Complying with Extended Producer Responsibility: What You Need to Know

Extended Producer Responsibility (EPR) marks a significant shift in how UK businesses must manage packaging waste. Introduced as part of the Government’s commitment to building a circular economy, EPR transfers responsibility for the full cost of dealing with packaging waste to the businesses that place packaging on the market.

This article provides a concise overview of the EPR packaging regulations, including who is affected, what’s changed, and the steps your organisation should take to ensure EPR compliance.

Extended Producer Responsibility (EPR) is a major reform of UK packaging waste regulations. It requires businesses that supply or import packaged goods to take full financial responsibility for the packaging they place on the UK market, once it becomes waste.

The goal is to reduce packaging waste, improve recycling rates and drive sustainable packaging design – all central to the UK’s broader strategy for environmental responsibility and a low-waste economy.

Under the previous “shared responsibility” system, packaging waste management costs were distributed across the supply chain. EPR replaces this with a “full cost recovery” model, placing the burden entirely on a single producer for a single piece of packaging, from collection through to disposal or recycling.

This means that in-scope businesses must now:

• Fund household waste collections through local authority waste management fees
• Demonstrate recycling activity by purchasing Packaging Recovery Notes (PRNs)

EPR applies to UK-based organisations that:

• Supply or import packaged goods to the UK market, and
• Meet the specified turnover and packaging volume thresholds.

The term producer includes more than just manufacturers. If your business is responsible for placing packaged goods on the UK market – regardless of who manufactured the packaging – you’re likely considered a producer under EPR.

4.1 Packaging Data Reporting

Both large and small producers must collect and report detailed packaging data. Key reporting categories include:

• Whether packaging is household (likely disposed of in domestic waste) or non-household (B2B)
• The material composition of each packaging component
• Nation of sale – where in the UK the packaging is sold or expected to become waste
• Self-managed waste: applicable to large producers who manage their own waste streams
• Recyclability of household packaging, using the government’s Recyclability Assessment Methodology (RAM)

Large producers must submit data twice a year. Small producers are currently only required to report annually.

4.2 Financial Payments (for large producers only)

In addition to reporting, large producers must also:

• Purchase PRNs (Packaging Recovery Notes) to evidence the recycling of their packaging waste
• Pay Local Authority Waste Management Fees, which fund household waste collection and processing. The amount owed depends on the recyclability of your packaging, as assessed through the RAM.

If your organisation may be in scope for EPR, its essential to act now to avoid non-compliance. Here’s how to get started:

✅ Review your packaging activities
✅ Identify what data you need to collect
✅ Understand your reporting and payment obligations

You can register directly with regulators or make life easier by joining a compliance scheme like Clarity Environmental, which can help you manage your responsibilities efficiently – from data collection to reporting and PRN purchasing.

For a more detailed breakdown of the requirements, see our Complete Guide to Extended Producer Responsibility.

Still have questions? Get in touch using the form below, and one of our compliance experts will help you understand your obligations and stay ahead of the changes.