Large producer
More than £2,000,000 turnover and more than 50 tonnes: register, report six-monthly, pay fees on household packaging, buy PRNs.
reg 24(1)Packaging EPR · Requirements
Packaging EPR reporting requirements in the UK: register, report, pay
The packaging EPR reporting requirements in the UK fall on producers with more than £1 million turnover and more than 25 tonnes of packaging: they register, collect data and report it through the Report packaging data service, and the large ones pay disposal fees.
They are set by SI 2024/1332, amended from 1 January 2026, and the next reporting date is 1 April 2027.
Before the detail
Packaging EPR reporting requirements, in brief
Extended producer responsibility for packaging, or pEPR, makes the businesses that place packaging on the UK market report what they supply and, if large, pay for household packaging waste and buy recycling evidence.
It replaced the 2007 packaging regulations, which were revoked on 1 January 2026, and it applies across all four UK nations.
Data goes to the environmental regulator for the producer’s nation through Defra’s Report packaging data service, known as RPD.
Fees go to PackUK, the scheme administrator, which is a Defra-hosted function acting for all four governments.
The scheme itself is explained on our packaging EPR guide; this page sorts the law by what each producer must do, and sits in the UK reporting requirements series.
In one table
The packaging EPR reporting requirements, one line each
Every producer duty, who owes it, when, and the regulation.
“Large” and “small” are the regulation 24 tiers.
| Requirement | Who | When | Provision |
|---|---|---|---|
| Apply the turnover and tonnage tests | Every business that supplies or imports packaging | Each year | reg 24 |
| Register with the environmental regulator | Large producers other than sellers | By 1 Oct in the preceding year | reg 28(1)(b)(i) |
| Register with the environmental regulator | Small producers; sellers only | By 1 Apr in the year | reg 28(1)(b)(ii) |
| Collect the Schedule 4 data for your class | Large and small producers | Continuously | reg 34(1) |
| Report six-monthly data | Large producers other than sellers | By 1 Oct (Jan–Jun); by 1 Apr (Jul–Dec) | reg 35(2) |
| Report twelve-monthly data, including nation data | Large producers in the relevant classes | By 1 Apr | reg 35(3) |
| Report annual data | Small producers | By 1 Apr | reg 36(2) |
| Assess recyclability and report results | Liable producers | With the data | regs 25(3), 37 |
| Pay disposal and administration fees | Large producers that supplied household packaging, not sellers | Quarterly instalments, per notice | regs 60, 68 |
| Meet recycling obligations with PRNs or PERNs | Large producers other than sellers | Each compliance year | reg 25(2); Sch 5 |
| Keep records and evidence | Large and small producers | At least 7 years | reg 34(2) |
Who is in scope
Large or small: two limbs, both required
Regulation 24 sets two tiers, and both limbs are “and” tests within each tier.
A large producer has turnover of more than £2,000,000 and supplied more than 50 tonnes of packaging.
A small producer has turnover of more than £1,000,000 and supplied more than 25 tonnes, but is not a large producer.
So a business with £3 million turnover that supplied 40 tonnes is small, and a business under £1 million turnover is out whatever its tonnage.
Turnover comes from the last financial year ending before 7 April in the year before the obligation year for which audited accounts are available, and tonnage from two years before the obligation year.
Group members that supply packaging aggregate their turnover and tonnage, and if the totals meet a tier every relevant member is in it, under Schedule 9.
GOV.UK’s “who is affected” guidance says “£1 million or more” in places, but the regulation says “more than”, and the regulation governs.
Charities are exempt from the producer obligations.
Turnover and tonnage, each tested on its own year
Small producer
More than £1,000,000 turnover and more than 25 tonnes, but not large: register and report once a year.
reg 24(2)Outside both tiers
£1,000,000 or less turnover, or 25 tonnes or less: no pEPR registration or reporting.
Defra guidanceProducer types
Seven producer types, seven reporting profiles
Regulation 15 names seven classes, and the Schedule 4 data a producer reports depends on its class and tier.
