Extended Producer Responsibility for Packaging in the UK: 2025 Update

The way UK organisations manage their packaging responsibilities is changing. Under new Extended Producer Responsibility (EPR) rules, producers will take on more accountability for the packaging they place on the market — and the associated recycling costs.

This shift is part of a broader effort to reduce waste and encourage more sustainable packaging choices. By transferring the financial responsibility from local authorities to producers, the government hopes to drive better packaging design, reduce excess material, and improve recycling rates across the UK.

For many businesses, this means a new set of obligations: more detailed data reporting, possible fees based on packaging type and volume, and a wider focus on the entire lifecycle of packaging materials — not just what happens at the point of sale.

The goal is to move toward a more circular economy, where packaging is used efficiently, reused where possible, and recycled at scale. That’s going to require thoughtful planning. Many organisations will need to revisit their packaging strategies, explore more sustainable options, and put systems in place to track and report data accurately.

It's a significant change — but with the right tools, it's also a chance to make long-term improvements in how packaging is managed.

What is Extended Producer Responsibility?

Extended Producer Responsibility (EPR) is the UK legislation that has replaced the previous packaging waste regulations. Introduced in stages from late 2023, EPR places more responsibility on businesses for the packaging they supply, use, and discard.

Most businesses are now required to record and report data on their packaging. Larger organisations also cover the costs of dealing with packaging waste — whether that’s recycling, landfill, or energy recovery.

The goal is to encourage packaging that’s easier to recycle and to make sure that those placing packaging on the market help fund its recovery. By thinking about the full lifecycle of packaging materials, businesses can reduce waste and improve sustainability across their supply chains.

Is your business obligated under UK EPR?

Your business has an EPR waste obligation if ALL of the following points apply:

It's an individual business, subsidiary or group (but not a charity)

Its annual UK turnover exceeds £1 million, AND

It has a physical presence in the UK, AND

It is responsible for more than 25 tonnes of packaging and/or packaging materials in the previous calendar year

It carries out any of the packaging activities

EPR Exemptions and Thresholds

While EPR applies to many businesses, there are some exemptions and thresholds to be aware of:

  1. Turnover Threshold: Businesses with an annual UK turnover of £1 million or less are exempt from EPR obligations.
  2. Packaging Quantity Threshold: Businesses handling 25 tonnes or less of packaging per year are exempt from EPR obligations.
  3. Charities: The EPR regulations do not apply to charities. However, profit-making Ltd companies that are attached to charities are not exempt.
  4. Exports: Packaging that is exported from the UK is exempt from EPR reporting requirements. However, producers must maintain robust documentary evidence to support the exclusion of exported packaging from their data.
  5. Reused Packaging: Reused primary packaging is exempt from reporting requirements. Reused secondary and tertiary packaging is also exempt unless it was imported.

It's important to note that even if your business falls below the thresholds or fits into an exempt category, you may still have obligations to collect and report certain data, particularly if you're part of a larger group of companies or if you operate under specific business models (e.g., franchises or online marketplaces).

The table below shows when an organisation is obligated as a small producer, or a large producer, or not obligated at all.

Producer Thresholds Turnover
< £1m £1m-£2m > £2m
Packaging Tonnage

This is the aggregated total from ALL packaging activities, including selling, as defined by the regulations

 < 25 tonnes No obligation No obligation No obligation
25-50 tonnes No obligation Small producer Small producer
> 50 tonnes No obligation Small producer Large producer

Who is considered a packaging producer under EPR?

"Producer" is defined widely to include persons performing any one or more of the following functions in the UK:

Brand Owners - who package goods and sell them under their brand name. When a brand is not identifiable, the obligation falls to the organisation that carries out the packing or filling of the packaging.

