ve made an account, you must register your organisation with the environmental regulators.

The registration fee is £1,216

The fee is £631 if you use a compliance scheme (#using-a-compliance-scheme). They can register on your behalf.

You’ll have to upload information about your organisation, This includes things like:
- address
- turnover
- packaging activities
- contact details
- the people who’ll be verifying and submitting your data
You’ll upload this as a CSV - a kind of spreadsheet. There is separate guidance explaining exactly what you need to supply (https://www.gov.uk/government/publications/organisation-details-how-to-create-your-file-for-extended-producer-responsibility-epr-for-packaging), and how to structure the information. There are also templates to help you (https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-templates-for-organisation-details).

Once you’ve submitted your organisation details, your packaging data and paid your registration fees, you can submit your registration application.

The regulator cannot consider your registration application until you have provided your packaging data.

Find out more about registering with the regulators (https://www.gov.uk/guidance/extended-producer-responsibility-for-packaging-register-and-pay-the-fee), including more details about fees.

Reporting your packaging data

You’ll use the service to upload and submit another CSV file containing your packaging data.

There is guidance that explains how to structure your data and what codes you must use (https://www.gov.uk/government/publications/packaging-data-how-to-create-your-file-for-extended-producer-responsibility).

The section in that guidance called ‘Small organisation packaging - all’ rules (https://www.gov.uk/government/publications/packaging-data-how-to-create-your-file-for-extended-producer-responsibility/packaging-data-file-specification-for-extended-producer-responsibility#small-organisation-packaging---all-rules) is the one that gives the most detail for small producers - follow this.

There is a tool that will generate a packaging data file (https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-generate-a-packaging-data-file) from the data that you have.

There are also example files (https://www.gov.uk/government/publications/extended-producer-responsibility-for-packaging-example-file-for-packaging-data) that show you what a well-formed CSV looks like, although these illustrate large producer submissions at the moment.

Waste disposal fees and recycling obligations

As a small producer, you do not have to pay waste disposal fees or buy packaging waste recycling notes (commonly called ‘PRNs’).

Using a compliance scheme

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

You’ll have to pay a fee to the compliance scheme for their services.

Compliance schemes can:
- pay your registration fees on your behalf
- report your packaging data
A compliance scheme cannot register your organisation on the service.

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).

Getting help

If you have any questions, contact your regulator or the EPR for packaging customer service team.

Environment Agency

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

Natural Resources Wales

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

Scottish Environment Protection Agency

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

Northern Ireland Environment Agency

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

Defra EPR for packaging customer service

Telephone: xx-xxxx-xxxx Monday to Friday, 8am to 4:30pm

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