Extended Producer Responsibility: The Complete Guide

Extended Producer Responsibility (EPR) is now in full swing. Producers are required to have completed their 2023 data and should now focus on submitting their 2024 packaging data.

Extended Producer Responsibility (EPR) requires packaging producers to fund the full cost of managing packaging waste. This includes collecting, sorting, treating, and recycling. Brand owners and producers will now cover these costs through local councils  – costs that previously fell to taxpayers.

As before, producers and importers continue to fund the recycling process itself by purchasing  Packaging Recovery Notes (PRNs) which you will continue to receive through your compliance scheme.

Packaging producers obligated under EPR will have been collecting detailed packaging data since January 2023 and have now submitted the first full year of EPR submissions.

The next submission for large producers will be in April 2025 for H2 (Jul-Dec) 2024 packaging data. Small producer will submit their first data report in April 2025 covering packaging activities in 2024.

By Q3 of 2025 obligated Producers will be required to gather more granular packaging data in the modulated categories, such as polymer type and packaging format.

(Click image to open in a new tab)

Organisations with a turnover of more than £1 million and placing over 25 tonnes of packaging onto the UK market must report under the EPR regulations. This minimum threshold for reporting has been lowered from previous regulations.

(Click image to open in a new tab)

Within this threshold, there are two main categories of producers:

You are considered a ‘small producer’ if you meet either of the following criteria:

• Your annual turnover is between £1 million and £2 million.
• You supply or import between 25 and 50 tonnes of empty packaging or packaged goods in the UK.

You are considered a ‘large producer’ if you meet both of the following criteria:

• Your annual turnover is £2 million or more (based on your latest audited accounts).
• You supply or import more than 50 tonnes of packaging or packaged goods in the UK.

The first step for any producer obligated under EPR is to enrol on the Report Packaging Portal (RPD) to receive an Organisation ID. This enrolment is a mandatory EPR requirement.

Importantly, it must be completed by an approved individual, such as a director or company secretary listed on Companies House. Your compliance scheme cannot complete this step on your behalf. Once registered, your compliance scheme will require your Organisation ID to facilitate your data submission.

See more about the RPD Portal in our FAQs:

• What is the RPD Portal?
• How do I Enrol on the RPD Portal for EPR?

As a small producer, you will be responsible for the following:

• Report data once a year. 1^st April 2025 will be the first submission for small producers
• Report ‘Nation of Sale’ data detailing where packaging is disposed, by nation within the UK
• As a small producer, you will not be obligated to pay a Local Authority Waste Management fee

As a large producer, you will be responsible for the following:

• Report packaging data at least twice a year
• Pay Local Authority Waste Management Fees if you supply packaging that goes into household waste collection and street bins. These are paid directly to the Scheme Administrator and are not paid through your compliance scheme
• Meet recycling obligations (met by acquiring PRNs/PERNs)
• Report Nation of Sale data detailing where packaging is disposed, by nation within the UK once a year. The first Nation of Sale report is due by December 2025 for 2024 data

Producers need to gather accurate data on the type, weight, and material of all packaging they place on the market. This includes specific details on each material used, considering its recyclability. Producers should also capture data on the intended use, such as household or business packaging, to ensure compliance with EPR requirements. Collecting this data thoroughly helps streamline reporting and supports sustainable choices across the supply chain and ensures accurate payments:

1. Type and weight of material

You should categorise your data by the following materials:

• Aluminium
• Fibre-based composite
• Glass
• Paper or cardboard
• Plastic
• Steel
• Wood
• ‘Other’

‘Other’ includes any materials you use that are not listed above including: bamboo, ink, ceramic, copper, cork, hemp, rubber, silicon.

2. Packaging Activity

This refers to how you place packaging onto the UK market.

• 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

3. Packaging type

This refers to whether your packaging is:

• Primary
• Secondary
• Shipment
• Tertiary

4. Waste type

Large organisations will need to report whether the packaging:

• is household
• is non-household
• commonly ends up in public bins
• is a drinks container
• is reusable
• becomes self-managed waste

There are 6 producer types under EPR with the single point of compliance often falling on the brand owners or importers. Your producer type relates to your packaging activity, which is how you place packaging onto the UK market.

A brand owner: an organisation that supplies packaged goods to the UK market under your own UK owned brand. Also referred to as ‘supplied under your brand’.

A packer/filler: an organisation that places goods into packaging when supplied onto the UK market. Also referred to as ‘packed or filled as unbranded’.

An importer: an organisation that imports packaged goods from outside the UK, who then go on to supply these products to the UK market. This also includes discarding packaging around an import. Also referred to as ‘imported’.

