Extended producer responsibility for packaging: who is affected and what to do
How UK organisations that supply or import packaging should comply with extended producer responsibility (EPR) for packaging.
The way UK organisations responsible for packaging must carry out their recycling responsibilities has changed.
If you’re affected by extended producer responsibility (EPR) for packaging, you will need to report your packaging data.
EPR for packaging fees have been deferred for a year. You will not have to pay any EPR for packaging fees in 2024. However, you must still follow this guidance and report your packaging data for 2023. You must also continue to pay any fees due under previous regulations.
A separate guidance collection covers existing producer responsibility regulations – you may need to meet both sets of regulations depending on your situation.
Check if you need to take action
The regulations will apply to all UK organisations that import or supply packaging.
You need to collect and report packaging data if all the following apply:
- you’re an individual business, subsidiary or group (but not a charity)
- you have an annual turnover of £1 million or more (based on your most recent annual accounts)
- you were responsible for more than 25 tonnes of packaging in 2022
- you carry out any of the packaging activities
Packaging activities
You may need to act if you do any of the following:
- supply packaged goods to the UK market under your own brand
- place goods into packaging
- import products in packaging
- own an online marketplace
- hire or loan out reusable packaging
- supply empty packaging
Some organisations that supply packaged goods to the UK market need to report ‘nation data’. You can find out more about this in the ‘check if you need to report nation data’ section.
Supplying goods to the UK market under your own brand
You may need to take action if packaged goods labelled with your own brand are supplied to the UK market. A brand includes any of the following:
- a name
- a trademark
- any distinguishing mark
For example, a confectionery company manufactures and packages sweets under their own brand. It sells these sweets to a supermarket. The supermarket goes on to sell the sweets to UK users. In this instance, the confectionery company may need to take action.
However, the confectionery company would not need to take action if it produced and packaged sweets under the supermarket’s brand, which the supermarket then sold. In this instance, the supermarket may need to take action.
You may also need to take action if you pay or license another company to do any of the following for you:
- produce goods that will be sold under your brand name
- pack goods that will be sold under your brand name
- place your branded goods on the UK market
- import goods for you
Placing goods into packaging
If you place goods into packaging you may need to take action. This could be goods you packaged for your own organisation or for another organisation.
Importing products in packaging
You may need to take action if your organisation imports products from outside the UK that are in packaging and goes on to supply these products to the UK market.
You may need to take action if you sell imported goods that are packed or filled by a UK third party on behalf of a company that is not established in the UK.
You may need to take action even if you discard packaging before selling the goods.
You do not need to take action if you import filled packaging that is:
- branded, and you’ve imported it on behalf of a brand owner that is established in the UK
- unbranded, and you go on to supply it to a ‘large’ organisation that applies its brand before supplying it on
The ‘check if you’re a large or small organisation’ section explains which organisations are classed as ‘large’.
You’ll also be able to check a list of large producers who have submitted data to the regulators. The list will be published once the data is ready and will be regularly updated.
Owning an online marketplace
Under EPR for packaging, you’re classed as carrying out the ‘owning an online marketplace’ activity if you operate a website or app that allows non-UK businesses to sell their goods into the UK. If you own an online marketplace, you may need to take action.
If your organisation owns a website or app that sells goods from UK organisations only, this is not classed as carrying out the ‘owning an online marketplace’ activity. However, you should check if you carry out any of the other packaging activities.
Hiring or loaning out reusable packaging
If you hire or loan out reusable packaging, you may need to take action.
For example, some organisations hire or loan out wooden pallets to other organisations for transporting goods. The wooden pallets are returned after use and loaned out again.
Supplying empty packaging
You may need to take action if you manufacture or import empty packaging and then supply it to a business that is not classed as a large organisation.
You can find out what the criteria are for a large organisation in the ‘check if you’re a large or small organisation’ section.
