EPR for packaging: extended producer responsibility explained

Packaging EPR is set up by the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (SI 2024/1332), which came into force on 1 January 2025 and were amended by SI 2025/1369 with effect from 1 January 2026. The same instrument revoked the old packaging waste regime, the 2007 Regulations, on 1 January 2026 (Schedule 17, paragraph 2).

What changed is who pays for household packaging once it is thrown away. PackUK describes the scheme as moving “the full cost of dealing with household packaging waste away from taxpayers and onto the packaging producers themselves” (PackUK, About us). Its 2026/27 operational plan forecasts total fee recovery of about £1.558 billion.

Three bodies run it. PackUK is the scheme administrator appointed under regulation 58; GOV.UK's launch notice of January 2025calls it “a Defra hosted function, delivering on behalf of the four UK nations”. It sets and collects disposal fees and pays local authorities. The four environmental regulators register producers and enforce reporting and recycling duties. And from 1 April 2026 UK Packaging PRO is the producer responsibility organisation, taking on functions gradually while PackUK keeps oversight.

Regulation 15(1)makes a person a producer if it is established in the UK, is one or more of seven classes, and performs that class's function in the UK in the course of business.

Two rules added on 1 January 2026 stop double counting along the chain. Under regulation 15(8), once a producer in classes one to six has supplied an item, no one else except a seller becomes its producer by supplying it again; under regulation 15(9), a new component, such as a new label, is assessed on its own. And where one business performs several functions, all its packaging counts towards the tonnage test, but the same item only once (reg 24(7)).

Each tier is an AND test, set in regulation 24. For a relevant year Y, a large producer had turnover “more than £2,000,000 in the last financial year that ended before 7th April in year Y-1 in respect of which audited accounts are available” and “in year Y-2… supplied in aggregate more than 50 tonnes of packaging”. A small producer passes the same pair at £1,000,000 and 25 tonnes and is not a large producer. Tonnage is UK packaging to the nearest tonne, excluding exempt packaging.

Four worked cases, each using the GOV.UK mapping for 2025 data: turnover from the last audited financial year ending before 7 April 2025, and packaging supplied in 2024.

Case A is the one most summaries get wrong: high turnover alone never makes a large producer. Accounts count as available once delivered to Companies House (reg 24(5)(b)), so if the latest year is not yet filed, the earlier filed year is tested.

Registration, record keeping and reporting apply to both tiers (reg 25(1)). The money, and the recycling evidence, fall only on large producers, and even then not on all of them.

The deadlines are in regulation 35for large producers and regulation 36 for small ones. A large producer that is only a seller reports once a year. GOV.UK's small producer guidanceis plain: “you do not have to pay waste disposal fees or buy packaging waste recycling notes”. A small producer still pays a registration fee.

Fees are paid in quarterly instalments or as the notice of liability specifies, and failing to pay 50 days after the due date exposes a producer to civil sanctions (reg 68). A compliance scheme can register you, report for you and buy PRNs, but GOV.UK says it “cannot pay your waste disposal fees”.

Only one set of per-material fees is final: the 2025/26 base fees, published by PackUK and updated on 30 June 2025. They are charged per tonne of household packaging; the tonnage they are spread over also includes packaging reported as commonly disposed of in public bins or littered.

The base fees documentdivides local authority household packaging costs, net of material income, plus PackUK's costs, by household tonnage placed on the market, material by material. The published rates are rounded to the nearest pound; invoices use rates to four decimal places.

The 2025/26 fees were charged on 2024 data: GOV.UK told large producers that from 2025 they may need to pay a waste disposal fee “based on your 2024 data”, and PackUK issued the first notices of liability in October 2025.

From 2026/27 the disposal fee is modulated by recyclability. Household packaging is rated red, amber or green under the recyclability assessment methodology (RAM); amber pays the base fee and red pays it multiplied by the factors in PackUK's modulated disposal fees statement (updated 17 February 2026). For the first three years the extra money raised on red funds a lower fee for green.

The duty to modulate is in the Regulations (reg 64); the factors are in a policy statement that can change without amending the instrument. The methodology itself comes in two versions, and using the wrong one is an easy error. PackUK's RAM 2027 announcementof 1 July 2026 says RAM 1.1 covers the 2026 reporting year, with deadlines of 1 October 2026 and 1 April 2027, and RAM 2027 covers packaging supplied in 2027. RAM 2027 is not retrospective. Packaging-design choices also shift a product's footprint, so a switch from red to green is worth testing against a life cycle assessment before it is made.