A distributor: an organisation that supplies unfilled packaging to a company who is not a large producer, subject to obligations, who then go on to supply that packaging to the UK market. Also referred to as ‘supplied as empty’.

A service provider: an organisation that hires or loans out reusable packaging. Also referred to as ‘hired or loaned’.

An online marketplace operator: an organisation that operates a website or app that enables businesses or persons to place their packaged items or goods onto the UK market from outside the UK. If a large producer supplies it on again, the responsibility falls back to the distributor. Also referred to as ‘supplied through an online marketplace that you own’.

EPR will change the way that costs of compliance are spread throughout the supply chain.

EPR replaces the 2007 Packaging Waste Regulations with a single point of compliance, placing full responsibility for each piece of packaging on one business. This is typically the brand owner or importer.

Here’s a general overview to help producers understand reporting obligations and fees:

Data Reporting and Compliance: Obligated producers must submit detailed packaging data at least twice a year. This may require additional administration and system updates within your business, particularly to ensure accurate, regular data submissions.

PRNs: Obligated producers must purchase Packaging Recovery Notes (PRNs) to meet their recycling obligations. This remains in place under EPR and ensures that producers contribute financially to the recycling process itself. Small producers will not have an obligation to acquire PRNs.

Local Authority Waste Management Fees: Any packaging reported as ‘household’ will be subject to this fee. The will be used to calculate the cost for fees derived from 2025 packaging that is paid for in 2026. Obligated producers are responsible for the costs of collecting, sorting, and treating household packaging waste, covering the full net cost. The first EPR Local Authority Waste Management Fee payment will be 1st October 2025 for obligated large producers to the Scheme Administrator.

Commercial packaging waste: For now, businesses that dispose of commercial packaging waste remain responsible for funding its collection and recycling.

Small producer obligations: Businesses that are classed as small producers do not currently have financial obligations under EPR, outside of the Environment Agency fees and compliance scheme membership costs. Need to Clarity that this will be used to calculate cost for the fees derived from 2025 packaging that is paid for in 2026.

Modulated fees, or eco-modulation, are a central part of the UK’s EPR for Packaging system, aimed at encouraging more sustainable packaging choices. These will only relate to ‘household’ packaging and results in lower fees for materials that are easier to recycle.

For your 2025 EPR submission (relating to packaging placed on the market 2025), there are additional reporting requirements affecting how much you pay for Local Authority Waste Management Fees.

Producers will need to report the material they have used in greater detail. For the material you use that is easier to recycle, you will pick up a reduced Local Authority base fee. For the material you use that is harder to recycle, you will pick up an increased Local Authority base fee.

There are expected to be 50-70 confirmed categories in total. We expect Defra to announce these categories before October 2025. Below are some possible modulated categories.

1. Plastics containing carbon black
2. PVC
3. Expanded polystyrene
4. Multi polymer plastic films
5. Compostable and degradable plastics
6. Non-polyolefin foamed plastics
7. Paper and card with double-sided lamination
8. Some coated papers
9. Paper and card with too much* foil embossing
10. Some fibre-based composites
11. Glass with attached ceramics
12. Some packaging in the ‘Wood’ and ‘Other’ category

*To be defined

Although the initial focus of eco-modulation is on recyclability, Defra will consider broader environmental implications of packaging materials in later EPR revisions. These calculations encompass the costs of Local Authority collection and sorting, offering lower fees for certain materials (bonus) and added fees for others (malus).

The Recyclability Assessment Methodology (RAM) is a key component of the UK’s Extended Producer Responsibility (EPR) framework and a central mechanism for calculating modulated fees. Through RAM, businesses assess the recyclability of their packaging materials to determine their associated fees, with easier-to-recycle packaging incurring lower costs. This requirement applies to “household” packaging and is designed to encourage producers to choose recyclable materials.

Using RAM, businesses assess each packaging component and assign it a Red, Amber, or Green rating, reflecting its recyclability. Components rated Green incur the lowest fees, while Red components, which are challenging to recycle, incur the highest fees. These ratings then modify the base fee for each material, creating financial incentives to reduce waste and support sustainable design.

Producers are expected to submit their recyclability assessments starting in January 2025, in line with EPR’s implementation schedule.

Read our guide on the Recyclability Assessment Methodology (RAM)

Producers were initially required to label packaging as ‘Recycle’ or ‘Do not Recycle’ by March 2027. However, in October 2024, the UK government removed this requirement to support EPR rollout and ensure consistency for large producers operating in both the UK and EU.

Do you or your business require further information about EPR? Reach out to our team of experts to book a free EPR consultation to review your business needs.

Alternatively, if you are a Comply with Clarity member and require further information on the revised timetable and your responsibilities, please get in touch utilising the form below, your compliance manager will respond to any of your questions.