Packaging definition
Packaging is any material that is used to cover or protect goods that are sold to users. It makes handling and delivering goods easier and safer. It also includes anything that’s designed to be filled at the point of sale, such as a coffee cup.
Packaging also makes goods look appealing for sale and may display a company’s logo or brand. ‘Goods’ could include raw materials or manufactured items.
What you may need to do
You may need to:
- collect and report data on the packaging you supply or import
- pay a waste management fee
- pay scheme administrator costs
- pay a charge to the environmental regulator
- get packaging waste recycling notes (PRNs) or packaging waste export recycling notes (PERNs) to meet your recycling obligations
- report information about which nation in the UK packaging is supplied in and which nation in the UK packaging is discarded in – this is called ‘nation data’
What you need to do depends on whether you’re classed as a ‘small’ or ‘large’ organisation. This is based on:
- your annual turnover
- how much packaging you supply or import each year
Check if you’re a large or small organisation
You’re classed as a small organisation if either of the following apply:
- your annual turnover is between £1 million and £2 million and you’re responsible for supplying or importing more than 25 tonnes of empty packaging or packaged goods in the UK
- your annual turnover is over £1 million and you’re responsible for supplying or importing between 25 tonnes and 50 tonnes of empty packaging or packaged goods in the UK
You will be classed as a large organisation if both of the following apply:
- you have an annual turnover of £2 million or more
- you’re responsible for supplying or importing more than 50 tonnes of empty packaging or packaged goods in the UK
You should base your annual turnover on your most recent annual accounts.
Your total weight is the amount of packaging in a calendar year (January to December) that you:
- supplied through the UK market
- imported and then discarded in the UK
If you’re a small organisation
To comply with the regulations, you must record data about the empty packaging and packaged goods you supply or import in the UK from either 1 January 2023 or 1 March 2023 - find out what period you must report on.
You do not currently have to report data, but you will need to in the future.
If you’re a large organisation
To comply with the regulations, you may need to:
- record data about the empty packaging and packaged goods you supply or import in the UK from either 1 January 2023 or 1 March 2023 - find out what period you must report on
- create an account for your organisation
- pay a waste management fee
- pay scheme administrator costs
- pay a charge to the environmental regulator
- get PRNs or PERNs to meet your recycling obligations
- report data about empty packaging and packaged goods you supplied or imported
Your waste management fee will initially be calculated based on packaging you’ve reported as ‘household packaging’. Find out more about what’s classed as household packaging.
The deadline for reporting depends on which nation your organisation is based in. Find out about the deadlines for reporting.
If you miss the deadline, you may need to pay a late fee.
You’ll need to report data every 6 months.
You may also need to report nation data.
PRNs and PERNs
A PRN (packaging waste recycling note) or PERN (packaging waste export recycling note) is evidence that packaging waste has been recycled.
You can get PRNs from accredited reprocessors. Reprocessors are responsible for recycling packaging waste. You can also get PERNs from accredited exporters.
By getting PRNs and PERNs, you work towards meeting your recycling obligations.
Period you must report on
There are different reporting periods depending on what year you will be reporting for.
Reporting periods for 2023
If you have all the required data recorded from 1 January 2023, you should report this data.
If you do not have all the required data recorded from 1 January, you must report all of your data from 1 March 2023. If you report data that covers a period starting from 1 March, this will be used to calculate a full year’s worth of data.
If your organisation is based in Wales
Large and small organisations in Wales should comply with this reporting schedule if they have the required data.
If you do not have all the required data recorded from 1 January, you must report all of your data from 17 July 2023. If you report data that covers a period starting from 17 July, this will be used to calculate a full year’s worth of data.
Reporting periods for 2024
Some of the rules are changing for reporting data from 2024 onwards. Find out more about what you must report.
