Packaging EPR · SI 2024/1332, as amended from 1 January 2026
EPR for packaging: producer tests, fees and PRNs
Extended producer responsibility for packaging, under SI 2024/1332, makes businesses that supply packaging pay for household packaging waste, on top of the recycling targets they already had to meet.
Whether it applies turns on two figures, turnover and tonnage, each measured in a different year and each read as “more than” in regulation 24.
Only one set of per-material fees is final — 2025/26 — and the next statutory date is 1 October 2026.
The scheme
Who pays for household packaging once it is thrown away
The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 came into force on 1 January 2025 and were amended by SI 2025/1369 from 1 January 2026.
The same instrument revoked the 2007 packaging waste regime on 1 January 2026 (Schedule 17, paragraph 2).
What changed is who pays for household packaging after use: PackUK describes the scheme as moving the full cost of dealing with household packaging waste away from taxpayers and onto producers.
PackUK’s launch notice of January 2025 calls it a Defra hosted function delivering on behalf of the four UK nations — not a company or arm’s-length body.
From 1 April 2026 UK Packaging PRO took on functions gradually, while PackUK keeps final decisions on producer fees and local authority payments.
PackUK’s 2026 to 2027 operational plan forecasts total fees of £1.558 billion for the year, and records that year 1 invoiced £1.46 billion against £1.523 billion required.
Three bodies run it
PackUK — the scheme administrator under reg 58: sets and collects disposal fees, pays local authorities.
The four environmental regulators — register producers and enforce reporting and recycling duties.
UK Packaging PRO — the producer responsibility organisation from 1 April 2026, with PackUK keeping fee decisions.
Who is a producer
Seven roles, and which pay what
| Class (reg 15(1)(b)) | Disposal fees if large? | Recycling obligations if large? | Reporting if large |
|---|---|---|---|
| Brand owner | Yes, if it supplied household packaging | Yes | Six-monthly |
| Packer/filler | Yes, if household | Yes | Six-monthly |
| Importer or first UK owner | Yes, if household | Yes | Six-monthly |
| Distributor | Yes, if household | Yes | Six-monthly |
| Online marketplace operator | Yes, if household | Yes | Six-monthly |
| Service provider | Yes, if household | Yes | Six-monthly |
| Seller | No — not in reg 60(1) | No — outside reg 25(2) | 12-monthly only |
Regulation 15(1) makes a person a producer if it is established in the UK, is one or more of the 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: under regulation 15(8), once a producer in classes one to six has supplied an item, nobody 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.
Where one business performs several functions all its packaging counts towards the tonnage test, but the same item only once (regulation 24(7)).
The tests
Two AND tests, measured in different years
Regulation 24(1): a large producer had turnover more than £2,000,000 in the last financial year that ended before 7 April in year Y-1 for which audited accounts are available, and in year Y-2 supplied in aggregate more than 50 tonnes of packaging.
Regulation 24(2): a small producer passes the same pair at more than £1,000,000 and more than 25 tonnes, and is not a large producer.
Both limbs within each tier are “and”: a £3 million business supplying 40 tonnes is small, not large, and a business at or under £1 million is outside both tiers whatever its tonnage.
“More than” excludes the line itself, so exactly £2,000,000 is not large.
GOV.UK’s who-is-affected guidance says “£1 million or more” and “£2 million or more”; the Regulations say “more than”, and where the two differ the Regulations govern.
The same guidance maps the years: for 2025 data, turnover from accounts up to 7 April 2025 and packaging supplied in the 2024 calendar year.
Accounts count as available once delivered to Companies House (regulation 24(5)(b)), so if the latest year is not yet filed, the earlier filed year is tested.
Tonnage is UK packaging to the nearest tonne, excluding exempt packaging (regulation 24(6)).
Producer tier · SI 2024/1332 reg 24
Your producer role (reg 15(1)(b))
Small producer — not large.
Turnover alone never makes a large producer: tonnage must also exceed 50 tonnes.
Register with your environmental regulator and pay the registration fee (reg 25(1)).
Report the previous calendar year’s data once a year, by 1 April (reg 36(2)).
No disposal fees and no PRNs: GOV.UK says a small producer does not pay waste disposal fees or buy PRNs.
Both limbs read “more than”: exactly £2,000,000 or exactly 50 tonnes is not enough.
Groups add the turnover and tonnage of members that supply packaging (Sch 9 ¶2).
Indicative only.
Nothing you enter is stored or sent.
