Environmental management – guidance

Packaging waste: producer responsibilities

Obligated packaging producers must register and meet their waste packaging recycling and recovery responsibilities.

Packaging: what it is

‘Packaging’ is any material used to hold, protect, handle, deliver and present goods. This covers the whole packaging supply chain from the raw material to the finished goods.

Packaging producer: what an obligated producer is

You are an ‘obligated’ packaging producer if you, or a group of companies you are part of:

  • handle 50 tonnes of packaging materials or packaging in the previous calendar year, and
  • have a turnover more than £2 million a year (based on the last financial year’s accounts)

‘Handling’ means you:

  • carry out one or more of the activities in the table or have these activities carried out on your behalf
  • own the packaging on which the activities are carried out
  • supply packaging or packaging materials at any stage in the chain or to the final user of the packaging

Description of activities

Activity Description
Raw material manufacture Produce raw materials for packaging manufacture
Packaging conversion Convert raw materials into packaging
Packing/filling Put goods into packaging or put packaging around goods
Selling Supply packaging to the end user
Importing Import packaged goods or packaging materials from outside the UK (includes raw materials that will become packaging, for example, plastic pellets used to make bottles)
Service provider A business that supplies packaging by hiring it out or lending it

Check the tonnage you handle

When you work out if you handle 50 tonnes of packaging or more, don’t include packaging or packing material you export or give to someone else to export. You must be able to demonstrate what packaging you’ve exported.

If you’re a holding company with one or more subsidiaries that handle packaging, you are a group and must combine all your yearly turnovers and weights of packaging handled to see if you’re an obligated packaging producer.

Small packaging producer status

You are classed as a small producer if you have a turnover:

  • between £2 million and £5 million
  • of less than £2 million but you are part of a company group that has an obligation

A small producer’s recycling obligation is based on turnover (to the nearest £10,000) and the main packaging material handled, not weight of packaging handled. You will need to provide proof of turnover or a set of audited accounts. This is known as the allocation method.

Licensors and pub chains

An explanation of what a licensor and pub operating business is can be found in the Regulations.

Make sure you know the type of packaging relevant to your business to check if you are an obligated producer, this is:

  • packaging or packaging materials with your trademark
  • around goods that carry your trademark
  • packaging or packaging materials members must buy from the head organisation or a business specified by the head organisation

Why you need to follow the packaging regulations

You must follow the regulations to help:

  • reduce packaging
  • reduce how much waste packaging goes to landfill
  • increase the amount of packaging waste that is recycled and recovered

Obligated packaging producers must register as a packaging producer every year. Your registration will provide your producer obligation – the amount of packaging in tonnes you are responsible for recovering and recycling. Once registered you must meet your obligation.

These are in addition to waste duty of care principles all businesses must follow.

Packaging producer: how to register

You must register with your environmental regulator by:

  • joining a compliance scheme who does this on your behalf
  • registering direct in the National Packaging Waste Database (NPWD)

Join a compliance scheme

Select an approved compliance scheme from the public register.

You join the scheme and for a fee they will register you with the correct environmental regulator and assist with your waste packaging recovery and recycling obligations.

Check the compliance scheme timescales and make sure you provide the correct information about your company and packaging waste.

Register direct

You need to register with the environmental regulator where your registered head office or main place of business is based. To submit a registration you must be an ‘approved person’. This is a:

  • director or company secretary
  • company partner
  • sole trader

Contact your environmental regulator and ask for an authorised signatory form. Once returned and accepted the NPWD will issue a login.

Log in and fill in the registration form in the NPWD.

If you’ve registered before your information is copied into your new registration. You will need to check it and make any necessary amendments. If your obligation is more than 500 tonnes you must provide your revised operational plan by 31 January.

By 7 April you must:

  • enter information and data into NPWD
  • review your auto-generated packaging obligations and check data inconsistencies
  • upload supporting documents
  • submit your application for registration
  • have paid the registration fee

By 31 January the following year you must:

  • meet your recovery and recycling obligation for the calendar year
  • provide your revised operational plan
  • submit an annual certificate of compliance

What you need to enter into NPWD

Step 1: contact details and business information

Provide your:

  • registered office information, and any main site address where your packaging activities happen or where you collate your packaging data
  • Standard Industrial Classification (SIC) code)
  • turnover (last set of audited accounts)
  • status – small producer, subsidiary, holding company or licensor

Groups can register:

  • as one group, the holding company can do this even if it’s not a packaging producer
  • individually
  • as a combination of individual subsidiaries and the holding company

Subsidiaries details you need to include are the:

  • company registration numbers
  • contact details, including addresses
  • Standard Industrial Classification (SIC) code)
  • turnovers
  • main packaging activities of each subsidiary
  • whether any subsidiary is a small producer

Small producers can chose to register as such (obligation based on turnover) or as a packaging producer (obligation based on weight of packaging).

Step 2: packaging data

You must describe:

  • your main packaging activity (for example, sell packaging)
  • any secondary packaging activities (for example, import packaging)
  • how you worked out how much packaging you handled in the previous year

You must enter:

  • the amount (in whole tonnes) of packaging you supply to the next stage in the packaging chain
  • any packaging you import and any packaging around goods you import
  • materials you or another company exports for which you have proper documents

Don’t include:

  • packaging that has been used before unless it is imported
  • process waste

Step 3: review your recovery and recycling obligation

NPWD auto-generates your obligation from the data you entered into the tables. If you don’t fill out the tables correctly you will have the wrong recovery and recycling target so you need to follow the instructions in the NPWD carefully.

Amend any data inconsistencies and then submit.

