Extended Producer Responsibility (EPR) is new legislation being rolled out in the UK as part of the 2025 Simpler Recycling scheme. Businesses started reporting their packaging waste in 2023, with financial obligations such as fees and taxes coming into place in 2025. The regulation will see businesses that put packaging onto the UK market be taxed for creating packaging waste. EPR aims to make businesses more accountable for the packaging they are putting into the economy. The responsibility and disposal of packaging waste currently lies with households and local authorities to collect and manage the waste. EPR aims to shift the responsibility onto the businesses that are supplying the products with the packaging, encouraging them to produce less packaging volume and making them fund the net cost of collecting, sorting, treating and recycling packaging waste.

So, which businesses does EPR apply to and what should you do to comply with the new legislation?

Extended Producer Responsibility (EPR) | E-commerce Packaging

Who does EPR apply to?

Extended Producer Responsibility (EPR) applies to any UK business which imports or supplies packaging into the UK market, which could end up in household waste. There is a misconception that it only applies to companies that actually manufacture packaging, but the EPR tax can also apply to online retailers, distributors and manufacturers in any industry.

You can check the government website to see if EPR applies to your business, which is likely if the following applies to your business:

An individual business, subsidiary or group (but not a charity)
Your annual turnover is more than £1 million
Responsible for more than 25 tonnes of packaging in 2022
Carry out any of the packaging activities defined by the Government

Extended Producer Responsibility (EPR) | Packaging in Warehouse

Does EPR affect my Business?

The government has identified criteria for small and large businesses, which will affect how the legislation will be applied. Please check the government guidance for any changes to the latest legislation

You will be classified as a small business 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 packaging 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 packaging in the UK

You will be classified as a large business 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 packaging in the UK

For both classifications, your turnover should be taken from your most recent company accounts. Total packaging weight is calculated on your usage in a calendar year – January to December – of packaging supplied through the UK market, including anything imported and then discarded in the UK.

How do I Comply with EPR?

If your business is required to comply with the new EPR legislation, there are a few key points to consider:

From October 2025, producers will have greater financial responsibility for household packaging waste.
New reporting requirements have been in effect since 2023. Additional data regarding packaging type and recyclability will need to be collected and reported every 6 months.
Data reporting requirements will become more complex, with the need to report individual packaging categories including paper, aluminium, glass, steel, wood and fibre-based composites. The introduction of EPR fees could see producer compliance costs increase, especially if you use hard or costly packaging to recycle.
From 1 April 2027, all packaging will need to display a binary recyclability label declaring either “recycle” or “do not recycle”
If you are a large business, you may have to pay scheme administrator costs, a registration charge to the environmental regulator, get PRNs or PERNs to meet your recycling obligations and report data about packaging you supplied or imported – this includes packaging around raw materials

How can I Reduce EPR Fees

Reducing EPR fees requires a comprehensive approach to packaging waste and its environmental impact and an understanding of how a circular economy is created. Here are some actions you can take to help reduce EPR fees for your business.

Conduct a Packaging Audit
A packaging or waste audit may include examining materials, design of packaging and practical implications; gathering data on packaging and associated costs; identifying problem areas and providing recommendations for optimization.
Reduce Unnecessary Packaging
Consider if every bit of packaging is necessary, do all packaging components serve a critical function and does the product need packaging at all?
Reduce Packaging Weight
EPR fees are calculated on the overall packaging weight, so using lightweight packaging materials which are sustainable can help reduce EPR fees. You should also ensure your packaging weight data is accurate and not over or underestimated. It’s important to carry out regular packaging audits and verify the packaging weights you are reporting.
Use the Smallest Size Packaging with Adequate Protection
If you are an ecommerce business, ensuring you are using the smallest size boxes that provide adequate protection for your products, can help reduce the volume of packaging you are putting in the environment.
Choose Sustainable Packaging Materials
While EPR fees have not currently been announced, Defra has announced that difficult-to-recycle materials are under consideration for higher modulated fees.
Meaning that EPR fees may be higher for materials that are deemed difficult to recycle, whilst those that are easier or more efficient to recycle will attract the lowest costs. This is not just the material type - multi-material packaging that is hard to separate can be difficult and costly to recycle. Can you switch to mono-material packaging? If you must use multi-material, can you ensure it is easily separated by the consumer for recycling? Making small changes to your packaging such as using paper tape can help reduce your environmental impact. Paper tape is commonly made from renewable sources, is biodegradable, recyclable and helps prevent the cross contamination of cardboard waste.

Efficient Packaging Training
Ensure all staff are trained to use the correct amount of packaging, avoiding overuse and wastage, and also minimising damages. This includes the training of temporary and seasonal staff.

Packaging Waste

Extended Producer Responsibility

Who does EPR apply to?

Does EPR affect my Business?

How do I Comply with EPR?

How can I Reduce EPR Fees

Extended Producer Responsibility

What are Packaging Recovery Notes (PRNs)?

Extended Producer Responsibility

Changes to the PRN / PERN system

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