Worked cases
Four businesses and a group
| Business | Turnover limb | Tonnage limb | Result |
|---|---|---|---|
| A: £3,000,000, 40 t | > £2m and > £1m | 40 t > 25 t, not > 50 t | Small producer |
| B: £2,400,000, 51 t | > £2m | 51 t > 50 t | Large producer |
| C: exactly £2,000,000, 60 t | Not > £2m; > £1m | > 50 t and > 25 t | Small producer |
| D: £950,000, 300 t | Not > £1m | Irrelevant | Outside both tiers |
Under Schedule 9, paragraph 2, group members’ turnovers and tonnages are added together, and where the totals pass a tier every relevant group member is in that tier.
Take subsidiary X (£1.5m, 30 t), subsidiary Y (£0.9m, 25 t) and a holding company with £4m of turnover that supplies no packaging.
GOV.UK says to leave out parts of the group that supply no packaging, so the totals are £2.4m and 55 t.
Both clear the large-producer lines, so X and Y are each large producers, although Y alone would be outside both tiers.
Duties
What each tier must do
| Duty | Large producer | Small producer |
|---|---|---|
| Register with the environmental regulator | Yes, each year | Yes |
| Report packaging data | Six-monthly: by 1 October (January–June) and 1 April (July–December); annual data by 1 April | Annually, by 1 April, for the previous calendar year (reg 36(2)) |
| Assess recyclability (RAM) | Yes, for household packaging, if a liable producer | No |
| Pay disposal and administration fees | Yes, if a liable producer (reg 60) | No |
| Recycling obligations (PRNs or PERNs) | Yes, in classes one to six | No |
Regulation 60(1), as substituted from 1 January 2026, makes a person a liable producer for an assessment year only if, in the calendar year before it started, it was in one of the first six classes, was a large producer and supplied household packaging.
For the 2026/27 assessment year, which began on 1 April 2026, that calendar year is 2025.
A large producer supplying only business-to-business packaging therefore pays no disposal fee but still carries recycling obligations.
Fees are paid in quarterly instalments or as the notice of liability specifies, and failing to pay within 50 days of the due date exposes a producer to civil sanctions (regulation 68).
A compliance scheme can register you, report for you and buy PRNs, but GOV.UK says it cannot pay your waste disposal fees.
Fees
What is final, and what is not
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, and were charged on 2024 data, with the first notices of liability issued in October 2025.
A 2025/26 fee on 60 tonnes of household plastic is 60 × £423 = £25,380; add 120 tonnes of paper and card (£23,520) and 15 tonnes of glass (£2,880) and the disposal fee is £51,780, before the administration fee.
Fees for 2026/27 have not been set: PackUK’s operational plan says it remains unable to calculate confirmed year 2 fees until all data is received and checked by the four regulators.
It intends to issue the initial notice of liability for 2026/27 by the end of November 2026.
The illustrative rates of December 2025 carried the warning that they were likely to change significantly, so budget with a range, not a rate.
Any page that says confirmed 2026/27 fees were due in June 2026 is out of date.
| Material | 2025/26 base fee, £/t |
|---|---|
| Aluminium | 266 |
| Fibre-based composite | 461 |
| Glass | 192 |
| Paper and card | 196 |
| Plastic | 423 |
| Steel | 259 |
| Wood | 280 |
| Other (bamboo, ceramic, cork…) | 259 |
Recyclability
Red, amber and green, from 2026/27
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; red pays it multiplied by the factors in PackUK’s modulated disposal fees statement; green pays less, by an amount that depends on the red and green mix actually reported.
The duty to modulate is in the Regulations (regulation 64); the factors sit in a policy statement that can change without amending the instrument.
The methodology has two live versions: PackUK’s RAM 2027 announcement 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, so applying it to 2026 data is wrong.
A design switch from red to green is worth testing against a life cycle assessment before it is made.
Recycling targets
PRNs and PERNs still apply
EPR did not end the 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.
The duty covers all its packaging, household and business-to-business, which is why a producer with no fee can still carry an obligation.
Schedule 5 sets the percentages to 2030: plastic rises from 55% in 2025 to 65% in 2030, glass from 74% to 85%, steel from 80% to 85%.
A producer that supplied 60 tonnes of plastic in 2025 has a 2026 obligation of 60 × 57% = 34.2 tonnes.
One that supplied 200 tonnes of glass must recycle 152 tonnes, of which 76% — 115.52 tonnes — by re-melt.
