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Extended Producer Responsibility for packaging (EPR)

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Overview

Since 1997, businesses that put packaging onto the UK market have been required to meet recycling targets under a system of producer responsibility whereby producers must contribute to the cost of recycling. From 1 January 2025, the system changed from one of just meeting targets to one where businesses also have to meet the ‘full net cost’ of collection, transport, recycling and disposal by paying a fee that will be used to pay for the costs incurred by local authorities in the management of packaging waste.

This system – known as EPR (Extended Producer Responsibility) – is applied through The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024.

The Producer Responsibility Obligations (Packaging and Packaging Waste) (Amendment) Regulations 2025 came into force on 1 Jan 2026 applying fee increases averaging around 8% to all fees for producers, reprocessors and exporters (amongst many other amendments).

The basic requirements of these regulations are the same as the previous 2007 regulations whereby obligated businesses must report on the amount of packaging they have placed on the UK market to which annual recycling targets are applied that must be met by buying evidence of recycling – PRNs – supplied by accredited reprocessors and exporters.

However, there are some fundamental changes under the new system that affect the types of businesses that are obligated and how much they will have to pay. The key change is that as well as acquiring PRNs, producers that supply items in household packaging (defined below) must pay a ‘waste fee’ on the total weight of that packaging supplied in the previous year.

Producers – summary of requirements

The thresholds above which a producer becomes obligated have been changed.

  • A large producer is one with a turnover in their latest accounts that is greater than £2m and that placed more than 50 tonnes of packaging onto the market in the previous year including primary packaging around products sold to the end user (known as Nation Data).
  • A small producer is one with a turnover between £1m and £2m and that placed more than 25 tonnes onto the market in the previous year.

EPR changes the definition of a producer from the one under the old system (that has a share of four activities; raw material manufacturer, convertor, pack filler & seller) to one where they come under one or more of the following descriptions and where they will take 100% responsibility for the packaging they handle:

  • Brand owner– A person whose name, trade mark or other distinctive mark appears on an item of filled packaging is a producer in relation to that item of packaging and any item of packaging contained within branded packaging, or forming primary packaging together with the branded packaging, whether or not that item is also branded.
  • A packer/filler is a producer in relation to any filled packaging which is filled by the packer/filler; and for which there is no brand owner.
  • An importer is a producer in relation to any filled packaging imported into the United Kingdom by the importer which is transport packaging or secondary packaging or any other packaging for which there is no brand owner where the brand owner is not responsible for the import of the packaging; or for which the brand owner is not a large producer.
  • A distributor is a producer in relation to any unfilled packaging which is manufactured or imported by the distributor and supplied to a person who is not a large producer
  • An online marketplace operator is a producer in relation to; (a) any packaging on items which are sold on their online marketplace by a person, acting in the course of business, who is not established in the United Kingdom; and (b) any unfilled packaging supplied on their online marketplace— (i) by a person, acting in the course of business, who is not established in United Kingdom; (ii) to a business which is not a large
  • A service provider is a producer in relation to any reusable packaging, the first time that packaging is supplied, but not otherwise.

A seller is a large or small producer that supplies packaged goods in any type of packaging to the end user that removes the packaging. Sellers will be required to report on the UK nation the packaging left to go to the end user and the nation in which that packaging is then removed by the end user. Eg hotel chain sells beverages in 200 tonnes of glass packaging in the year but provides hot drinks to take away in 100kg of paper cups. They must enrol as a large producer and report on the paper cups they have pack filled.

Exported packaging is excluded from obligations and does not have to be reported.

Large producers should have been submitting half-yearly data reports (1 April and 1 October) since 2023 and have to register annually by 1 April each year. Small producers are required to register annually by 1 April with annual data for the previous year. Registration will require fees to be paid to the regulators (EA, SEPA, NRW, NIEA).

Enrolling

All producers must enrol on a new system called RPD (Report Packaging Data) prior to submitting data by the deadlines.

