Manufacturer Obligations for Packaging Waste: Identifying Affected Parties and Proposed Actions
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The UK government has updated the Extended Producer Responsibility (EPR) regulations for packaging, effective from 2025. These regulations aim to ensure that businesses that meet certain turnover and packaging tonnage thresholds report packaging data and pay fees covering the net costs of collection, sorting, recycling, and disposal of household packaging.
Who is Affected?
Organisations that import or supply packaging in the UK may need to comply with the new regulations. This includes businesses that place goods into packaging, import products in packaging, own an online marketplace, hire or loan out reusable packaging, or supply empty packaging.
Small and Large Producers
Small organisations are obligated if they have either:
- An annual turnover between £1-2 million and handle over 25 tonnes of packaging per year, or
- An annual turnover above £2 million handling between 25 and 50 tonnes of packaging annually.
These small producers must report packaging data starting in 2025.
Large organisations must meet both:
- An annual turnover of more than £2 million, and
- Responsibility for over 50 tonnes of packaging in a calendar year.
Large producers have full reporting and fee obligations.
Registration and Fees
Producers can register directly with the Environment Agency or via compliance schemes that manage obligations on their behalf. The base fees for 2025 are calculated using the packaging tonnages reported for 2024 and local authority waste management costs, with most fees being lower than previously estimated due to strong industry compliance and validated data.
Reporting Requirements
Businesses must report data about the empty packaging and packaged goods they supply or import in the UK. The deadline for reporting depends on which nation your organisation is based in. Reporting periods and deadlines vary, so it's essential to check the specific requirements for your situation.
Compliance Schemes
Compliance schemes are third parties that help organisations meet the packaging regulations requirements. If you choose to work with a compliance scheme, ensure they appear on the compliance scheme public register.
Further Information
Detailed illustrations and examples of primary, secondary, tertiary, and shipment packaging can be found in the 'agreed positions and technical interpretations' guidance. Separate guidance is available for existing producer responsibility regulations.
For more information or questions, email the packaging team. If you're complying as an individual subsidiary, create an account and report packaging data as an individual subsidiary.
The regulations apply to all UK organisations that import or supply packaging. Missing the deadline may result in a late fee. The UK regulations for packaging producer responsibility have been updated.
[1] Environment Agency guidance on EPR regulations for packaging [2] Defra guidance on EPR regulations for packaging [3] Compliance scheme public register [4] Join the Defra user panel to help improve their services
- The revised Environmental-Science regulations for packaging, effective from 2025, apply to businesses in the industry, including those that import, supply, or own packaging in the UK.
- In the UK, Personal-Finance could be impacted as small businesses, meeting certain turnover and packaging tonnage thresholds, will need to report packaging data and pay fees under the new regulations.
- Large businesses, responsible for over 50 tonnes of packaging annually, will have full reporting and financial obligations under the updated Business sector regulations for packaging.