Paragraph numbers are those of Schedule 4.
| Class | Who it is | Large: six-monthly | Large: twelve-monthly | Small: annual |
|---|---|---|---|---|
| Brand owner | Supplies packaged goods under its own brand | 2, 3, 5, 6, 7, 9, 10, 12, 13 | — | 2, 5, 7 |
| Packer/filler | Places goods into packaging | 2, 3, 5, 6, 7, 9, 10, 12, 13 | — | 2, 5, 7 |
| Importer or first UK owner | Imports packaged goods | 2, 3, 5, 6, 7, 9, 10, 12, 13 | 11 | 2, 5, 7, 11 |
| Distributor | Supplies empty packaging | 2, 3, 5, 6, 7, 9, 10, 12, 13 | 11 | 2, 5, 7, 11 |
| Online marketplace operator | Lets non-UK sellers supply UK customers | 2, 3, 12, 13 | 4, 11 | 2, 3, 4, 11 |
| Service provider | Hires or loans out reusable packaging | 2, 3, 5, 6, 7, 9, 10, 12, 13 | 11 | 2, 5, 7, 11 |
| Seller | Supplies packaged goods to the end user | — | 11, 13 | 11 |
A business can be more than one class at once, and all its packaging counts, but the same item of packaging is counted only once.
Since 1 January 2026, resupplying packaging does not create a new producer, except a seller, under regulation 15(8).
What is reported
The Schedule 4 data, item by item
Every weight is the actual, measured weight in kilograms to the nearest kilogram, under paragraph 1 of Schedule 4.
Exempt packaging is left out, and household packaging can only be excluded where the producer can evidence the conditions for doing so.
The household split matters most, because household packaging is what disposal fees are charged on.
Nation data, item 11, records where packaging is supplied or discarded in England, Scotland, Wales and Northern Ireland, and some sellers and importers may estimate it for 2025 to 2027.
Liable producers also assess the recyclability of their household packaging and report the results, using RAM 1.1 for 2026 data and RAM 2027 for 2027 data, according to PackUK.
Distributors of empty packaging record the large producers they supply, so that obligations follow the packaging down the chain.
| Para | Data |
|---|---|
| 2 | Weight of packaging supplied, by material |
| 3 | Weight of household packaging, by material |
| 4 | Methodology used to collate items 2 and 3 |
| 5 | Breakdown by packaging type: primary, secondary, tertiary, shipment |
| 6 | Household primary and shipment packaging |
| 7 | Drinks containers, by weight and units |
| 8 | Unfilled packaging supplied to each large producer |
| 9 | Reusable or refillable packaging and the reuse system |
| 10 | Commonly binned or littered household items |
| 11 | Nation data: supplied or discarded in each UK nation |
| 12 | Packaging waste collected and recycled, including closed loop |
| 13 | Packaging waste collected, by nation of collection |
| 14 | Plastic and paper bags supplied in England |
When
Registration and reporting dates through RPD
Large producers report six-monthly data by 1 October, for January to June of that year, and by 1 April, for July to December of the previous year, under regulation 35.
Their twelve-monthly data, such as nation data, is due by 1 April for the previous calendar year.
Small producers report once a year, by 1 April, for the previous calendar year, under regulation 36.
A large producer that is not only a seller applies to register by 1 October in the year before, so registration for 2027 was due on 1 October 2026, under regulation 28.
Small producers, and large producers that are only sellers, apply by 1 April in the registration year.
A business that becomes a producer, merges or acquires a brand after those dates has 28 days.
Everything is done in RPD, which is also where large producers check their recycling obligations, accept PRNs and see their disposal fee.
The other dated UK duties are collected on the UK sustainability regulation timeline.
- 1
Collect data from 1 January
Record the Schedule 4 items for your class as packaging is supplied.
- 2
1 April: report H2 and annual data
July–December of the previous year, plus twelve-monthly items such as nation data.
- 3
1 October: report H1 data
January–June of the current year, and register for the next year.
- 4
Pay per the notice of liability
Usually quarterly instalments across the April–March assessment year.
- 5
Hold PRNs or PERNs
Evidence of recycling against the Schedule 5 targets, accepted in RPD.
Fees and modulation
Who pays, how much, and when modulation starts
Disposal fees are paid by liable producers under regulation 60: large producers that supplied household packaging in the previous calendar year in any class except seller.
A large producer supplying only non-household packaging, a seller, or any small producer pays no disposal fee.
The fee year, or assessment year, runs from 1 April to 31 March, and fees are usually paid in quarterly instalments set out in PackUK’s notice of liability.
The only final per-tonne fees are the 2025/26 base fees, for example £423 for plastic, £196 for paper and card and £192 for glass.
The 2026/27 fees were not confirmed on 11 October 2026: PackUK’s operational plan says it intends to issue notices of liability for that year by the end of November 2026.
Corrections to 2025 data made after 1 September 2026 do not change a producer’s 2026/27 fees.
Modulation by recyclability applies from 2026/27, with a red-rated factor of 1.2, rising to 1.6 in 2027/28 and 2.0 in 2028/29, under PackUK’s modulation statement.