The initial enrolment must be carried out by a director or company secretary who can then delegate the submission of data files to another person. The system is about as un-user friendly as you can get and patience is required. An email address can only be used for one organisation, therefore consultants or persons managing data for a number of separate businesses or subsidiaries within a group have to have a different email address for each organisation enrolment.

Once enrolled, a producer must submit organisation details and data in CSV format by the 6-monthly deadlines (or annually for a small producer). The following are the key templates and guidance pages:

If the producer is a member of a compliance scheme, the scheme must report this data.

Producer registration

  • Registration is required annually by 1 October. Registration can either be direct with the relevant environmental Agency (EA, SEPA, NRW or NIEA) or with a Compliance Scheme (CS).
  • Registering direct enables the producer to avoid CS fees and markups on PRNs, but the producer is then legally liable if it fails to secure the PRNs it needs to meet its recycling targets.
  • Registering with a CS reduces the registration fee (see below) but there will be significant CS fees. However, the CS takes full legal responsibility for meeting its member’s targets.
  • Online businesses – those selling products on behalf of overseas companies – have to pay an additional registration fee on top of the standard fee.
  • The EPR regulations give the Agencies greater powers than under the previous regulations to take enforcement action against producers who do not submit their data by the statutory deadlines. This will be through Civil Sanctions and can take the form of Enforcement Undertakings or more likely, a Variable Penalty.

 Producer data reporting

Under the previous system, packaging was packaging. EPR now requires packaging to be reported under a number of different types with the main aim of distinguishing household packaging from non-household packaging. This is because household packaging will have a waste fee applied per tonne placed on the market whereas all packaging will be subject to the recycling targets.

Previously, data had to be reported once a year by early April. EPR requires data to be reported:

  • By large producers every 6 months by 1 April (for 1 Jan – 30 Jun) and 1 October (for 1 Jul – 30 Sep)
  • By small producers, annually by 1 April with the previous year’s packaging.

The regulators publish very useful Technical Interpretations guidance (v8) for producers that provides extensive technical information on packaging types and responsibilities as well as a long list of specific packaging items to determine whether they are classed as obligated packaging.

Packaging types

Packaging has to be reported under the following categories:

  • Primary packaging – the packaging around the sales unit.
  • Secondary packaging – the packaging used to convey the sales unit to the sellers.
  • Tertiary packaging (which is not shipment packaging) – transit packaging
  • Shipment packaging – any packaging added to primary packaging for shipping single or multiple sales units to businesses or consumers sold online or via mail order. It includes packaging sent directly to the customer or to a collection point.

Packaging materials

The list of packaging materials that must be reported on is as before – paper, glass, steel, aluminium, plastic, wood and ‘other’ plus a new category of ‘fibre composite’ to cover disposable cups, tetrapak etc.

Definition of household packaging

Only packaging reported as ‘household’ will have the waste fee applied although packaging that will be caught by the Deposit Return System (DRS) will be excluded from the waste fee even though DRS is not due to be implemented until 1 October 2027.

All primary and shipment packaging should be reported as household packaging unless the following applies and can be evidenced:

  • The packaging is supplied directly to a business or public institution, either because the business or public institution is the end user of the goods or because the business or public institution supplies the goods to an end user with all of the packaging removed

OR

  • It is packaging for a product which is designed for use only by a business or a public institution and the packaging for that product is not reasonably likely to be disposed of in a household bin or a public bin.

Packaging that satisfies one test but not both, is treated as household packaging.

Once enrolled, an organisation must submit the following files in CSV format by the 6-monthly deadlines (or annually for a small producer):

Targets

The government has set the following targets through to 2030 although it is anticipated that these will be reviewed in 2026. These are applied to the total tonnage of each material placed on the market in the previous calendar year by the producer. Guidance has been produced for direct registrants to calculate their PRN obligations.

*The ‘melt’ row is the percentage of the glass target that must be met by melt recycling (eg glass manufacture) rather than by the use of waste glass for aggregates etc.

