EPR Packaging — What It Is, Whether It Affects You, and What to Do Next
If you've heard the term "EPR" thrown around and had no idea what it means — this guide is for you. No jargon, no waffle. Just the stuff that actually matters for your business.
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So… What Actually IS EPR?
Okay, let's make this really simple. Imagine you run a biscuit company. You sell your biscuits in a plastic tray, wrapped in a cardboard box. When your customer finishes the biscuits, they throw away the box and the tray.
Someone has to deal with all that packaging. Someone has to collect it, sort it, and recycle it. That costs money. In the past, the government (and therefore taxpayers) mostly paid for that. Now the rules have changed.
EPR — Extended Producer Responsibility — is the new regulatory system that says: if your business puts packaging on the UK market, you help pay for the cost of dealing with it.
The one-line version:
Your packaging generates waste. EPR makes sure the businesses creating that packaging help pay to clean it up.
Does This Affect Your Business?
Here's how to know if EPR applies to you. Ask yourself three questions:
Government and industry estimates suggest that many tens of thousands of UK businesses are now in scope of packaging EPR — including manufacturers, importers, retailers, and online sellers. If you have more than £1m turnover and handle more than 25 tonnes of packaging, you're very likely one of them.
Does your business make, import, brand, or sell packaged goods in the UK?
This includes pretty much any product that arrives in any kind of packaging — plastic, cardboard, glass, metal, wood.
Does your business have a turnover of more than £1 million per year?
Businesses below £1m turnover or under 25 tonnes of packaging a year are currently outside the EPR thresholds — but should still track tonnage in case they grow.
Does your business handle more than 25 tonnes of packaging per year?
That sounds like a lot, but for many manufacturers and importers it adds up quickly. One tonne = roughly 1,000 kg. Your answer here also determines whether you're a small or large producer — which affects how often you must report.
What type of producer are you?
Small Producer
£1m–£2m turnover and 25–50 tonnes of packaging per year
Lighter duties: report once a year, by 1 April.
Large Producer
≥£2m turnover and >50 tonnes of packaging per year
Full duties: report twice a year (April and October), higher fees.
If you answered yes to all three: EPR applies to you. Whether you're a small or large producer changes your reporting frequency and fee level — both are covered in this guide.
What Do You Actually Have to Pay?
This is where most businesses get confused — and unfortunately, it's also where most businesses accidentally overpay. Let us break it down simply.
Your EPR fee is calculated based on the weight of packaging you put on the market each year. But — and this is the big part — it also depends on what type of packaging it is and who ends up with it.
Household packaging
Packaging that ends up in people's homes (e.g. cereal boxes, water bottles, shopping bags). This attracts higher fees because councils have to collect and process it.
Non-household packaging
Packaging that stays in businesses — like the pallet wrap around your delivery or the cardboard used in B2B shipments. This attracts lower fees.
There's more on top: PRNs and waste management fees
Under packaging EPR you'll still need PRNs or PERNs (Packaging Recovery/Export Recovery Notes) to meet your recycling obligations — usually procured by your compliance scheme if you're registered with one. On top of that, you'll pay new waste management fees that reflect the cost of collecting and treating your household-type packaging through local authority kerbside systems.
The overpayment problem is real
Industry reviews of EPR data often find four- and five-figure annual overpayments where packaging has been misclassified as household or incorrectly allocated between nations. For a mid-size business, that's typically £5,000–£15,000 a year. Getting this wrong once costs a lot. Getting it wrong for years is even worse.
Important Dates You Can't Ignore
The EPR calendar can feel overwhelming — there are lots of deadlines and they matter. Miss one and you could face late fees or enforcement action. Here are the ones that matter most right now.
Updated EPR rules come into force
From 1 January 2026, updated EPR rules apply. If you meet the EPR thresholds and haven't registered by your regulator's deadline, you may be non-compliant and at risk of enforcement action.
Data submission deadline
This deadline covers all small producers (full 2025 data) and large producers (Jul–Dec 2025 data) — so it affects the majority of obligated businesses. Don't miss it.
Mid-year data submission (planned — large producers)
Large producers must submit January–June 2026 packaging data, including mandatory Self-Managed Organisation Waste data, by 1 August 2026.
Notice of Liability issued
Your EPR invoice for the year will be sent. This is based on the data you submitted.
Deposit Return Scheme goes live
New rules for drinks packaging. More detail to come in 2026 as the DRS organisation builds out its systems.
7 Practical Tips to Stay on Top of EPR
These are the things we tell every client. Get these right and you're already ahead of most businesses in the UK.
Tip 1: Know your tonnage — it's the first thing anyone will ask
If you don't know how many tonnes of packaging your business uses each year, start there. Add up all your packaging — plastic, cardboard, glass, metal — by weight. You need this number to know if EPR applies to you at all.