Small producers must review their obligation calculated on the turnover and main material handled entered.

To find out how the producer obligation is calculated see Schedule 2 of the Packaging Waste Regulations 2007.

The table shows the current UK government recycling targets in percentages:

Material 2014 (%) 2015 (%) 2016 (%) 2017 (%)
Aluminium 46 49 52 55
Glass* 75 76 77  
Glass by remelt* 65 66 67  
Steel 73 74 75 76
Paper/ board 69.5 69.5 69.5 69.5
Plastic 42 47 52 57
Wood 22 22 22 22

*new glass targets announced by Defra for 2014 to 2016

Step 4: upload supporting information

Operational plan

If you have an obligation of more than 500 tonnes, you must send an operational plan. If you are registering the first time you must submit it with your application by 7 April. It must cover all the requirements of Schedule 3, Part 3 of the regulations. If you are re-registering you submit it by 31 January.

Consumer information obligations

If your main activity is selling packaging, you must give your customers information about:

  • return, collection and recovery systems they can use
  • their role in reusing, recovering and recycling packaging and packaging waste
  • what recovery and recycling symbols on packaging mean
  • how to get copies of waste strategy guidance

You must upload an explanation on how you will achieve this.

Packaging producer charges

You can’t pay online. You must pay by cheque, BACS or credit or debit card.

The charges for direct registration are:

  • producer: £776
  • small producer: £562

You can also register the group as a small producer if you’re a group of companies with a combined turnover under £5 million.

Group: £776 plus these subsidiary charges:

  • £180 each for the first 4 subsidiaries
  • £90 each for the next 5 to 20 subsidiaries
  • £45 for any further subsidiaries

Northern Ireland

There are different charges, contact the Northern Ireland Environment Agency.

PCS fee

When you join a compliance scheme, the scheme must pass on your registration fee to the appropriate authority:

  • single company: £564
  • small producer: £345

You can also register the group as a small producer if the group of companies has a combined turnover under £5 million.

Group: £564 plus these subsidiary charges:

  • £180 each for the first 4 subsidiaries
  • £90 each for the next five to 20 subsidiaries
  • £45 for any further subsidiaries

Late fees

If you register with a compliance scheme after the registration deadline you will have to pay an additional late fee of £110.

New information fee

If you need to update your information during the registration year there is no charge for making a minor change. If you need to correct your obligation or packaging handling data (for example, following an inspection by your environment regulator) the charge is £220.

Business changes

Tell your environment regulator within 28 days if a change to your business means the information you supplied in your registration needs updating.

Cancel registration

Do this immediately if you become a member of a producer compliance scheme or stop being a producer.

Financial difficulties

Tell your environmental regulator immediately if your business has:

  • a winding up order, or a resolution for voluntary wind-up
  • entered insolvency, receivership or administration

Comply with your registration

Once registered you must meet your obligations.

Get evidence

You can recover and recycle packaging that your business handled or supplied yourself.

You must get evidence of waste packaging recycling and recovery equivalent to the weight of your obligation from accredited reprocessors and exporters. They (or yourself if you are accredited) can issue electronic packaging recovery notes (ePRNs) and electronic packaging export recovery notes (ePERNs) for the waste packaging they recycle or recover.

While you can’t use the NPWD to carry out financial transactions for evidence notes, it will record and track ePRN/ePERNs credited to your account, and show the remaining balance of your obligation for which you still need evidence.

Certificate of compliance (CoC)

The NPWD generates your CoC. It will say whether your obligation has been met. Your authorised person must check it’s correct, and then submit it on the NPWD.

The deadline is 31 January immediately following the end of the calendar year.


If you fail to meet your legal obligations, or provide false or misleading information you may face prosecution under criminal law. In England and Wales there are also civil penalties. These include:

  • fixed penalty fines for minor offences
  • higher fines for more serious offences
  • an enforcement undertaking: an offer, formally accepted by your environment regulator (in England it is the Environment Agency, or Natural Resources Wales), that redresses the impact of your non-compliance

Public Register and disclosure

By law, we must put your details on a public register. This will include the name and address of your registered office or your main place of business for each site.

If you think any information you provide about your business is confidential, contact your environment regulator and explain why. Be aware that under the Freedom of Information Act 2000 and the Environmental Information Regulations 2004 your environment regulator may have a legal duty to disclose information about you if asked.

Contact your environmental regulator


Environment Agency
Producer Responsibility Regulatory Services
Quadrant Two
99 Parkway Avenue
S9 4WF

Telephone: 03708 506 506

Email: packaging@environment-agency.gov.uk


Scottish Environment Protection Agency (SEPA)
Producer Responsibility Unit
Erskine Court
The Castle Business Park

Telephone: 01786 457 700

Email: producer.responsibility@sepa.org.uk

Northern Ireland

Northern Ireland Environment Agency (NIEA)
Producer Responsibility Unit
Klondyke Building
Cromac Avenue
Gasworks Business Park
Lower Ormeau Road

Telephone: 028 9056 9338

Email: packaging@doeni.gov.uk


Producer Responsibility Unit
Natural Resources Wales
Rivers House
St Mellons Business Park
St Mellons

Telephone: 0300 065 3000

Email: packaging@naturalresourceswales.gov.uk

Legislation and regulations

The producer responsibility regime implements the Directive on Packaging and Packaging Waste (94/62/EC).

The Producer Responsibility Obligations (Packaging Waste) Regulations 2007 (as amended) cover recycling and recovery, while the The Packaging (Essential Requirements) (Amendment) Regulations 2013 cover single market and design and manufacturing aspects.