Packaging regulations

Extended Producer Responsibility

What the UK’s Extended Producer Responsibility scheme for packaging means for your business – and how to tell whether it applies to you.

Overview

What is EPR?

Extended Producer Responsibility (EPR) is replacing the Producer Responsibility Packaging regulations, introduced in 1997 to increase recycling rates. Within 25 years, recycling rose by around 70% – and corrugated cardboard and paper packaging reached a recycling rate of around 84%.

With businesses, consumers and government increasingly conscious of the environmental damage caused by packaging waste, plastic packaging has been at the forefront of scrutiny – and the Plastic Packaging Tax (PPT) was the first step to address it.

EPR significantly increases businesses’ responsibility for the environmental impact of their packaging. Businesses will contribute to the costs of collecting, sorting and recycling the packaging they place on the market.

~70%

Rise in recycling within 25 years of the 1997 regulations

~84%

Recycling rate for corrugated cardboard and paper packaging

The goal

What is the goal of the EPR scheme?

EPR is designed to encourage businesses to source more sustainable packaging – creating a more circular economy and increasing recycling rates. It works as a financial incentive to use recyclable materials and to include recycled content in packaging.

Under the scheme, businesses may need to:

Report packaging data

Pay fees

Purchase packaging waste recovery notes

Show how much packaging has been recycled

Cover the net cost of packaging waste

Rather than it falling on the taxpayer.

Who it affects

Do your packaging activities qualify?

It’s not only the type of packaging you use that decides whether you’re financially liable or need to report it. EPR may also apply if your business:

Sells under its own brand

Supplies goods or products into the UK market in your own brand.

Uses unbranded packaging

Places goods or products into unbranded packaging.

Imports goods

Uses packaging to import goods or products.

Runs an online marketplace

Owns an online marketplace.

Hires out reusable packaging

Loans out or hires any reusable packaging.

Supplies empty packaging

Supplies empty packaging to other businesses.

The size of your business also determines whether you’re affected by EPR, and what your direct responsibilities are.

Business size

Are you a small or a large producer?

Small producer

Small business

You may qualify as a small producer if:

Your annual turnover is between £1 million and £2 million and you handle or supply more than 25 tonnes of packaging – empty or containing goods – into the UK market, or
Your annual turnover exceeds £1 million and you handle 25–50 tonnes of packaging.

What you’ll need to provide:

Simplified reporting of your packaging usage.

Large producer

Large business

You’re classed as a large producer if:

Your annual turnover exceeds £2 million, and
You handle or supply more than 50 tonnes of empty packaging or packaged goods into the UK market.

What you’ll be liable for:

Purchasing packaging recovery notes (PRNs) – certificates that demonstrate your compliance with packaging recycling targets.
Paying associated fees and costs, including fees for packaging waste management and recycling schemes.

Groups & subsidiaries

How does EPR affect parent companies, groups and subsidiaries?

Businesses within a parent company, group or subsidiary structure have several options for registering for packaging EPR.

Group registration

The parent company registers as a single entity for the whole group, taking responsibility for EPR compliance for all its subsidiaries.

Individual subsidiary

Each subsidiary registers independently. Subsidiaries that exceed the turnover and packaging tonnage thresholds must register and submit their own reports.

Selective registration

The parent company registers some, but not all, of its subsidiaries – suitable when only some subsidiaries meet the compliance requirements.

Collective compliance

Where subsidiaries don’t meet the turnover and tonnage thresholds individually but do exceed them collectively, the parent company must register and take responsibility for their compliance.

Looking ahead

EPR will play a growing role in UK sustainability

EPR requires more detailed reporting of packaging use from both large and small businesses. As environmental concerns continue to grow, it’s likely to become an increasingly important policy tool – playing a vital role in the UK’s transition to a more circular economy, where resources are used efficiently and waste is kept to a minimum.