2026 is the only year the overall glass target and the re-melt target are the same number, and they measure different things.
Evidence counts only for the year the waste was received for recycling, except that December evidence can count for that year or the next (regulation 40(3)–(4)), and surplus evidence for one material cannot cover another.
Schedule 5 · obligation by material
2026 obligation: 34.2 t of plastic PRNs or PERNs (60 t × 57%).
Fee illustration at the final 2025/26 base fee: 60 t × £423 = £25,380 — not a 2026/27 figure.
Sources: SI 2024/1332 Sch 5 Tables 1–2 and reg 40; PackUK 2025/26 base fees.
Surplus evidence for one material cannot cover another.
December evidence may count for that year or the next (reg 40(4)).
Nothing you enter is stored or sent.
Deposit return
Drinks containers, and the 2028 backstop
The Deposit Return Scheme for England and Northern Ireland starts on 1 October 2027 under SI 2025/67, for drinks containers made wholly or mainly of PET, aluminium or steel from 150 ml to 3 litres.
Glass is not in it.
EPR already allows for the scheme: drink containers made of any material other than glass are left out of the disposal fees and the recyclability assessment (regulations 57(3) and 25(5)), subject to regulation 136.
So a brewer’s glass bottles pay the glass fee, and its cans do not — today, not only once the deposit scheme launches.
Regulation 136 is the backstop: if no relevant deposit scheme is running anywhere in the UK on 1 January 2028, the carve-outs fall away, and for fees from the assessment year beginning 1 April 2028.
All four nations sit on 1 October 2027, but glass differs by nation: Wales includes it, with a transitional period; the four-nation picture is on UK regimes by jurisdiction.
The full 2025 Regulations carry the deposit scheme’s machinery.
The other packaging regime
EPR and Plastic Packaging Tax
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.
It has a 10-tonne registration threshold, covers plastic only, and has no offset with EPR in either direction.
Both can land on the same tonne: if the 60 tonnes of plastic in the fee example were imported components under 30% recycled content, the 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 tax’s mass-balance rules for chemically recycled content are not in force until 1 April 2027.
The Plastic Packaging Tax page covers the tax in full.
For sustainability reporting, packaging appears twice: purchased packaging and its end-of-life sit in Scope 3 emissions, and a rising, modulated fee is a transition cost a climate disclosure under UK SRS S2 may need to address.
For the wider map, see ESG reporting requirements in the UK.
The next twelve months
A dated checklist, to October 2027
Every date beside this comes from the Regulations or from PackUK; where it is an intention rather than a statutory deadline, it says so.
Re-run both tier tests each spring on the newly filed accounts and the latest calendar-year tonnage, because growth past either large-producer line changes everything.
Split household and non-household packaging at item level, hold a RAM rating with supplier evidence for every household line, and buy PRNs through the year rather than in a December rush.
Reconcile the notice of liability to your own data within days of arrival.
For every regime’s dates together see the UK sustainability regulation timeline.
- 1 Oct 2026H1 2026 data, RAM 1.1
Large producers — reg 35(2)(a).
- End Nov 20262026/27 notices of liability
PackUK’s intention, not a statutory date.
- Dec 2026Buy the balance of 2026 PRNs
December evidence can count for 2026 or 2027.
- 1 Jan 2027RAM 2027 applies
To packaging supplied from today.
- 1 Apr 2027H2 2026 and annual data; small producers’ 2026 data
Red factor rises to 1.6 for 2027/28.
