Extended Producer Responsibility: The Complete Guide

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.

Large producers submit packaging data twice per year: in April (covering July to December of the previous year) and in October (covering January to June of the current year).

Small producers submit once per year in April, covering packaging activities across the previous calendar year (January to December).

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*RPS update, the EA has delayed data collection until 1st January 2026, with reporting required by 1st April 2027

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.

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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 AND you’re responsible for supplying or importing more than 25 tonnes of packaging 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 packaging 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.

It must to be completed by a Companies House director within your business. If your business is not on Companies House, you must provide evidence that you are a senior contact. 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?

Understanding whether packaging is classified as household or non-household is a fundamental part of EPR. This distinction affects how you assess and report your packaging, and ultimately the fees you need to pay.

Household Packaging

Household packaging refers to materials that are typically thrown away by consumers at home and items commonly discarded in public bins. A category of household packaging is:

• Commonly binned: This is packaging that commonly ends up in public bins. For an exhaustive list of commonly binned items, please visit the government’s guidance on commonly binned packaging.

Household packaging classes include:

• Primary Packaging: For example cans, and boxes that hold products sold to consumers.
• Shipment Packaging: Packaging added to primary packaging for shipping products directly to homes.

If you supply household packaging, there are additional responsibilities to consider:

• Recyclability Assessment Methodology (RAM): Along with PRN costs, household packaging is subject to a Local Authority Waste Management fee to cover the costs of local authorities managing this waste. Household packaging needs to be assessed using the recyclability assessment methodology (RAM), which helps determine how recyclable the packaging is. This applies only to household packaging and influences modulated fees.

For more details, please refer to the government’s guidance on household packaging.

Non-Household Packaging

Non-household packaging is typically used by businesses or public organisations and does not end up in consumer waste. Packaging is automatically considered household until evidenced otherwise. Non-household packaging classes include:

• Secondary packaging, like the cardboard boxes used to group products for shipping between businesses.
• Tertiary packaging, such as pallets or shrink wrap used for transporting goods.

Packaging can also be classed as non-household if:

• It’s supplied directly to businesses or public organisations.
• It’s designed for business use and unlikely to end up in household bins.
• You, as the importer, dispose of the packaging without supplying it within the UK.

Producers need to keep records to show why packaging is classified as non-household. These records must be kept for at least seven years.

For more details, please refer to the government’s guidance on non-household packaging.

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

• Report data once a year in April for the previous year’s packaging activities (January-December).
• As a small producer, you will not be obligated to pay a Local Authority Waste Management fee, purchase PRNs or perform recyclability assessments.

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

• Report EPR packaging data 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 PackUK 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 sold, by nation within the UK once a year. The first Nation of Sale report has been delayed until October 2026.

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 non-household 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 (liquid and non-liquid)
• Glass
• Paper and cardboard
• Plastic (flexible and non-flexible)
• 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
• pack or fill goods in the UK that’s unbranded when it’s supplied
• supply products in packaging
• supply empty packaging
• own an online marketplace
• hire or loan out reusable 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 (household)
• is a drinks container (household or non-household)
• is reusable
• becomes self-managed waste (organisation or consumer)

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’.

Seller: An organisation that provides packaging direct to the end user.

With EPR waste collection costs and funding have changed. 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. Obligated producers are then responsible for the costs of collecting, sorting, and treating household packaging waste, covering the full net cost. The EPR Local Authority Waste Management Fee payment is issued after the government has processed H2 and is paid directly 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.

Modulated fees, also known as eco-modulation, are a key part of the UK’s Extended Producer Responsibility (EPR) system. They are designed to encourage more recyclable household packaging by adjusting Local Authority Waste Management fees based on recyclability performance.

Under the Recyclability Assessment Methodology (RAM), household packaging materials are assessed and assigned a red, amber or green outcome, which is then used to modulate the base fee. Packaging that is easier to recycle is expected to attract lower fees than packaging that is more difficult to recycle.

As part of EPR reporting obligations, producers are required to submit additional recyclability data for household packaging placed on the market. This information is used to determine how Local Authority Waste Management fees are modulated.

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.