The targets are applied to 100% of the weight that a producer has reported for the previous year and must then be met by the acquisition of PRNs from accredited exporters and UK reprocessorsi n the same way as the current system.

Waste fee

The waste fee applied by EPR is a completely new cost for producers. It has been introduced to comply with Article 8a of the EU Waste Framework Directive – that was in UK law at the time of Brexit – that required producers to pay the full net cost of the collection, transport, recycling and disposal of packaging waste. Initially, Defra initially wanted to apply this to all commercial as well as household waste, but practical issues led to the decision to just apply it to household waste. In theory, it should only apply to packaging waste that is the responsibility of local authorities to collect, but the definition of household waste above means that it will include household-like packaging ending up in commercial waste bins eg beer and wine bottles in the hospitality industry.

The waste is applied to the weight of household-defined packaging placed on the market by every large producer in the previous calendar year, that is a combination of the two 6-monthly sets of data.

Year 2 (2026) illustrative waste fees have been published by PackUK but the final position is unlikely to be known until June/July and will then be applied to 2025 data and invoiced in October 2026. These will take account of the RAM rated modulation for household-defined packaging.

To calculate the potential impact of this on a producer in 2026, it is simply a matter of multiplying the relevant material fee by the total tonnage of household waste (excluding DRS materials) reported by that producer.

From 2026 onwards, the waste fee will be modulated to take account of recyclability. Defra have developed a Recyclability Assessment Methodology (RAM) (19 May 2025 version) that producers will have to use to consider whether their packaging falls into a green, amber or red category. A base fee will then be modulated to raise or lower a base fee, leading, potentially, to a producer having several levels of fee for different sub-materials. For 2025, the regulators have issued a Regulatory Position Statement that enforcement action will not be taken if producers fail to apply RAM to H1 data (1 Jan – 30 Jun 2025) although it is mandatory for flexible and rigid household plastic packaging to be reported separately. PackUK has published illustrative Base Fees for 2026 but clearly, these will change before the final fees are announced.

In addition to the introductory document linked above, there are two further documents to read to assess the category your packaging will fall into:

The waste fee will be collected by the Scheme Administrator (now called PackUK) – through a contracted financial organisation – and passed to local authorities based on claims made against ‘efficient and effective’ service criteria to cover their costs for collection, transport and recycling of recyclables along with a contribution towards the costs of disposal of packaging left in the residual waste stream and in public litter bins.

Nation data

As well as data needed to calculate the targets and the waste fee cost, where obligated large producers supply products in primary packaging to end users, they must also report ‘nation data’ on an annual basis, the first time being by 1 April 2027 for 2026 data. The previous requirements were amended by a Regulatory Position Statement. The table below shows the reporting dates requirement for nation and self managed own waste data.

This applies if they:

  • supply filled or empty packaging 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 through which organisations based outside the UK sell their empty packaging and packaged goods to UK consumers
  • import packaged goods into the UK for your own use and discard the packaging.

Nation data should show which UK nation the packing was supplied to the end user from and which nation it would then have been discarded in.

Self-managed waste

And as if life wasn’t complicated enough, obligated businesses must also report on the packaging waste they have discarded themselves – this has to be reported every six months in the Packaging Data File mentioned above but not until 2027 as amended by the Regulatory Position Statement.

The Scheme Administrator (PackUK)

The Scheme Administrator is a body appointed by Defra that is responsible for the interface between industry and local authorities and for ensuring that producer waste fees are sufficient to meet the payments needed by local authorities to cover their ‘effective and efficient’ packaging waste collection, recycling and disposal costs. The Scheme Administrator is PackUK.

