Packaging waste: prepare for extended producer responsibility

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 importing or supplying more than 25 tonnes of packaging to the UK market in the previous calendar year 
• you carry out any of the packaging activities

Use the online service to check if you need to report packaging data.

If you’re a small producer

A ‘small producer’ is an organisation that either:

• has an annual turnover of more than £1 million and up to £2 million and supplies more than 25 tonnes of packaging in the UK

• has an annual turnover of more than £1 million and supplies more than 25 tonnes and no more than 50 tonnes of packaging in the UK
  
  Find out what you must do as a small producer

  Packaging definition   

  Packaging is any material that is used to cover or protect goods that are supplied. It makes handling and delivering goods easier and safer. It includes anything that’s designed to be filled at the point of sale, such as a coffee cup.
  
  Find out more about what constitutes primary, secondary, tertiary and shipment packaging
  
  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
  
  There are detailed illustrations and examples in the ‘agreed positions and technical interpretations’ guidance, produced by the environmental regulators. It is currently stored on the National Packaging Waste Database

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 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 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 can check a list of large producers who have submitted data to the regulators. The list 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.

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 calendar year

If you’re a small organisation

To comply with the regulations, you should have recorded data about the packaging you supplied or imported into the UK in 2024 and reported this data by 1 April 2025.

Find out what period you must collect data on and the deadlines for reporting

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 1 January 2025  (for more information about this see the section about ‘when to collect and report your data for 2025’)
• 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 2026, report data between 1 July 2026 and 1 October 2026.

For the period July to December 2026, report data between 1 January 2027 and 1 April 2027.

If you miss the deadline, you may need to pay a penalty charge.

You may also need to collect and report nation data. Find out more about 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 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.

Recycling obligations will apply from 2026 onwards based on your 2025 data. 

Period you must report on 

There are different reporting periods depending on what year you will be reporting for, and whether you will be reporting as a small or large producer.

Find out more about reporting periods and deadlines

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)

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 part of a group of companies  

If you’re part of 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.   

More information and examples

There are detailed illustrations and examples in the ‘agreed positions and technical interpretations’ guidance, produced by the environmental regulators. It is currently stored on the National Packaging Waste Database.

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 2025 calendar year by 1 April 2026.

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 later fee.

Reporting nation of sale data and self-managed organisation waste for 2024 to 2026 

The environmental regulators have issued a statement on nation of sale data and data about self-managed organisation waste. 

This only applies to nation of sale data and data about self-managed organisation waste. It does not apply to any other data you must collect for EPR for packaging.

Read the regulatory position statement to understand how this affects your data submission.

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

There is separate guidance that explains fees and recycling obligations.

Illustrative base fees for EPR are available. The illustrative fees are a first estimate, based on the best available evidence to date, and are not final figures.

Your fee will be lower if you use packaging that is easier to recycle. Find out more about the recyclability assessment methodology, including how to report recyclability and how fees will be modulated.

You will also have to pay a registration fee when you register your organisation.

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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