EPR did not end the old evidence market. Under regulations 25(2) and 40, a large producer in classes one to six must recycle a share of the packaging it supplied in the previous year, material by material, and “may only demonstrate compliance… through the acquisition of PRNs or PERNs or both”. This applies to all its packaging, household and business-to-business alike, which is why a producer with no fee can still carry an obligation.

The rates come from Schedule 5. A producer that supplied 60 tonnes of plastic in 2025 has a 2026 obligation of 60 × 57% = 34.2 tonnes of plastic PRNs or PERNs. One that supplied 200 tonnes of glass must recycle 200 × 76% = 152 tonnes, of which 76% again, 115.52 tonnes, must be by re-melt.

Two timing rules catch people out. Evidence counts only for the year the waste was received for recycling, except that December evidence can be used for that year or the next (reg 40(3)–(4)). And, as GOV.UK puts it, you cannot use excess PRNs or PERNs for one material to cover another.

The Deposit Return Scheme for England and Northern Ireland starts on 1 October 2027 under SI 2025/67, covering drinks containers made wholly or mainly of PET, aluminium or steel from 150 ml to 3 litres. Glass is not in it.

Packaging EPR already allows for this. The Regulations define a drink container as a single-use bottle or can of PET, glass, steel or aluminium between 150 ml and three litres, and leave those “made of any material other than glass” out of the disposal fees and the recyclability assessment (regs 57(3) and 25(5)). So a brewer's glass bottles pay the glass fee, and its cans do not.

The carve-out has a backstop. Under regulation 136, if no deposit scheme is in operation anywhere in the UK on 1 January 2028, the exclusions fall away, and for fees from the assessment year beginning 1 April 2028. Wales runs its own scheme with glass included; our guide to how the four nations differ sets the regimes side by side.

Plastic Packaging Tax is an HMRC tax under the Finance Act 2021, charged at £228.82 per tonne from 1 April 2026 on plastic packaging components with less than 30% recycled plastic. There is no offset between it and packaging EPR in either direction.

Both can land on the same tonne. If the business in the fee example had also imported its 60 tonnes of plastic as components with under 30% recycled plastic, Plastic Packaging Tax would add 60 × £228.82 = £13,729.20, on top of the £25,380 disposal fee and the 34.2 tonnes of PRNs. The mass-balance rules for chemically recycled content are not in force until 1 April 2027. Our Plastic Packaging Tax guide covers the tax in full.

For sustainability reporting, packaging shows up twice. Purchased packaging and its end-of-life treatment sit in Scope 3 emissions, and a rising, modulated fee is a transition cost that a climate disclosure under UK SRS S2 may need to address. For the wider map of what applies to UK companies, see ESG reporting requirements in the UK.

Every date below comes from the Regulations or from PackUK. Where a date is an intention, not a statutory deadline, the table says so.

Most packaging EPR errors come from treating the two tests as either/or, from reading an illustrative fee as final, or from assuming one scheme replaced another. Test yourself on the six statements below.

The same Regulations land differently on a supermarket brand, a mid-sized importer and a brewer. Pick the description that fits; each tab says what applies, what to do and by when.

The timeline marks what has passed and what comes next as of the day you read it. For every regime's dates together, see the UK sustainability regulation timeline.

Producerreg 15

A UK-established business in one of seven classes, from brand owner to seller, performing its function in the course of business.

Large producerreg 24(1)

Turnover more than £2 million AND more than 50 tonnes of packaging supplied, each measured in its own year.

Small producerreg 24(2)

Turnover more than £1 million AND more than 25 tonnes supplied, but not a large producer.

Liable producerreg 60

A large producer in one of the first six classes that supplied household packaging in the calendar year before the assessment year; it pays the fees.

Disposal feePart 5

The per-tonne charge on household packaging, paid to PackUK to fund local authority waste costs.

Notice of liabilityreg 67

PackUK’s notice stating the disposal and administration fees a liable producer owes for an assessment year.

PRN and PERNreg 40

Packaging waste recycling note and export recycling note: the only evidence a large producer can use to meet its recycling obligations.

RAMPackUK

Recyclability assessment methodology: rates household packaging red, amber or green. RAM v1.1 covers 2026 data; RAM 2027 covers 2027.

Modulationreg 64

Adjusting the disposal fee by recyclability rating: red above the base fee, amber at it, green below it.