The duty to modulate is in the regulations, but the factors sit in the statement and could change without an amending instrument.
Every registered producer also pays an annual registration charge to its regulator, set in Schedule 1 as amended by SI 2025/1369, with inflation increases from 2027.
Recycling obligations
PRNs and PERNs, on top of the fees
Disposal fees did not replace the old recycling evidence system: large producers other than sellers must also meet recycling obligations, under regulation 25(2).
They do so only by acquiring packaging waste recycling notes from accredited reprocessors, or export notes from accredited exporters.
The obligation is last year’s tonnage in each material multiplied by this year’s target in Schedule 5.
Evidence for one material cannot be used for another, and a December note can count for that year or the next.
Small producers have no recycling obligation, the GOV.UK small producer guidance confirms.
| Material | 2026 target | 2027 target |
|---|---|---|
| Plastic | 57% | 59% |
| Wood | 46% | 47% |
| Aluminium | 62% | 63% |
| Steel | 81% | 82% |
| Paper, board, fibre-based composite | 77% | 79% |
| Glass | 76% | 78% |
| Glass by re-melt | 76% | 77% |
Records
Records: seven years
A producer keeps the data it must collect, and the evidence for any household packaging it excludes, for at least seven years after the end of the reporting period, under regulation 34(2).
Large producers keep evidence of packaging waste they collected and had recycled, including closed-loop food-grade plastic, for seven years after the activity.
Liable producers keep their recyclability assessment records for seven years after each is made.
A compliance scheme can carry out reporting and recycling duties for its members, but it cannot pay disposal fees, which stay with the producer.
Enforcement
Penalties for missing a pEPR requirement
| Failure | Consequence | Provision |
|---|---|---|
| Operating as a producer without registration, or applying late | Offence | reg 115(1)(a)–(b) |
| Failing to keep records | Offence | reg 115(1)(c) |
| Failing to report, or reporting after the deadline | Offence | reg 115(1)(d)–(e) |
| Failing to meet recycling obligations or certify compliance | Offence | reg 115(3) |
| Any producer offence | A fine on conviction; unlimited on summary conviction in England and Wales | reg 119 |
| Civil sanction instead of prosecution | £1,000 fixed monetary penalty, variable monetary penalty, compliance notice or enforcement undertaking | reg 121; Sch 13 |
| Not paying fees within 50 days of the due date | Contravention attracting civil sanctions; unpaid fees recoverable as a debt with interest | reg 68(3)–(4) |
Regulators publish enforcement action under regulation 126, and the producers who registered are listed on a public register.
PackUK can recalculate a notice of liability up to four years after the assessment year, or ten where it lacked information because a producer did not submit it.
A separate return
Plastic packaging tax: a different regime, a different return
Plastic packaging tax is an HMRC tax under the Finance Act 2021, not part of pEPR, and the same tonne of plastic can bear both.
It is charged at £228.82 per tonne from 1 April 2026, under section 45, on finished plastic packaging components with less than 30% recycled plastic.
Registration is triggered at 10 tonnes of finished plastic packaging components made in or imported into the UK, over the previous 12 months or the next 30 days.
Returns are quarterly, due with payment by the last working day of the month after each quarter, with weights in kilograms, according to HMRC.
From 1 April 2027, under Finance Act 2026 section 107, pre-consumer plastic stops counting as recycled plastic and chemically recycled content can count through mass balance.
The full rules are on our plastic packaging tax page, and the border tax on steel, aluminium and other imports is a third regime again, on the CBAM reporting requirements page.
Myths and changes
What pEPR does not require, and what is changing
pEPR is not a disclosure in the annual report; its data goes to regulators, though some companies cite it in their ESG disclosures.
Small producers pay no disposal fees and buy no PRNs.
Sellers report twelve-monthly only, mainly nation data, and pay no disposal fee and buy no PRNs.
PET, steel and aluminium drinks containers of 150 ml to 3 litres are already outside pEPR disposal fees, ahead of the deposit return scheme that starts on 1 October 2027 under SI 2025/67.
If no UK deposit scheme is running by 1 January 2028, regulation 136 brings those containers back into pEPR fees from the 2028/29 year.
How the four nations’ rules line up is set out on the regimes by jurisdiction page.
Statements still circulating that are out of date
“Confirmed 2026/27 fees in June 2026” — not published; PackUK now targets the end of November 2026.
“pEPR replaced PRNs” — large producers still buy PRNs or PERNs.