Its main responsibilities include:

  • Incentivising:
    • the use of environmentally sustainable packaging;
    • the prevention of packaging becoming waste;
    • an increase in the reuse of packaging, and in the quantity and quality of packaging materials recycled; and
    • a reduction in the disposal of packaging waste
  • Communicating with producers, packaging manufacturers, scheme operators, relevant authorities and waste management companies
  • Conducting, or making arrangements for, national or local public information campaigns
  • Providing guidance to businesses which are producers, to assist them in understanding and meeting their disposal cost obligations under these Regulations.
  • Assessing the efficient disposal costs of relevant local authorities
  • Assessing the waste income of relevant authorities under regulation
  • Developing a methodology which producers must use to assess the recyclability of the packaging they supply
  • Compiling a list of items of packaging which are commonly disposed of in public bins or as ground litter
  • Compiling a list of:
    • the items which are collected for recycling from households by each relevant authority in each part of the United Kingdom;
    • those items which are collected for recycling from households by more than 75% of the relevant authorities in the United Kingdom responsible for waste collection.

Producer Responsibility Organisation (PRO)

The PRO is a ‘producer-led’ industry body that was appointed by Pack UK in March 2026 to carry out much of the development responsibilities of PackUk. PackUK will retain responsibility for payments to local authorities, but it is expected that the PRO will be more focussed on increasing recycling rates, developing modulated fee levels and potentially, replacing the PRN with an alternative funding mechanism.

Compliance Schemes

Compliance Schemes have to be approved by the relevant regulator (EA, SEPA, NRW, NIEA) and must then register annually. The application requires a 3 year operational plan and evidence of financial robustness and the operator must satisfy a fit and proper person test. There are currently 18 compliance schemes listed on the 2026 public register (the first 14 all registered with the EA):

  • Avask
  • Beyondly
  • Biffpack
  • Comply With Clarity
  • Ecosurety
  • ERP UK
  • Kite Environmental Solutions
  • Packcare
  • Paperpak
  • Recycling Lives Compliance Services
  • REPIC
  • Smart Comply
  • Valpak Limited
  • Veolia
  • Wastepack Northern Ireland (NIEA)
  • Valpak Scotland (SEPA)
  • Scotpak (SEPA)
  • Wastepack (SEPA)

They are responsible for meeting the statutory obligations of their producer members including submitting data that is ‘as accurate as reasonably possible’ and acquiring the necessary PRNs to meet the total obligation of all their members.

In a change from the previous regulations, Compliance Schemes will have to pay a 3-yearly approval fee and an annual registration fee. It will also then have to pay a fee per member to the regulator that is three times the old system fee.

Reprocessors and exporters

For 2026, the accreditation system changed significantly for reprocessors and exporters compared to what they have been used to in previous years. Applications still need to be submitted in September for the following year, but there are many differences, the key ones being:

  • Reprocessors and exporters handling packaging will have to register annually regardless of whether they wish to issue PRNs. They will also then need to apply for accreditation to be able to issue PRNs. Separate registrations/accreditations are required for each material. It is an offence not to be registered if a business is reprocessing or exporting packaging.
  • Registered-only operators have to submit quarterly returns showing significant detail on waste received, exported recycled etc.
  • Accredited operators will have to submit monthly reports with the same information but also reports showing PRN sales and revenue.
  • Exporters will only be able to issue PRNs on waste once it has been received by the destination site and NOT from the date of export that was the previous requirement.
  • A ‘person with significant control’ in each operator will have to satisfy a ‘fit and proper person’ test.
  • Guidance for applying to be registered and accredited can be found here.

Data is largely managed through Summary Log excel spreadsheets specific to exporters and reprocessors. Every load of waste received for reprocessing or export has to be listed and completed Summery Logs for each calendar month submitted by midnight on the 20th of the following month. Tonnage data is then extracted from these to populated monthly data reports.

To be eligible to apply for accreditation, a reprocessor or exporter must be able to demonstrate to the Agency that they are active ie currently recycling or exporting packaging waste of the type that being applied for.

Applying for registration and accreditation

Applications for accreditation (to be able to issue PRNs) can only be submitted at the same time or after an application for registration.