If you have all the data under the new rules for 2024, you should report it in 2 batches:
- report your January to June data from 1 July 2024
- report your July to December data from 1 January 2025
If you do not have all the data required under the new rules, you should still report in 2 batches:
- do not report any data relating to packaging supplied between 1 January and 30 March 2024
- report data collected under the new rules from 1 April to 30 June – do this from 1 July 2024
- report your 1 July to 31 December data from 1 January 2025 - this data must follow the new 2024 rules
If you do this, the data from the 2 submissions will be used to calculate the 3 missing months (January, February and March 2024).
Deadlines for reporting packaging data
Small organisations should:
- collect your 2023 packaging data - you do not have to report it
- collect your 2024 data and submit it by April 2025
Large organisations
In England, Scotland and Northern Ireland you should submit by:
- 1 October 2023 to report for January to June 2023
- 1 April 2024 to report for July to December 2023
In Wales, you should submit data for July to December 2023 by 1 April 2024. You can include data from January to June 2023 if you have it.
These deadlines are laid out in the regulations. You should make your best effort to meet them but no enforcement action will be taken about late submission if your data is submitted by 31 May 2024.
If you’re a parent company, group or subsidiary
Parent companies and their subsidiaries can comply with EPR for packaging in different ways. They can comply as:
- a whole group - the parent group creates an account and reports packaging data on behalf of each subsidiary that supplies packaging
- individual subsidiaries - each subsidiary that supplies packaging creates an account and reports independently
- a mix of the other ways - the parent company reports on behalf of some parts of the group, while other subsidiaries report for themselves
If the parent group is reporting on behalf of some or all of its subsidiaries, you’ll need separate packaging data for each subsidiary. Check the guidance on creating your packaging data file for more information.
If you’re complying as a whole group
If you have a group of companies, add up the turnover and weight of packaging supplied or imported for all members of the group that supply or import any packaging at all. If these totals meet the criteria for a small or for a large organisation, then each of these members must comply with EPR for packaging. It does not matter whether they meet the criteria individually.
When calculating a total, do not include the turnover of any parts of the group that do not supply or import packaging. These parts of the group do not need to report packaging data.
If you’re complying as an individual subsidiary
Create an account and report packaging data as an individual subsidiary, rather than as part of your parent company.
If you supply or import any packaging at all, you must report packaging data, regardless of your annual turnover.
If you’re complying as a parent company for part of the group
If some of your subsidiaries are going to report independently and some as part of the group, you can create an account as a parent company for part of the group and report on that part’s behalf.
Do not include any subsidiaries that are creating an account independently.
Every subsidiary that supplies or imports any packaging at all must report its packaging data, regardless of its annual turnover.
Check if you need to collect nation data
Nation data is information about which nation in the UK packaging is supplied in and which nation in the UK packaging is discarded in.
If your organisation must act under EPR for packaging, you must submit nation data if you also do any of the following:
- supply filled or empty packaging directly to customers in the UK, where they are the end user of the packaging
- supply empty packaging to UK organisations that are either not legally obligated, or are classed as a small organisation
- hire or loan out reusable packaging
- own an online marketplace where organisations that are based outside the UK sell their empty packaging and packaged goods to UK users
- import packaged goods into the UK for your own use and discard the packaging
You will need to submit your nation data for the 2024 calendar year by 1 December 2025.
Nation data should show where in the UK you’ve supplied packaging to a person or business who’s gone on to discard it.
Supplying packaging includes:
- selling
- hiring
- loaning
- gifting
This also includes packaging that you’ve imported and then discarded.
If you miss the deadline, you may need to pay a late fee.
Collecting and reporting your packaging data
Your data submission must include the information about the:
- packaging activity – this is how you supplied the packaging
- packaging type – for example, if the packaging is household or non-household
- packaging class - whether the packaging is primary, secondary, shipment or tertiary
- packaging material and weight
Find out more about how to collect your packaging data.
Information about fees
EPR for packaging fees have been deferred for 1 year. Fees were starting in October 2024. They will now start in October 2025.
As soon as we can, we will give you an indication of what the material fees will be. These will vary depending on the materials you report.