“The 2007 packaging regulations still apply” — revoked on 1 January 2026.
“Apply RAM 2027 to 2026 data” — RAM 2027 is not retrospective.
Check yourself
Six statements about pEPR requirements
Each answer names the provision it turns on.
The scheme’s design, from PackUK to the deposit return seam, is on the extended producer responsibility page.
The other UK regimes with dated filings are gathered on the sustainability reporting requirements hub.
True or false?
A business with £3m turnover supplying 40 tonnes of packaging is a large producer.
Small producers report once a year, by 1 April.
A large producer supplying only business-to-business packaging pays disposal fees.
Confirmed 2026/27 disposal fees were published in June 2026.
Packaging data must be kept for seven years.
Paying plastic packaging tax reduces a producer’s pEPR fees.
0 of 6 answered.
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Frequently asked
Packaging EPR reporting requirements, answered
What are the packaging EPR reporting requirements in the UK?
A producer that meets the small or large producer test must register with the environmental regulator, collect packaging data under Schedule 4 to SI 2024/1332, and report it through the Report packaging data service.
Large producers report six-monthly by 1 October and 1 April and pay disposal fees if they supplied household packaging; small producers report once a year by 1 April.
Both keep records for seven years.
Am I a large or small producer under packaging EPR?
Large: turnover of more than £2,000,000 and more than 50 tonnes of packaging supplied.
Small: turnover of more than £1,000,000 and more than 25 tonnes, but not large.
Both limbs must be met in each tier.
Turnover is from the last financial year ending before 7 April in the year before the obligation year with accounts available, and tonnage is from two years before.
Is the pEPR turnover test “more than” or “£1 million or more”?
Regulation 24 of SI 2024/1332 says “more than £1,000,000” and “more than £2,000,000”.
Some GOV.UK guidance says “or more”, but the statutory instrument governs, and the difference only matters at exactly £1m or £2m.
What are the seven producer types under pEPR?
Brand owner, packer/filler, importer or first UK owner, distributor, online marketplace operator, service provider and seller, under regulation 15.
A business can be more of one at once, and each item of packaging is counted only once.
Which data a producer reports depends on its class and its size.
When is packaging EPR data due?
Large producers report six-monthly data by 1 October (for January to June of that year) and by 1 April (for July to December of the previous year), plus twelve-monthly data by 1 April.
Small producers report once, by 1 April, for the previous calendar year.
The next deadline is 1 April 2027 for 2026 data.
When must a producer register for pEPR?
A large producer that is not only a seller applies by 1 October in the year before the registration year, so 1 October 2026 for 2027.
A small producer, or a large producer that is only a seller, applies by 1 April in the registration year.
A business that becomes a producer later has 28 days.
What data do I report under packaging EPR?
The descriptions in Schedule 4 to SI 2024/1332 that apply to your class and size: weights by material, household packaging, packaging type (primary, secondary, tertiary, shipment), drinks containers, reusable packaging, commonly binned or littered items, nation data, and packaging waste collected.
Weights are in kilograms to the nearest kilogram.
Who pays pEPR disposal fees?
Liable producers under regulation 60: large producers that supplied household packaging in the previous calendar year as a brand owner, packer/filler, importer, distributor, online marketplace operator or service provider.
Small producers, sellers and producers supplying only non-household packaging pay no disposal fee.
Every registered producer pays a registration charge.
Have the 2026/27 pEPR fees been confirmed?
Not as at 11 October 2026.
PackUK’s operational plan says it cannot calculate confirmed year 2 disposal fees until producer data has been checked by the four regulators, and intends to issue notices of liability for 2026/27 by the end of November 2026.
The December 2025 figures were illustrative only.
When does fee modulation start?
Modulation of household packaging disposal fees by recyclability applies from the 2026/27 fee year, with a red-rated modulation factor of 1.2, rising to 1.6 in 2027/28 and 2.0 in 2028/29 under PackUK’s modulation statement.
The factors sit in a policy statement, not the regulations.
Which recyclability methodology applies to my data?
RAM 1.1 applies to packaging supplied in 2025 and 2026, including the 1 October 2026 and 1 April 2027 submissions.
RAM 2027 applies to packaging supplied in 2027 and is not retrospective, according to PackUK.
Do small producers need PRNs?
No. Recycling obligations, discharged by acquiring packaging waste recycling notes (PRNs) or export notes (PERNs), apply to large producers other than sellers under regulation 25(2).
Small producers report data and pay a registration charge, but buy no PRNs and pay no disposal fees.
How long must pEPR records be kept?
