Why platforms are now firmly in scope and what compliance really looks like in practice
Online marketplaces have become one of the most significant routes by which goods and packaging enter the UK. In under 30 years, e-commerce in the UK has grown from around 1% of total retail sales in 2000 to almost 30% by 2024, peaking at close to 40% during the Covid pandemic. Globally, nearly half of all digital purchases are now made through online marketplace platforms, rather than individual retailer websites.
This growth has fundamentally changed how regulators view responsibility. Under the UK’s evolving Extended Producer Responsibility (EPR) framework, online marketplaces are no longer treated as neutral intermediaries. Instead, they are increasingly recognised as obligated producers, with direct legal, financial and reporting responsibilities for packaging and products placed on the UK market via their platforms.
For large platforms such as Amazon, as well as rapidly growing marketplaces like Temu, EPR compliance is now a strategic operational issue – not a peripheral regulatory concern.
Why online marketplaces are now in scope
The rapid rise of cross-border e-commerce has exposed long-standing weaknesses in producer responsibility legislation. Historically, non-UK sellers were able to sell goods directly to UK consumers without registering, reporting packaging data, or contributing to recycling costs.
UK policy has moved decisively to close this gap.
Under current UK rules, an online marketplace (OMP) is defined as a UK-based business operating a website or app that enables third-party sellers to sell goods to UK consumers. Where those sellers are non-UK based and not themselves compliant with UK packaging regulation, responsibility now transfers to the marketplace.
This principle has applied under packaging EPR since 2024 and was extended further in August 2025, when online marketplaces were formally recognised as producers under the UK WEEE Regulations for electrical and electronic equipment sold by non-UK sellers.
Together, these reforms form part of a wider shift toward ensuring that all businesses benefiting from access to the UK market contribute fairly to the environmental costs they create.
Packaging EPR: how it applies to online marketplaces
Extended Producer Responsibility for packaging makes obligated producers responsible for the full net cost of managing household packaging waste, including collection, sorting, recycling and disposal.
An online marketplace is treated as a packaging producer where it enables non-UK sellers to place packaged onto the UK market. In those cases, the marketplace effectively assumes the producer role that would otherwise sit with the overseas seller.
This means online marketplaces may be required to:
- Register on the Report Packaging Portal (RPD)
- Collect and submit detailed packaging data
- Report packaging by material, class and waste stream
- Pay EPR waste management fees
- Purchase recycling evidence (PRNs/PERNs)
- Retain records and evidence for at least seven years
Importantly, UK-based sellers using an online marketplace remain responsible for their own EPR obligations. Marketplaces therefore operate in a hybrid compliance environment, managing obligations for some sellers but not others – a complexity that requires careful data segmentation and governance.
Thresholds, producer size and group rules
Packaging EPR obligations apply once specific thresholds are met. These thresholds are particularly relevant for large platforms and marketplace groups.
A business must comply with packaging EPR if it has:
- Turnover of £1 million or more, and
- Handled more than 25 tonnes of packaging in the previous calendar year
Producers are then categorised as:
- Small producers: £1-2 million turnover and 25–50 tonnes of packaging
- Large producers: £2 million+ turnover and more than 50 tonnes of packaging
Large producers are subject to the full scope of EPR obligations, including waste management fees.
For corporate groups, thresholds apply across all UK group entities combined, preventing obligations from being avoided by splitting activities across subsidiaries.
Data reporting: the backbone of marketplace compliance
At the heart of EPR is data accuracy – and for online marketplaces, this is where compliance becomes particularly demanding.
Marketplaces must collect and report packaging data broken down by:
- Material type (e.g. plastic, paper, glass)
- Packaging class (primary, secondary, tertiary, transport)
- Waste stream (household vs non-household)
- Producer role
- UK nation where packaging is likely to become waste
Large producers must report twice a year, while small producers report annually. All obligated producers must retain robust audit trails and evidence, with a named responsible person confirming accuracy.
Given the scale and diversity of seller activity on large platforms, maintaining accurate, auditable and defensible data is one of the biggest risks marketplaces face.
Nation of sale and self-managed waste: what online marketplaces need to know
A core element of packaging EPR is understanding where packaging is likely to become waste within the UK. This is known as nation of sale data and is used to apportion recycling costs fairly between England, Scotland, Wales and Northern Ireland.
For online marketplaces, collecting this information can be particularly complex, given the volume of transactions, multiple fulfilment routes, and the mix of UK and non-UK sellers operating on a single platform.
Recognising these challenges, regulators have issued Regulatory Position Statement RPS 330, setting out a revised approach to the introduction of nation of sale and self-managed organisational waste requirements.
Under the current regulatory position:
- Nation of sale and self-managed waste data collection is expected to begin from 1 January 2026
- Reporting of this data will be required on or before 1 April 2027
- Regulators have confirmed a proportionate enforcement approach during this interim period, provided producers are taking reasonable steps to prepare their systems
For marketplaces, this period should be treated as a preparation window, not a pause. Platforms are expected to assess data availability, review seller information flows, and implement systems capable of supporting nation-level reporting once mandatory.
The financial reality: EPR fees and cost exposure
From 2025 onwards, EPR introduces real financial liabilities for obligated producers.
Key cost elements include:
- Waste management fees, based on household packaging volumes
- Fee modulation, from 2026, linking costs based on recyclability
- Environment Agency registration fees
- Scheme administration costs
- PRN/PERN costs, which remain a legal requirement alongside EPR
Packaging that is harder to recycle will attract higher fees, meaning that packaging design, material choice and seller packaging standards now have direct cost implications for online marketplaces.
For platforms managing thousands of sellers, small inefficiencies in packaging choices can scale into significant financial exposure.
WEEE: expanding producer responsibility beyond packaging
In August 2025, UK WEEE regulations were updated to explicitly include online marketplaces as producers for electrical and electronic equipment sold by non-UK sellers
This requires marketplaces to:
- Register under the WEEE Regulations
- Report EEE placed on the UK market
- Finance collection, treatment and recycling of waste electricals
- Engage with approved compliance schemes
This change mirrors the policy direction under packaging EPR: ensuring that environmental obligations cannot be avoided through cross-border online sales.
Why online marketplaces need specialist compliance support
While producers can technically comply independently, the operational reality for online marketplaces is very different from that of traditional brand owners or retailers.
Marketplaces must manage:
- Large volumes of third-party sellers, often with limited compliance knowledge
- Rapid product onboarding and delisting
- Inconsistent packaging specifications
- High-volume, fast-moving data flows
- Multiple regulatory regimes (packaging, WEEE, batteries)
As regulation tightens and enforcement increases, compliance failures carry not just financial penalties but reputational risk.
Why online marketplaces work with Clarity
Clarity supports complex producer models where scale, data quality and regulatory overlap are central challenges.
For online marketplaces, Clarity provides:
- Marketplace-ready data management built for high-volume reporting
- Integrated support across packaging EPR, WEEE and PRNs
- Active PRN trading capability, supporting cost control and transparency
- Ongoing regulatory insight as requirements evolve
- Practical, defensible compliance delivery – not just annual reporting
As EPR continues to expand and evolve, online marketplaces need more than a reporting service – they need a compliance partner that understands how platforms operate.
Looking ahead: compliance as a platform responsibility
The growth of online marketplaces shows no sign of slowing. At the same time, UK environmental regulation is becoming more detailed, more costly and more closely enforced.
For online marketplaces, producer responsibility is now embedded in platform governance. Those that invest early in strong systems, robust data and specialist compliance support will be better placed to manage cost, reduce risk and demonstrate leadership in a rapidly evolving regulatory landscape.