Applications for both require:

These are submitted with an online application form that for accreditation, includes a Business Plan showing the intended use of PRN revenue.

Monitoring

The regulators can audit accredited operators at any stage. If they are not satisfied that the operator is compliant with its conditions of accreditation, they can suspend or cancel the accreditation. Suspensions can be lifted once the operator is compliant but a cancellation is permanent for the rest of the compliance year.

Plastic waste exports

From 21 May 2026, new rules apply to B3011 plastic waste exports from the EU that will affect NI and from 1 Jan 2027, will affect B3011 exports from the UK to the EU.

GB to EU

  • New Annex VII layout required for EU compliance – 21 May 2026
  • DIWASS reporting – 1st January 2027
  • 2 day prior reporting – start date still to be confirmed by commission

GB to OECD or non-OECD and GB to NI and NI to GB

  • No change

EU to EU

  • No change

EU (including NI) to OECD countries

  • PIC procedure for export of non-hazardous plastic waste – 21 May 2026
  • Strict environmental audit obligation – 21 May 2027

EU (including NI) to Non-OECD countries

  • PIC procedure for export of non-hazardous plastic waste – 21 May 2026
  • Complete ban for non-hazardous plastic waste exports – 21 November 2026

Fees

The latest fees are shown here. They are revised each year, supposedly in line with the CPI, but the change from 2025 to 2026 was far higher. 2026 fees are shown below.

Producer registration fees have to be paid annually to the regulators by 1 Oct for the following year, either direct of by the Compliance Scheme

  • To register direct with the Agencies – Large producer – £2842, Small producer – £1303
  • Registration through a Compliance Scheme – per large producer – £1803, small producer – £696
  • In all cases:
    • Fee per subsidiary if registering as a group – £690/subsidiary up to 20, £172/subsidiary over 20
    • Additional fee for online businesses – £2885
    • Late registration fee – £386 per producer
    • Resubmission fee – £512 per producer
    • The registration fee has to be paid  by 1 October for the 2027 compliance year.

Compliance Scheme fees to be paid to the regulators

  • Initial approval – £8,691
  • Annual registration – £14,702 (will have to be paid twice in 2025)

Reprocessors and exporters 

Registration (by 1 Oct each year) per site for reprocessors and per material for exporters

  • £3228 for 1st year
  • £1571 for second and subsequent years

Annual accreditation per site for reprocessors and per material for exporters

  • up to 500 tonnes -£546
  • 501 to 5,000 tonnes – £2184
  • 5,001 to 10,000 tonnes – £3276
  • Over 10,000 tonnes – £3965

For exporters per overseas site (ORS) accreditation approval – £328

To amend an approved Sampling and Inspection Plan – £574

Enforcement

The regulations provide the regulators with much greater powers of enforcement than under the old regulations. For instance, as well as the increased late registration fee shown above, there are a range of Civil Sanctions that can be applied if a producer fails to register – including the submission of data – by the deadlines. This can include a Variable Penalty Notice that can be several thousand pounds depending on the size of the producer and the scale of their obligation. The full list of offences for which Civil Sanctions can be applied is shown here.

Data releases

At present (May 2026), there is a Service Level Agreement in place for producer data but not yet for recycling data.

Producer data is currently being published every two months on the old NPWD website with updates on the previous publication and as soon as available, the latest 6-monthly figures, normally 6 weeks after the data deadlines of 1 April and 1 October.

Recycling data is published on a new GOV.UK page, the first data relating the first quarter of 2026 being published on 18 May following a highly disrupted first quarter of digital delivery issues. Following this first quarter, given that recyclers have to submit monthly reports, data should also be published monthly. However, unlike the old system where the quarterly data gave a clear indication of the amount recycled and eligible for PRNs, changes to the new system, especially the fact that export PERNs can only be claimed once the packaging waste has arrived at the overseas recycling site – mean it is very difficult to determine the reality of likely PRN availability for the year.

Relevant Links

Data

Producers

Reprocessors and exporters

Email addresses