Extended Producer Responsibility (EPR) for Packaging in the UK Explained

Extended Producer Responsibility (EPR) is a policy approach aimed at reducing waste, increasing recycling, and encouraging sustainable product design to promote a more circular economy. It holds producers responsible for the entire life cycle of their products, including take-back, recycling, and disposal. As EPR legislation continues to emerge worldwide, existing legislation is also evolving to better align with the global shift toward a more circular economy, such as the new EPR for Packaging regulations in the United Kingdom (UK). These regulations will make producers significantly more responsible for the recovery and recycling costs of their packaging. 

Is EPR for Packaging replacing the Packaging Waste Regulations? 

EPR for Packaging is intended to replace the UK's existing Packaging Waste Regulations (PWR), introduced in 1997 as the first piece of producer responsibility legislation in the country. While PWR has been successful in achieving national recycling targets, a need was identified for a more robust scheme to help the UK manage the recovery and recycling of packaging.  

The proposal to introduce EPR for Packaging in the UK was published in 2022. Once adopted, the government opted to introduce the new regulations in a phased approach. All organizations within the scope were required to collect packaging data from January 1, 2023. Packaging fees for 2024 have been deferred until October 2025, when they will be expected to be paid in full. However, in-scope organizations still need to report packaging data for 2023. EPR for Packaging is expected to be fully implemented by 2027.  

What is EPR for Packaging in the UK?  

EPR for Packaging refers to a new set of EPR regulations in the UK. Currently, the UK’s Packaging Waste Recycling Notes (PRN) system operates under a model known as shared producer responsibility. This means that multiple organizations within the supply chain collectively share the financial responsibility for packaging recycling. However, the new EPR regulations will take after the model set by many European countries and make businesses individually responsible for managing their packaging waste. This will mandate businesses to financially support the lifecycle of their products, including end-of-life management, like that of batteries and electronics under the Waste Electrical and Electronic Equipment (WEEE) regulations.  

Ultimately, these updates aim to enhance recycling in the UK and incentivize producers to use recycled materials. Further shifting the costs of managing packaging waste from the taxpayer to the producers will have a stronger impact on incentivizing sustainable packaging materials and encourage producers to use more recycled content.  

Download our e-book “An Introduction to Extended Producer Responsibility” for an in-depth look into EPR and the general compliance process.  

Who is obligated to comply with EPR for Packaging in the UK?  

Organizations in the UK that import or supply packaging will fall within the scope of the new EPR for Packaging scheme. These organizations must collect and report their packaging data if they:  

• Operate an individual business, subsidiary, or group (charities are exempt) or carry out packaging activities 
• Accumulated a gross revenue of £ 1 million ($1,317,300) or more based on recent annual accounts up to April 7 of the previous year 
• Imported or supplied more than 25 tons of packaging to the UK market in the previous year 

Producers must adhere to the EPR for Packaging regulations if they:  

• Supply branded packaged goods to the UK market (these include the organization’s name, trademark, or any distinguishing mark) 
• Place goods into packaging 
• Import packaged goods 
• Own an online marketplace 
• Supply empty packaging 
• License another company to produce, pack, or import branded packaged goods 
• Place packaged goods on the UK market 

How do in-scope organizations comply with EPR for Packaging? 

To comply with the new EPR for Packaging regulations, in-scope organizations may need to: 

• Collect and report packaging data  
• Pay waste management fees 
• Pay scheme administrator fees 
• Pay the environmental regulator 
• Obtain packaging waste recycling notes (PRNs) or packaging waste export recycling notes (PERNs) 
• Report ‘nation data” (identifying which nation within the UK is supplied and which nation accrues the discarded packaging) 

These expectations are dependent on the organization’s size. Whether an organization is classified as ‘small’ or ‘large’ will be determined by annual turnover and the quantity of packaging supplied or imported annually.  

Small organizations are identified by: 

• Having an annual turnover between £1 million ($1,317,300) and £2 million ($2,634,680) and being responsible for supplying or importing more than 25 tons of packaging in the UK  
• Having an annual turnover of over £1 million ($1,317,300) and being responsible for supplying or importing between 25 tons and 50 tons of packaging in the UK    

The reporting deadline for small organizations to submit 2024 data is April 1, 2025. They must also collect packaging data for 2023 but are not required to report it.  

Large organizations are identified by meeting both of the following: 

• Having an annual gross revenue of more than $2 million  
• Supplying or importing more than 50 tons of packaging into the UK 

Large organizations operating in England, Scotland, and Northern Ireland must submit their packaging data by: 

• October 1, 2024, for data from January to June of 2024 
• April 1, 2025, for data from July to December of 2024 

In Wales, data from both large and small organizations must be submitted by April 1, 2024, for data from July to December of 2023.  

Organizations must contact the environmental regulator if they are unable to meet their reporting deadlines.  

Streamline EPR for Packaging compliance with Source Intelligence 

Complying with EPR for Packaging will introduce organizations to new challenges within their supply chains, such as understanding their reporting obligations and collecting quality data from suppliers. Source Intelligence can help you streamline this process through our powerful EPR platform. Our software enables you to automate supplier data collation, build and publish scheme reports, and much more, reducing your internal resource burdens and business risk. Explore our EPR program to learn more about how we can help support your EPR compliance goals.