Importers - who import filled packaging

Distributors - who manufacture or import empty packaging and sell that packaging to anyone who is not an obligated producer

Online marketplaces - who operate a marketplace whereby non-UK sellers can sell filled or empty packaging to UK consumers

Service providers - who hire out or lend reusable packaging

Sellers - who sell filled packaging to the end-consumer

EPR Timeline

The timeline for EPR implementation has been updated:

2023 - Packaging data should have started to be collected from 1st January. Large producers should have begun reporting their packaging data from October 2023.

2024 - Large producers should have submitted their 2023 data by 31st May. EPR fees have been deferred for 2023 data.

2025 - Large producers must begin RAM assessments and reporting for all household packaging placed on the market in 2025

2025 - Large producers will begin paying fees based on the packaging they placed on the market in 2024.

2026 - Mandatory labelling is introduced for packaging except for films and flexibles.

2027 - Films and flexibles to be collected by local authorities and be obligated under the labelling system.

What do you need to do to comply with EPR?

The key obligations under EPR UK are that producers must register their organisation, report packaging data, and ensure their products are collected and recycled or recovered properly.

There are increased reporting requirements for producers under the new EPR regulations. Organisations will now have to collect and provide detailed reporting on the packaging they produce and how the waste will be managed.

Large Organisations

To comply, your organisation needs to:

Record data about the empty packaging and packaged products handled and supplied within the UK

Create an account on the EPR packaging online service.

Submit data about empty packaging and packaged goods you handled or supplied throughout the UK market.

From 2025, based on your 2024 data, you may need to pay a waste management fee, scheme administrator costs, and a registration charge to the environmental regulator.

Large organisations need to submit data every 6 months:

  • Report data for 1 January to 30 June from 9 August 2024 (deadline to report 1 October 2024)
  • Report data for 1st July to 31 December from January 2025 (deadline to report 1 April 2025)

Small Organisations

To comply:

Record data about all the empty packaging and packaging items you handle and supply through the UK market as of 1st January 2023.

Register for the EPR packaging online service. (Registration opens in 2024 for small organisations)

Submit your data about the empty packaging and packaged products you handled or supplied through the UK market during 2024 by 1 April 2025.

What data do I need to collect for EPR?

You must collect data about the packaging you've supplied through the UK market or imported into the UK. Data must be recorded in kilograms. To prepare a submission to report your obligations, the following information is required:

Material: aluminium, steel, glass, wood, plastic, paper, cardboard, fibre-based composites, other.

Producer type: brand owner, importer, distributor, packer/filler, online marketplace owner

Level of packaging:

  • Primary packaging: packaging that contains the product for sale to the end user
  • Secondary packaging: packaging that groups multiple products for sale as a single item
  • Tertiary packaging: packaging used to transport goods and usually handled by businesses
  • Shipment packaging: packaging added to products for shipping directly to customers or collection points (typically disposed of as household waste)

Components: the individual components that make up the whole packaging and their weight. From 2025, this includes identifying which components must be assessed together under RAM because they cannot be easily separated by hand.

Household vs Non-household: You'll need to determine whether the packaging you supply is household or non-household.

Drinks containers: Data on single-use drinks containers needs to be reported separately.

Commonly binned items: Certain types of packaging need to be reported separately as they are considered "commonly binned" (in a public bin) items.

Reusable packaging: Data on reusable packaging needs to be collected and reported separately. Note that reusable packaging only needs to be reported on its first use.

Self-Collected Waste

Producers who collect and manage their own packaging waste (self-collected waste) will need to report this separately from 2026. This could include packaging waste collected directly from customers or through take-back schemes. There are two categories of self-collected waste:

  1. Self-managed consumer waste
  2. Self-managed organisation waste

Self-managed consumer waste

This category includes:

  • Recovered packaging waste that is not commonly collected by local authorities
  • Reusable packaging waste

If you're a large organisation, self-managed consumer waste you report may be used to offset packaging you've reported as household packaging. This can potentially reduce your waste management fee. To be eligible for offsetting:

  • The material you have collected must be the same packaging material as the household packaging you've reported.
  • You must have evidence that it has been recycled.