At least seven years after the end of the reporting period to which the data relate, under regulation 34(2) of SI 2024/1332, together with any evidence needed to support household packaging exclusions.
What are the penalties for pEPR non-compliance?
Failing to register, keep records, report or report on time is an offence under regulation 115, punishable by a fine.
Regulators may instead use civil sanctions under Schedule 13: a £1,000 fixed monetary penalty, variable monetary penalties, compliance notices or enforcement undertakings.
Late payment of fees is also a contravention.
Is plastic packaging tax part of packaging EPR?
No. Plastic packaging tax is a separate HMRC tax under the Finance Act 2021, at £228.82 per tonne from 1 April 2026 on plastic packaging components with less than 30% recycled plastic.
It has its own 10-tonne threshold and quarterly returns, and neither regime offsets the other.
Does the deposit return scheme change pEPR reporting?
For drinks containers, yes.
PET, steel and aluminium drinks containers of 150 ml to 3 litres are already outside pEPR disposal fees, and the deposit return scheme for them starts on 1 October 2027.
Glass drinks containers stay in pEPR in England and Northern Ireland.
If no UK scheme is running by 1 January 2028, regulation 136 brings the exclusions back in.
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.
Checked against 24 sources fromlegislation.gov.ukDefra and Environment AgencyDefraPackUKPackUK / DefraHMRC
- legislation.gov.ukThe Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (SI 2024/1332)
pEPR itself, as amended from 1 January 2026 by SI 2025/1369.
- legislation.gov.ukSI 2024/1332, regulation 24 — large and small producer thresholds
More than £2m and more than 50 tonnes; more than £1m and more than 25 tonnes.
- legislation.gov.ukSI 2024/1332, regulation 28 — application for producer registration
Large producers by 1 October of the preceding year; small producers and sellers by 1 April.
- legislation.gov.ukSI 2024/1332, regulation 34 — record keeping
The data each class collects, and seven years’ retention.
- legislation.gov.ukSI 2024/1332, regulation 35 — reporting: large producers
Six-monthly by 1 October and 1 April; twelve-monthly by 1 April.
- legislation.gov.ukSI 2024/1332, regulation 36 — reporting: small producers
Annually by 1 April for the previous calendar year.
- legislation.gov.ukSI 2024/1332, Schedule 4 — producer reporting information
The fourteen descriptions of data, in kilograms to the nearest kilogram.
- legislation.gov.ukSI 2024/1332, regulation 60 — liability for disposal and administration fees
Large producers that supplied household packaging, other than sellers.
- legislation.gov.ukSI 2024/1332, Schedule 5 — recycling obligations
Material targets for PRNs and PERNs, 2025 to 2030.
- legislation.gov.ukSI 2024/1332, regulation 115 — offences: producers
Failing to register, keep records or report on time.
- legislation.gov.ukSI 2024/1332, regulation 119 — penalties for offences
A fine on conviction.
- legislation.gov.ukSI 2024/1332, Schedule 13 paragraph 2 — fixed monetary penalty
£1,000.
- legislation.gov.ukSI 2025/1369, regulation 12 — registration charges
The amended producer registration charges.
- Defra and Environment AgencyExtended producer responsibility for packaging: who is affected and what to do
Updated 20 April 2026: activities, groups, nation data.
- DefraEPR for packaging: what you must do as a small producer
No disposal fees or PRNs for small producers.
- Defra and Environment AgencyReport packaging data
Updated 19 August 2026: the RPD service for registration, data and PRN acceptance.
- PackUKPackUK operational plan: 2026 to 2027
Confirmed year 2 fees not yet calculable; notices of liability by the end of November 2026.
- PackUK / DefraEPR for packaging: 2025 base fees
The only final per-material fees, for 2025/26.
- PackUKEPR for packaging: modulated disposal fees
How fees are modulated by recyclability from 2026 to 2029.
- PackUKPackUK publishes Recyclability Assessment Methodology (RAM) 2027
RAM 1.1 for 2026 data; RAM 2027 for 2027 data.
- PackUK / DefraEPR for packaging: notice of liability
How the fee is invoiced, paid and recalculated.
- legislation.gov.ukFinance Act 2021, section 45 — plastic packaging tax rate
£228.82 per tonne from 1 April 2026.
- HMRCSubmit your Plastic Packaging Tax return
Quarterly returns, due the last working day of the following month.
- legislation.gov.ukSI 2025/67 — Deposit Scheme for Drinks Containers (England and Northern Ireland), regulation 1
The deposit return scheme from 1 October 2027.