Guidance

Extended producer responsibility for packaging: mergers and transfers of ownership

What to do if your company merges with another company, or acquires a brand or business from another producer

From:
Department for Environment, Food & Rural Affairs
Published
10 February 2026

Mergers and changes of ownership are different from joining or leaving a group. Guidance on ‘mid-year changes’ for groups and subsidiaries will be published in February.

This guidance applies when at least one of the companies involved was already registered for EPR for packaging. If none of the companies were registered but together they meet the thresholds after merging, the normal registration rules apply.

Mergers

These rules apply if both:

  • a new company was formed from the merger of 2 or more existing companies
  • one or more of those companies was registered for EPR for packaging in the year of the merger

Large or small producer status

If any of the merged companies was a large producer, the new company is treated as a large producer. Otherwise it is treated as a small producer.

This applies for the year of the merger and the following year. After that, the new company’s status is based on its own turnover and packaging tonnage.

For the definition of large and small producers, see who is affected by EPR for packaging.

Registration

The new company must register for EPR for packaging by the later of:

  • the earliest date by which any of the merged companies would have had to register
  • 28 days after the merger

Packaging tonnage

The new company is treated as supplying:

  • all the packaging supplied by each merged company before the merger
  • all the packaging supplied by the new company after the merger

Fees and obligations

The new company is responsible for waste disposal fees and administration fees for the assessment year starting 1 April in the year of the merger. This applies whether the merger happens before or after 1 April.

It is also responsible for any unpaid fees from previous years, including fees arising from later recalculations.

The new company must keep all relevant records and evidence from the merged companies.

PRNs and PERNs

Packaging recycling notes (PRNs) and packaging export recycling notes (PERNs) obtained by the merged companies can be transferred to the new company. The new company can use them to meet its recycling obligations.

Guidance on the process for transferring PRNs and PERNs will be published separately.

Transfer of ownership of a brand or business

These rules apply if a producer transfers ownership of:

  • their whole business
  • part of their business
  • a brand

Notifying the regulator

The new owner must notify the regulator in writing within 28 days. The notification must include:

  • the name of the brand or business acquired
  • who transferred it to them
  • the date of the transfer

Registration

The new owner must register for EPR for packaging — or re-register as a large producer if the transfer takes them over the threshold. They must do this by the later of:

  • the deadline for the previous owner’s registration
  • 28 days after the transfer

Adjusted thresholds

In the year of the transfer and the following 2 years, adjusted figures apply when determining whether the new owner is a large or small producer.

The adjusted turnover is the new owner’s turnover plus the previous owner’s turnover.

The adjusted packaging tonnage is the new owner’s packaging tonnage plus the previous owner’s packaging tonnage.

If only part of a business or a single brand was transferred, the adjusted figure includes only the proportion of turnover or tonnage attributable to that part or brand.

These adjusted figures are compared against the standard thresholds for large and small producers.

Additional reporting (large producers only)

If the previous owner was a large producer, both the previous and new owner must submit or resubmit their packaging data for 4 reporting periods:

  • January to June in the year before the transfer
  • July to December in the year before the transfer
  • January to June in the year of the transfer
  • July to December in the year of the transfer

In these reports, any packaging supplied by the previous owner before the transfer date using the transferred brand or through the transferred business must be reported by the new owner instead.

The previous owner must still submit these reports even if they are no longer a producer after the transfer.

Reports must be submitted by the later of:

  • the usual reporting deadline
  • 28 days after the transfer

Fees and obligations

The scheme administrator calculates waste disposal and administration fees for the assessment year starting 1 April in the year of transfer using the data submitted or resubmitted by both parties.

Recycling obligations for packaging supplied using the transferred brand or business become the responsibility of the new owner.

Get help

Contact the environmental regulator for your nation if you have questions about mergers or transfers of ownership.

Updates to this page

Published 10 February 2026

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