- 1 Oct 2027H1 2027 data; deposit scheme starts
- 1 Jan 2028Reg 136 backstop tested
By reader
What packaging EPR means for three kinds of business
| You are | What applies | What to do | By when |
|---|---|---|---|
| A large brand owner or retailer | Turnover above £2m and more than 50 tonnes: registration, six-monthly data, recyclability assessment of household packaging, disposal and administration fees, and recycling obligations met with PRNs or PERNs | Submit January–June 2026 data under RAM v1.1, budget for the 2026/27 notice without treating an illustrative rate as final, and buy 2026 PRNs material by material | Data by 1 October 2026 and 1 April 2027; the 2026/27 notice is expected by the end of November 2026 |
| A small producer | Turnover above £1m and more than 25 tonnes, but not over both large-producer lines: registration and annual data only, no disposal fees and no PRNs | Keep records through 2026, report the year once, and re-run both tests every year, because growth past either large-producer line changes everything | Annual data for 2026 by 1 April 2027 |
| A drinks producer | Glass drinks containers stay in EPR and carry disposal fees; PET, aluminium and steel containers of 150 ml to 3 litres sit outside the fees and the recyclability assessment because of the Deposit Return Scheme | Separate glass from other drink containers in your data, report glass as household packaging, and prepare the non-glass lines for the deposit scheme | Deposit Return Scheme from 1 October 2027; the reg 136 backstop is tested on 1 January 2028 |
Where packaging EPR stands
From the 2024 Regulations to the deposit scheme backstop
| Date | What happened or happens | Status |
|---|---|---|
| 1 January 2025 | SI 2024/1332 applies; first reports due by 1 April 2025 | Done |
| 21 January 2025 | PackUK launches as scheme administrator for the four nations | Done |
| October 2025 | First notices of liability: 2025/26 disposal fees on 2024 data | Done |
| 1 January 2026 | SI 2025/1369 amendments in force; the 2007 Regulations revoked | Done |
| 1 April 2026 | Year 2 begins with modulation; the UK Packaging PRO appointed | Done |
| 1 October 2026 | Large producers report January–June 2026 under RAM v1.1 | Due |
| End of November 2026 | 2026/27 notices of liability, PackUK’s stated intention, not a statutory date | Planned |
| 1 January 2027 | RAM 2027 applies to packaging supplied from this date | Planned |
| 1 April 2027 | H2 2026 and small producers’ annual data; year 3 begins | Due |
| 1 October 2027 | Deposit Return Scheme starts for PET, aluminium and steel drinks containers | Law |
| 1 January 2028 | If no deposit scheme is running, the drink container carve-out ends | Law |
Terms
Packaging EPR terms, with where each is defined
| Term | Where | Meaning |
|---|---|---|
| Producer | reg 15 | A UK-established business in one of seven classes, from brand owner to seller, acting in the course of business |
| Large producer | reg 24(1) | Turnover more than £2m AND more than 50 tonnes of packaging supplied, each measured in its own year |
| Small producer | reg 24(2) | Turnover more than £1m AND more than 25 tonnes, but not a large producer |
| Liable producer | reg 60 | A large producer in one of the first six classes that supplied household packaging in the previous calendar year; it pays the fees |
| Disposal fee | Part 5 | The per-tonne charge on household packaging, paid to PackUK to fund local authority waste costs |
| Notice of liability | reg 67 | PackUK’s notice of the disposal and administration fees a liable producer owes for an assessment year |
| PRN and PERN | reg 40 | Packaging waste recycling and export recycling notes: the only evidence a large producer can use for its recycling obligations |
| RAM | PackUK | The recyclability assessment methodology rating household packaging red, amber or green; v1.1 for 2026 data, RAM 2027 for 2027 |
| Modulation | reg 64 | Adjusting the disposal fee by rating: red above the base fee, amber at it, green below it |
Test yourself
Seven EPR claims, true or false
Most packaging EPR errors come from treating the two tests as either/or, reading an illustrative fee as final, or assuming one scheme replaced another.
Each answer names the regulation that settles it, and the full instrument is on legislation.gov.uk.
For a harder case you can put it to the member agent after creating a free account, or book a free 15-minute call.
EPR for packaging: true or false?
A business with £3 million turnover that supplied 40 tonnes is a large producer.
At exactly £2,000,000 turnover and 60 tonnes, a business is a large producer.
EPR for packaging replaced PRNs.
Confirmed 2026/27 disposal fees were published in June 2026.
A small producer supplying household packaging pays disposal fees.
Glass bottles leave packaging EPR when the Deposit Return Scheme starts.
A seller that is a large producer still has no disposal fee and no recycling obligation.
0 of 7 answered.
Nothing you choose is stored or sent.
Frequently asked
EPR for packaging, answered
What is EPR for packaging?
Extended producer responsibility for packaging is the UK scheme set up by SI 2024/1332 that makes businesses supplying packaging pay for household packaging waste and meet recycling targets.
It has applied since 1 January 2025 and was amended from 1 January 2026.
Producers above the thresholds register and report; large producers that supply household packaging also pay disposal fees to PackUK.
Who needs to comply with EPR for packaging?
A UK business in one of the seven producer roles — brand owner, packer/filler, importer or first UK owner, distributor, online marketplace operator, service provider or seller — that passes both tests for a tier.
Large: turnover more than £2 million and more than 50 tonnes supplied.
Small: more than £1 million and more than 25 tonnes.
The two figures come from different years.
What is a large producer under packaging EPR?
