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.
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
Use the online service to check if you need to report packaging data.
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 that’s unbranded when it’s supplied
- 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 consumers. 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 that’s unbranded when it’s supplied
If you place goods into packaging and that packaging is unbranded when it’s supplied, 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 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’.
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 consumers. 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, emptied and then discarded in the UK
If you’re a small organisation
To comply with the regulations, you must:
- record data about all the empty packaging and packaged goods you supply or import in the UK from either 1 January 2023 or 1 March 2023 (for more information about this see the section about ‘when to collect and report your data for 2023’)
- create an account for your organisation from January 2024
- pay a charge to the environmental regulator from 2024
- report data about empty packaging and packaged goods you supplied or imported
You’ll need to report your data between 1 January 2024 and 1 April 2024.
If you miss the deadline, you may need to pay a penalty charge.
You may also need to report nation data.
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 (for more information about this see the section about ‘when to collect and report your data for 2023’)
- create an account for your organisation from July 2023
- 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
In 2024 your waste management fee will be calculated based on packaging you’ve reported as ‘household packaging’. Find out more about what’s classed as household packaging.
You’ll need to report data every 6 months.
For the period January to June 2023, report data between 1 July 2023 and 1 October 2023.
For the period July to December 2023, report data between 1 January 2024 and 1 April 2024.
If you miss the deadline, you may need to pay a penalty charge.
You may also need to report nation data.
When to collect and report your data for 2023
If you have all the required data recorded from the 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 the 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.
Large organisations in Wales should comply with this reporting schedule if they have the required data. If they do not have the required data, they should start collecting data from the date the regulations come into force in Wales in mid-2023 and submit it between 1 January 2024 and 1 April 2024.
Small organisations in Wales should comply with this reporting schedule if they have the required data. If they do not have the required data, they should start collecting data from the date the regulations come into force in Wales from mid-2023 and submit it between 1 January 2024 and 1 April 2024.
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 re-processors. Re-processors 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.
If you’re a parent company, group or subsidiary
For parent companies and their subsidiaries, there are different ways you can comply with EPR for packaging. You can register:
- as a whole group (in this instance, the parent group complies with EPR for packaging on behalf of every subsidiary within the group)
- as individual subsidiaries (in this instance, the subsidiaries that meet the turnover and tonnage requirements comply with EPR for packaging independently)
- as a parent company for part of the group (this is where the parent company registers to comply with EPR for packaging on behalf of some, but not all of its subsidiaries)
You should register as a parent company for part of the group if some of your subsidiaries do not meet the turnover and tonnage requirements in their own right, but do meet the requirements when combined. In this instance, the parent company will comply with EPR for packaging on behalf of the combined subsidiaries.
Check if you need to report 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 consumers
- import packaged goods into the UK for your own use and discard the packaging
You will need to submit your nation data for the 2023 calendar year by 1 December 2024.
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, emptied and then discarded.
If you miss the deadline, you may need to pay a penalty charge.
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
As soon as we can, we will give you an indication of what the material fees will be in 2024. These will vary depending on the materials you report.
From 2025 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.
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 pay your waste management fee.
If you choose to work with a compliance scheme, you should make sure they appear on the compliance scheme public register.
Get help
If you have any questions, contact the packaging team.
Email: EPRTeam@daera-ni.gov.uk
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