For example, if you have collected plastic carrier bags for recycling as part of a front-of-store take-back scheme, you can offset this against any plastic packaging you've reported in the household packaging category. However, if you have not reported any plastic packaging, there will be no offset applied.

Self-managed organisation waste

This category includes all packaging waste that you have collected yourself on-site, such as:

  • Your own branded packaging waste
  • Other brands' packaging waste
  • Packaging waste you've received from another organisation for 'backhauling'
  • Unbranded packaging waste
  • Packaging waste you've recovered from consumers that is commonly collected by local authorities

While this type of waste must be reported, it cannot be used to offset your EPR obligations.

For both categories of self-collected waste, you need to specify which nation the packaging was collected in and which it was sent to for recycling. This must be broken down by weight and material type.

By accurately reporting your self-collected waste, particularly self-managed consumer waste, you may be able to reduce your overall EPR obligations and associated fees.

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. From 2026, you must submit nation data if you:

  • 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 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

Unlike the main packaging data which is reported every 6 months, nation data is reported annually. You will need to submit your nation data for the 2024 calendar year by 1 December 2025.

Nation data should show where in the UK you've supplied packaging to a person or business who's gone on to discard it. This includes packaging that you've imported and then discarded.

EPR fees

The government has released illustrative base fees for household waste for the year 2025 to 2026. These fees are subject to change and are provided to help producers prepare for the financial implications of EPR. The fees are presented for each material type.

Here’s a breakdown of the illustrative base fees for 2025/26 for each packaging material in £ per tonne:

Material Rate
Aluminium £435
Fibre-based composites £455
Glass £240
Paper or board £215
Plastic £485
Steel £305
Wood £320
Other £280

Version 3 of the EPR Fees released by DEFRA on 20th December 2024

These fees are indicative and may change before implementation in 2025. The government will continue to refine these figures based on new data and updated cost estimates with the final fee figures being released after 1st April 2025.

It's important to note that these disposal fees apply only to household packaging waste. However, large producers have two separate financial obligations under the new EPR system:

  1. Disposal fees for household packaging waste (as shown in the table above)
  2. Recycling obligations for all packaging (both household and non-household) which must be met through the purchase of Packaging Recovery Notes (PRNs) or Packaging Export Recovery Notes (PERNs)

Starting in 2026, these disposal fees will be "modulated" based on the recyclability of the packaging, meaning fees may be increased, reduced, or left unchanged depending on how environmentally sustainable the packaging is.

In addition to these material-specific fees, producers will also be required to pay a scheme administrator fee. This fee will cover the costs of running the EPR scheme and will be in addition to the per-tonne rates for materials.

The exact amount of the scheme administrator fee has not yet been announced, but it will be an important consideration for producers when budgeting for their EPR obligations.

Recyclability Assessment Methodology (RAM)

The Recyclability Assessment Methodology (RAM) is a key component of EPR implementation starting from January 2025. Under RAM, large producers must evaluate and report on how recyclable their household packaging is, which directly impacts the fees they'll pay.

One of the most challenging aspects of RAM is that packaging components that cannot be easily separated by hand must be assessed together as a single unit. For example, a plastic bottle with a firmly adhered label would need to be assessed as one component, while a bottle with an easily removable sleeve would have each part assessed separately. This means producers need a sophisticated system to track both individual components and combined units through the assessment process.

To comply with RAM requirements, producers need to assess each packaging unit through five distinct stages:

Classification: First, packaging must be categorized into one of eight material types: paper and board, fibre-based composites, plastic (both flexibles and rigids), steel, aluminium, glass, wood, or other materials. For combined units, classification is based on the predominant material by weight.

Collection: Producers must determine whether their packaging is widely collected by local authorities (75% or more), has limited collection (50-75%), or requires take-back schemes.