In future, the waste management fee will also vary depending on how easily the packaging can be recycled. Your fee will be lower if you use packaging that is easier to recycle.
You must still report your packaging data for 2023.
Getting help from a third party (compliance scheme)
Compliance schemes are third parties that help organisations meet the EPR for packaging requirements.
Compliance schemes can:
- pay your registration fees
- get PRNs or PERNs to meet your recycling obligations
- report your packaging data
A compliance scheme cannot make your waste management payments.
If you choose to work with a compliance scheme, you should make sure they appear on the compliance scheme public register.
Get help and give feedback
If you have any questions, contact the packaging team.
Email: pEPR@defra.gov.uk
Tell us what you think
You can give feedback about this guidance and the rest of the EPR guidance - let us know if anything is unclear or incorrect.
Last updated 16 April 2024 + show all updates
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This small update fixes the collection period and reporting deadlines for nation data - the first report of nation data will be for the 2024 calendar year and must be submitted by 1 December 2025
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This change explains that the list of large producers on RPD will be published once the data is ready.
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New reporting regulations come into force on 1 April. This guidance has been updated to with some small changes of wording to align with these regulations, and a link to guidance that gives more detail on the changes.
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Changed detail about small producers under ‘What you may need to do’, specifying more clearly that they should collect data but don’t yet have to report.
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Clarification in the deadlines section that small organisations are only obligated to collect the data, not report it, and giving early warning that they'll have to collect and report in 2024. Signposting the specific period obligated to report in Wales from July to December, but that data for January to June 2023 can also be reported in April 2024. Changing 'they' to 'you' when appropriate for style. Fixed typo in the contact email link.
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We've added a link so that you can give feedback about this guidance.
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An update to match regulations: where packaging is decribed as 'imported, emptied and then discarded', that's been changed to 'imported and discarded' throughout.
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This update adds a recent decision by the English and Scottish regulators: they will take no enforcement action as long as organisations submit packaging data by 31 May 2024.
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The report packaging data service is now live. This update adds a link to that service.
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There's been a decision to defer extended producer responsibility for packaging fees for one year. This update reflects that, and also explains that other timescales have not changed - producers still have to report packaging data for 2023.
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The service for reporting data is now scheduled to go live in August 2023. This update reflects that.
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Added Welsh translation
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We’ve changed the title of the guidance as the regulations are now in force. We’ve made minor changes to the style, order, and some terminology to make the guidance clearer and to reflect the fact that the regulations are now in force. We’ve also updated the following sections, to make them clearer: Packaging activities; What you may need to do; PRNs and PERNs; Check if you need to report nation data; Collecting and reporting your packaging data; Information about fees. We’ve added a new section titled ‘When to collect and report your data for 2023’.
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We've added a link to the compliance scheme public register.
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We've added a link to a service that helps you to check if you need to report packaging data.
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We’ve made minor changes throughout the guidance to make it clearer. The second packaging activity has been updated to say: ‘pack or fill packaging that’s unbranded when it’s sold’. We’ve made it clear that you will not need to take action if you import packaged goods on behalf of another organisation. In this case, the organisation who you import the goods for will need to take action. Small organisations must create an account and register from January 2024. Large organisations must create an account and register from July 2023. We’ve removed text about ‘collecting and submitting your packaging data’ and added a link to new guidance on how to collect your packaging data.
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Added translation
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There are minor format and style changes throughout to make the guidance clearer and easier for people to use. We’ve added a packaging definition, information about PRNs and PERNs, street bin waste, and compliance schemes. We’ve updated the packaging activities section and the information about nation data. We’ve also updated the packaging categories, the household and non-household waste section, the ‘get help’ email address. We’ve clarified that the regulations apply to packaging that’s supplied to consumers and businesses. We’ve also clarified how to submit information about reusable packaging and how parent companies, groups and subsidiaries can comply with the regulations.
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First published.