A producer with turnover of more than £2,000,000 in the last financial year ending before 7 April in the year before the obligation year, for which audited accounts are available, and that supplied more than 50 tonnes of packaging two years before the obligation year.
Both limbs must be passed.
What are the EPR packaging fees?
The only final per-material fees are for 2025/26, per tonne of household packaging: aluminium £266, fibre-based composite £461, glass £192, paper and card £196, plastic £423, steel £259, wood £280, other £259.
Fees for 2026/27 were not set as at 1 October 2026; PackUK intends to issue notices of liability by the end of November 2026.
Who pays EPR fees?
Only a liable producer: a large producer that, in the calendar year before the assessment year, was a brand owner, packer/filler, importer or first UK owner, distributor, online marketplace operator or service provider, and supplied household packaging.
Sellers, small producers and large producers of business-to-business packaging only do not pay disposal fees.
Do small producers pay EPR fees?
No disposal fees and no PRNs.
A small producer registers with its environmental regulator, pays a registration fee and reports its packaging data once a year by 1 April.
When is the next EPR packaging deadline?
1 October 2026, when large producers report January to June 2026 data assessed under RAM 1.1.
Then 1 April 2027 for large producers’ July to December 2026 data and annual data, and for small producers’ 2026 data.
Has EPR replaced PRNs?
No. Disposal fees and recycling obligations are separate liabilities under the same Regulations.
A large producer in one of the first six roles must still meet the Schedule 5 targets — 57% for plastic in 2026 — and can show it only with PRNs or PERNs.
Are drinks containers in EPR for packaging?
Glass drinks containers are in and pay disposal fees.
Single-use PET, aluminium and steel drink containers of 150 ml to 3 litres are already outside the disposal fees and the recyclability assessment, because they belong to the Deposit Return Scheme from 1 October 2027.
If no deposit scheme is running anywhere in the UK on 1 January 2028, they come back in.
Is EPR the same as Plastic Packaging Tax?
No. Plastic Packaging Tax is an HMRC tax of £228.82 a tonne on plastic components under 30% recycled plastic, with a 10-tonne threshold.
EPR covers every material under different thresholds.
Neither offsets the other.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
- legislation.gov.ukSI 2024/1332 — Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024
The scheme, in force from 1 January 2025 and amended by SI 2025/1369 from 1 January 2026.
- legislation.gov.ukSI 2024/1332, regulation 24 — large and small producers
More than £2m AND more than 50 t; more than £1m AND more than 25 t; turnover and tonnage years.
- legislation.gov.ukSI 2024/1332, regulation 15 — who is a producer
The seven classes, and the 2026 rules on resupply and new components.
- legislation.gov.ukSI 2024/1332, regulation 60 — liable producers
Disposal fees fall on large producers in classes one to six that supplied household packaging.
- legislation.gov.ukSI 2024/1332, regulation 35 — reporting by large producers
1 October and 1 April six-monthly deadlines; annual data by 1 April.
- legislation.gov.ukSI 2024/1332, Schedule 5 — recycling obligations
Material targets 2025–2030 and the glass re-melt table.
- legislation.gov.ukSI 2024/1332, Schedule 9 paragraph 2 — groups
Group members aggregate; every relevant member is caught.
- legislation.gov.ukSI 2024/1332, regulation 136 — the deposit-scheme backstop
The drink-container carve-outs fall away if no UK scheme runs by 1 January 2028.
- legislation.gov.ukSI 2025/67, regulation 1 — Deposit Return Scheme (England and Northern Ireland)
In force 1 October 2027; PET, aluminium and steel, 150 ml to 3 litres.
- Defra and Environment AgencyEPR for packaging: who is affected and what to do
The year mapping for turnover and tonnage; group totals leave out non-packaging members.
- DefraEPR for packaging: what you must do as a small producer
Small producers pay no disposal fees and buy no PRNs.
- PackUKEPR for packaging: 2025 base fees
The only final per-material fees: 2025/26, £ per tonne of household packaging.
- PackUKOperational plan 2026 to 2027 (10 August 2026)
2026/27 fees not yet calculable; notices of liability intended by the end of November 2026; £1.558bn forecast.
- PackUKModulated disposal fees statement
Red factors 1.2 (2026/27), 1.6 (2027/28), 2.0 (2028/29).
- PackUKPackUK publishes RAM 2027 (1 July 2026)
RAM 1.1 covers 2026 data; RAM 2027 covers 2027 and is not retrospective.