Sortation: The assessment considers whether the packaging can be effectively sorted in materials facilities, taking into account factors like size, shape, and material detection. Combined units must pass sortation criteria as a whole.

Reprocessing: This stage evaluates whether the packaging can be effectively reprocessed using current UK infrastructure, considering factors like contamination and material composition. The presence of inseparable components can significantly impact reprocessing capability.

Application: The final stage assesses whether the recyclate produced can be effectively used in new products.
Based on these assessments, each packaging unit receives a red, amber, or green rating. These ratings will influence the modulation of EPR fees, with more recyclable packaging attracting lower fees.

The RAM assessment process requires detailed technical knowledge and careful documentation. Producers must maintain evidence supporting their assessments for at least 7 years, as these may be subject to regulatory audit. This includes documentation of how inseparable components were identified and assessed together.

Key Considerations for EPR Data Collection

To successfully collect all the data required for EPR calculations the following points should be kept in mind:

  1. Report Each Component Once: Each packaging component must only be reported once in its lifetime. This is crucial to avoid double-counting and ensure accurate reporting. For example, if you import a product in packaging and then add additional packaging before selling it, you would only report the packaging you added, not the imported packaging (unless you were responsible for the import).
  2. Detailed Record-Keeping: Maintain comprehensive records of all packaging data, including weights, materials, and supply chain information. These records should be kept for at least 7 years, as they may be subject to audit by environmental regulators.
  3. Material Classification: Ensure accurate classification of packaging materials, particularly for composite materials. Report the predominant material by weight for composite packaging that cannot be separated by hand.
  4. Component Separation Assessment: From 2025, you'll need to track which packaging components can be separated by hand and which must be assessed together under RAM. This affects both your recyclability assessment and potentially your fee calculations.
  5. Reusable Packaging: Remember that reusable packaging should only be reported the first time it's supplied. Keep track of which reusable packaging has already been reported to avoid duplicate reporting in subsequent years.
  6. Supply Chain Communication: Establish clear communication channels with your supply chain partners to ensure you have accurate information about the packaging of products you're importing or distributing.
  7. Regular Data Collection: Set up systems to collect packaging data regularly throughout the year, rather than trying to gather all the information at the end of the reporting period. This will make the reporting process smoother and reduce the risk of errors.
  8. Stay Informed About Changes: Keep up-to-date with any changes to EPR regulations, reporting requirements, or material classifications. The requirements may evolve over time, and it's important to adapt your data collection and reporting processes accordingly.
  9. Distinguish Between Household and Non-Household: Ensure you have a clear understanding of what constitutes household vs. non-household packaging in your supply chain, as this affects how it's reported and potentially the fees associated with it.
  10. Nation Data: If required to report nation data, set up systems to track where packaging is supplied and discarded across the UK nations.
  11. Self-Collected Waste: Accurately track and report self-collected waste, particularly self-managed consumer waste that may be used to offset EPR obligations.

By keeping these considerations in mind, you can ensure you're collecting all the necessary data for EPR calculations in a comprehensive and accurate manner.

Documentary Evidence: What To Keep And Why

Good record-keeping is a key part of staying compliant with EPR requirements. Environmental regulators may audit your submissions, so it’s important to keep clear, accurate documentation that supports your data.

Here are the main things to keep in mind:

  1. Record Retention: Keep all relevant documentation for at least 7 years. This includes records of packaging data, calculations, and any evidence supporting your classifications or exemptions.
  2. Types of Evidence: Collect and maintain various types of evidence, including:
    • Invoices and delivery notes for packaging materials and packaged goods
    • Product specifications and technical data sheets
    • Packaging weight calculations and measurement records
    • Proof of recycling for self-managed consumer waste
    • Records of reusable packaging to show it's only been reported once
    • Evidence supporting household vs. non-household classifications
    • RAM assessment documentation and supporting evidence for recyclability ratings
  3. Non-Household Packaging Evidence: If you've classified any primary or shipment packaging as non-household, you need robust evidence to support this. This could include:
    • Bespoke product specifications for business-only goods
    • Service contracts for products supplied as part of a service agreement
    • Customer confirmations that they are the end-user of the packaging
  4. Self-Collected Waste Evidence: For self-managed consumer waste that you want to use to offset your obligations, maintain clear records of:
    • The amount and type of waste collected
    • Where and when it was collected
    • Proof that it has been recycled
  5. Exports: If you're excluding any packaging from your data because it's exported, keep clear documentary evidence of the export.
  6. Data Collection Methodology: Document your methodology for collecting and calculating your packaging data. This is particularly important for online marketplace operators, who must submit their methodology to the relevant environmental regulator.
  7. Approved Person: Ensure all submitted data is verified by an approved person within your organization. Keep records of who this person is and their qualifications to fulfill this role.
  8. Audit Trail: Maintain a clear audit trail that shows how you arrived at your final reported figures. This should include any assumptions made or estimations used in your calculations.
  9. Regular Reviews: Conduct regular internal reviews of your documentary evidence to ensure it's complete, accurate, and up-to-date.
  10. Data Security: Ensure all documentary evidence is stored securely and in compliance with data protection regulations.

By maintaining comprehensive documentary evidence, you'll be well-prepared for any potential audits and can demonstrate your compliance with EPR regulations.

Making EPR Reporting Easier with PackTotal

Navigating the new EPR rules can feel complex and time-consuming. That’s why we built PackTotal — a UK-specific packaging data management system that runs on your own server and helps you stay on top of your Extended Producer Responsibility (EPR) and Plastic Packaging Tax (PPT) obligations.

How PackTotal Helps

  1. One place for everything: All your packaging data lives in a central database that supports detailed packaging hierarchies, including grouped components for RAM assessments. It’s designed to work smoothly across departments and handle large datasets with ease.
  2. Automatic calculations: Once your data is in, PackTotal handles the maths — calculating obligations based on materials, recycling rates, and current legislation. This reduces errors and saves hours of manual work.
  3. Built-in RAM tools: RAM assessments are integrated into the system. You can assess individual components or groups, store documentation, and maintain an audit trail — all without juggling spreadsheets or separate systems.
  4. Easy data entry and imports: The interface is straightforward and designed so multiple teams can enter data. You can also import from external systems, which cuts down on duplicate effort and improves accuracy.
  5. Error checks before you report: PackTotal highlights missing or unusual data before running calculations. It’s a small thing that makes a big difference when you're trying to avoid mistakes or resubmissions.
  6. Clear, custom reports: You can create EPR reports in the right format for submission — no extra formatting or manual tweaks required.
  7. Document Library: Store all the evidence you’ll need for audits or submission — supplier certificates, recyclability documents, and so on. Everything stays on your own server and is easy to access when you need it.
  8. Sustainability tracking: If your business has CSR or environmental goals, PackTotal can help you track sustainability metrics alongside your compliance data — giving you insight and visibility across your packaging decisions.
  9. Ready for what’s next: PackTotal is designed to scale as your needs grow. We keep it up to date with changes to UK regulations so you can be confident you’re always reporting against the current rules.

For senior teams, PackTotal offers more than just a smoother reporting process. It reduces the risk of non-compliance, supports internal accountability, and saves time across departments — freeing up resources for higher-value work. It’s a practical investment that helps teams stay ahead of evolving regulations while maintaining full control over their data.

Using PackTotal takes a lot of the heavy lifting out of EPR reporting. It helps you save time, reduce errors, and make more informed decisions about your packaging — all with your data stored securely, on your own infrastructure.

If you'd like to see how it works, get in touch to arrange a demo or ask us anything. We're always happy to help.

For full government guidance on EPR, visit the official GOV.UK site.

To discuss your requirements, request more information or arrange a free demo please contact us, we will be more than happy to help.

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