Tip 2: Don't classify everything as 'household' packaging
This is the most common mistake. Lots of businesses assume all their packaging is household because it's simpler. But B2B transit packaging, pallet wrap, and internal distribution packaging is non-household — and it attracts much lower fees. Review your split carefully.
Tip 3: Join a compliance scheme — don't go it alone
Unless you're a large business with a dedicated compliance team, managing EPR yourself is hard work. Compliance schemes (like Valpak or Veolia) handle your data submissions and fee payments for you. They're worth every penny.
Tip 4: Keep records of your packaging data — all of it
The regulator can ask to see your packaging records going back several years. Keep weight data, material types, and submission history somewhere safe and organised. Losing this data is a compliance failure even if you've paid the right fees.
Tip 5: Put the important dates in your calendar right now
The 1 April 2026 deadline covers all small producers and half-year data for large producers, so it affects the majority of obligated businesses. Missing it triggers late fees and puts you on the regulator's radar. Put it in your diary today.
Tip 6: Get a fee review — most businesses are overpaying
More than half of businesses we speak to have never had their EPR fees independently checked. A proper review takes a few hours and often finds four- or five-figure annual overpayments. It pays for itself almost immediately.
Tip 7: Sort your data systems before the next deadline — not after
Regulators reported a noticeable number of late or corrected submissions for the very first EPR data deadlines in 2025, mainly due to poor data systems. Getting your process sorted in 2026 means you're far less likely to be flagged for follow-up or enforcement.
What Do You Actually Need to Do Right Now?
Not sure where to start? Here's the simplest version of what you need to do, in order.
Work out your annual packaging tonnage
Add up all materials across your whole business.
Check if you're above the registration threshold
25+ tonnes AND £1m+ turnover = you must register. 50+ tonnes AND £2m+ = you're a large producer with twice-yearly reporting.
Register with the Environment Agency
Or check your existing registration is current and correct.
Join a compliance scheme (or review your current one)
They handle submissions and fees for you.
Review your household vs non-household split
This is where most businesses overpay. Don't skip this.
Set up a packaging data tracking system
Even a simple spreadsheet is better than nothing.
Mark the April 2026 deadline in your calendar
It affects large and small producers alike.
What's Coming Down the Track?
EPR isn't going away — it's getting bigger. Here are three things happening in the next few years that every producer should know about.
Recyclability Assessments (from 2026)
The current RAM v1.1 has already been in force since January 2025. A new RAM 2027 version is expected in July 2026, with updated criteria applying from January 2027. That gives packaging teams a roughly six-month window in late 2026 to check their designs against the new rules and plan changes. If your packaging scores poorly on recyclability, you'll pay higher EPR fees — and packaging redesigns typically take 2+ years, so businesses need to start planning now.
Deposit Return Scheme — October 2027
The UK is introducing a deposit return scheme for drinks containers. When a customer buys a drink in a plastic bottle or can, they'll pay a small deposit and get it back when they return the empty. If you produce drinks packaging, this will affect your labelling and reporting requirements.
Digital Waste Tracking — from October 2026
A new digital system will track where all UK waste goes — and from October 2026, paper waste transfer notes are being phased out, with digital records becoming the default. This gives regulators near real-time data on how waste moves through the system. Your waste contractor will need to be digitally compliant, and you'll need to verify that your collections are correctly logged. Check with your contractor now — don't wait until October.
Quick Answers to Common Questions
Q: What if I'm a small business — does EPR still apply?
If your turnover is below £1 million per year, you're currently exempt from registering. However, you still need to know your packaging tonnage in case your business grows past the threshold.
Q: I sell goods on Amazon. Am I responsible for EPR?
Yes — online marketplace sellers are treated as producers under EPR. If you import goods and sell them on platforms like Amazon, eBay, or Etsy, you're responsible for the packaging on those goods.
Q: What happens if I don't register?
If you should be registered and you're not, regulators can take enforcement action — including financial penalties and, in serious cases, criminal prosecution with potentially unlimited fines. In practice, regulators use a mix of civil penalties and enforcement undertakings, escalating to prosecution for deliberate non-compliance. Either way, it's not worth the risk.
Q: How do I know if I'm overpaying my EPR fees?
The most common sign is that you've never had your household/non-household classification reviewed. If your compliance scheme or advisor hasn't specifically checked this with you, there's a good chance you're paying more than you need to.
Q: Does EPR apply if I only export goods?
If you're exporting goods and the packaging leaves the UK, those goods may be exempt from UK EPR fees — but you need proper documentation to prove it. If you can't evidence the export, you'll pay the fee.
Still not sure where your business stands?
Book a free 15-minute call with one of our EPR specialists. We'll look at your specific situation, tell you exactly what applies to you, and give you a clear action plan — no charge, no obligation.
Millstone Compliance — independent EPR advisors with no ties to any compliance scheme