PACKAGING WASTE EXTENDED PRODUCER RESPONSIBILITY (EPR) EXPLAINED

Packaging Waste Extended Producer Responsibility (EPR) is changing how businesses report and manage packaging across the UK.

Under the UK’s EPR framework, businesses may now have more responsibility for the packaging they place onto the market and the environmental impact linked to its disposal.

For many organisations, this means:

• Increased reporting requirements
• More detailed packaging information
• A greater focus on how packaging is managed throughout the supply chain

The rules can feel complex at first, but understanding the basics can help businesses prepare for their obligations and improve compliance.

WHAT IS PACKAGING EPR?

Packaging Waste Extended Producer Responsibility (EPR) is a UK regulation that gives businesses greater responsibility for the packaging they place onto the market.

In simple terms, businesses may now need to report how much packaging they supply and contribute towards the cost of managing packaging waste once it is disposed of.

This can include primary, outer, transit, and household shipment packaging used across supply chains.

EPR is also designed to improve how packaging waste is managed across the UK. The regulations are expected to support higher recycling rates, reduce non-recyclable packaging, and encourage more sustainable packaging design.

The regulations are also encouraging businesses to:

• Reduce excess packaging
• Increase recycled content
• Use lighter packaging materials
• Explore reusable packaging systems
• Design packaging that is easier to recycle

WHO NEEDS TO COMPLY?

EPR obligations can vary depending on your annual turnover, the amount of packaging your business handles, and the activities your organisation carries out.

Businesses may have obligations if they:

• Hire or loan packaging
• Import packaged goods
• Supply empty packaging
• Sell own-brand products
• Operate an online marketplace
• Manage reusable packaging systems
• Place packaged goods onto the UK market

EXEMPT ORGANISATIONS

In general, exempt organisations are businesses with a turnover under £1 million or those handling less than 25 tonnes of packaging each year.

These organisations do not need to register for EPR, report packaging information, or pay waste management fees.

SMALL ORGANISATIONS

Small organisations are typically businesses with a turnover between £1 million and £2 million, or those handling between 25 and 50 tonnes of packaging annually.

These businesses must register for EPR and report packaging information.

Small businesses must report:

• Material type
• Packaging class
• Branding ownership
• Weight in kilograms
• An annual submission by 1 April
• Packaging data from 1 January to 31 December

These businesses do not currently pay full waste management fees.

LARGE ORGANISATIONS

Large organisations are generally businesses with a turnover of over £2 million and handling more than 50 tonnes of packaging per year.

These organisations must register for EPR, submit more detailed reporting, and contribute towards EPR waste management fees.

Large organisations are also expected to:

• Submit accurate nation data
• Include branding and weight information
• Report packaging data across two reporting periods
• Split reporting by packaging class and material type

All packaging weights must be reported in kilograms (kg).

OWN-BRAND RESPONSIBILITIES 

If a product carries your company branding, your business may still be responsible for the packaging, even if another company manufactures the item. 

This is particularly important for: 

• Branded workwear
• Private label products 
• Imported branded goods 

WHAT INFORMATION MAY NEED TO BE REPORTED? 

EPR increases reporting requirements for many businesses. 

Depending on the organisation's size and activity, this can include: 

• Nation data reporting 
• Packaging material data 
• Packaging weight reporting 
• Recyclability assessments 
• Household and non-household packaging classification 

HOUSEHOLD VS NON-HOUSEHOLD PACKAGING 

Correctly classifying packaging is an important part of EPR compliance because it can affect reporting obligations, waste management fees, and nation data requirements. 

WHAT IS HOUSEHOLD PACKAGING? 

Household packaging is packaging likely to be disposed of by consumers through household or public waste streams. 

This can include: 

• Drink bottles 
• Food containers 
• Product wrapping 
• Protective packaging 
• Online delivery boxes 
• Packaging used for direct-to-consumer sales 

WHAT IS NON-HOUSEHOLD PACKAGING? 

Non-household packaging is typically used within business operations and supply chains. 

This can include: 

• Pallets 
• Shrink wrap  
• Tertiary packaging 
• Secondary packaging 
• Transit packaging between businesses 

Even where waste management fees may not apply, businesses may still need to report non-household packaging under EPR regulations.

WHY CORRECT CLASSIFICATION MATTERS 

Correctly identifying packaging types helps businesses apply the right reporting rules and understand where obligations or fees may apply. 

Classification can impact: 

• EPR obligations 
• Nation data reporting 
• Reporting requirements 
• Waste management fees 

Preparing accurate packaging information early can help businesses improve compliance and reduce reporting challenges later. 

PRACTICAL STEPS FOR BUSINESSES 

As reporting requirements continue to evolve, businesses should start reviewing their packaging processes sooner rather than later. 

Practical steps can include: 

• Reviewing packaging supply chains 
• Preparing internal reporting systems early 
• Ensuring accurate packaging material records 
• Identifying household and non-household packaging 
• Working with suppliers to obtain packaging weight data 
• Training procurement and logistics teams on packaging requirements 

TOP TIP: Your packaging supplier may also be able to support compliance efforts by providing packaging specifications and packaging data.

NEED SUPPORT UNDERSTANDING EPR? 

Understanding packaging obligations can feel overwhelming, especially as regulations continue to evolve. 

Our ESG team is on hand to support businesses with guidance around packaging reporting requirements, packaging classifications, and compliance considerations. 

Speak to the team to learn more about Packaging Waste Extended Producer Responsibility (EPR).