The UK’s extended producer responsibility (EPR) scheme is transforming how businesses deal with packaging waste. If your organisation places packaged goods on the UK market, you may now have greater financial responsibility for what happens to that packaging once it becomes waste.

Under the extended producer responsibility legislation, many UK organisations must now collect packaging data, report packaging data, and help fund waste management and recycling systems. The aim is to shift the cost of managing packaging waste away from taxpayers and towards the businesses that produce or supply packaging.

In this guide, we explain what is EPR, why the extended producer responsibility EPR scheme has been introduced, and how the EPR regulations affect companies that supply packaged goods, import packaging, or handle packaging materials across the supply chain. We also cover packaging data reporting, nation data, and what businesses must do to achieve EPR compliance.

Table of Contents

• Understanding Extended Producer Responsibility for Packaging
• What Is EPR?
• Why Has Extended Producer Responsibility Been Introduced?
• Is Your Business Affected by EPR?
  • Small Organisations
  • Large Producers
• Household Packaging vs Non-Household Packaging
• Packaging Activities That May Require Action
  • Own Brand Products
  • Importing Products in Packaging
  • Supplying Empty Packaging
• Key EPR Data Reporting Deadlines
• What Do Businesses Need to Do Under EPR?
• How Kite Packaging Can Help

Understanding Extended Producer Responsibility for Packaging

The extended producer responsibility (EPR) system is changing how businesses handle packaging waste in the UK. Under the new extended producer responsibility legislation, organisations that place packaged goods on the UK market must take greater financial responsibility for what happens to that packaging after it is used.

This means businesses must contribute to the cost of managing packaging waste, including waste management, recycling, and collection. Instead of local governments carrying most of the cost, packaging producers and organisations within the supply chain now share that responsibility.

The extended producer responsibility EPR scheme replaces parts of the current packaging waste regulations and introduces stricter requirements for packaging data, reporting, and environmental accountability. The goal is to reduce household packaging waste, improve recycling processes, and encourage more sustainable packaging across the UK market.

Under the extended producer responsibility system, businesses must:

• Collect packaging data on the packaging materials they place on the UK market
• Report packaging data through official data reporting processes
• Contribute towards waste management fees and recycling costs
• Improve packaging design using more recyclable materials
• Support better recycling efforts and infrastructure in the UK

These EPR regulations aim to create a more transparent and accountable approach to packaging waste management, while also supporting the development of a circular economy.

What Is EPR?

So, what is EPR in practical terms?

Extended producer responsibility (EPR) is a government policy that makes businesses responsible for the entire lifecycle of their packaging waste. This includes the design, use, and disposal of packaging used to supply packaged goods on the UK market.

Previously, most waste management costs were funded by taxpayers through local governments. The extended producer responsibility EPR framework changes this by requiring packaging producers and organisations across the supply chain to cover those costs directly.

Businesses affected by extended producer responsibility must now:

• Record data on their packaging materials and packaging components
• Report packaging data through official data submission systems
• Pay waste management fees linked to the amount and type of packaging supplied
• Continue to purchase packaging recovery notes to meet recycling obligations
• Review packaging design and consider more sustainable packaging choices

These new rules mean businesses must think more carefully about how they supply packaging, import goods, or import packaging when placing products on the UK market.

By shifting responsibility to producers, the UK government hopes to reduce unnecessary packaging, improve recycling rates, and ensure companies take greater environmental responsibility for their products.

Why Has Extended Producer Responsibility Been Introduced?

The introduction of extended producer responsibility addresses several problems with the current packaging waste regulations and earlier recycling frameworks.

For many years, the UK relied on the Packaging Waste Regulations 2007 and a system that required businesses to purchase packaging recovery notes. While this approach helped increase recycling rates, it did not fully cover the cost of managing packaging waste.

In fact, the system only funded a small portion of the real waste management costs associated with household packaging waste.

Some of the key issues included:

• Limited connection between packaging recovery notes and actual recycling efforts
• Large volumes of packaging waste exported overseas instead of recycled domestically
• PRN prices fluctuating due to market demand rather than true recycling costs
• Little incentive for businesses to use sustainable packaging or recyclable materials

These challenges highlighted weaknesses in the UK’s recycling system and slowed progress towards a stronger circular economy.

The extended producer responsibility legislation aims to address these issues by:

• Making packaging producers financially responsible for managing packaging waste
• Encouraging better packaging design and sustainable packaging choices
• Increasing investment in UK recycling infrastructure and waste management systems
• Improving transparency through mandatory packaging data submission and data reporting

By strengthening EPR compliance and improving data collection, the government hopes to create a more effective and sustainable extended producer responsibility system for businesses operating in the UK.

Is Your Business Affected by EPR?

Not every organisation must follow the same extended producer responsibility (EPR) obligations. Whether your business needs to act depends mainly on business turnover and the amount of packaging supplied to the UK market.

In general, UK organisations may be affected if they:

• Have an annual business turnover of £1 million or more
• Handle or supply packaged goods containing at least 25 tonnes of packaging materials per year
• Import packaging or packaged products into the UK
• Supply packaging as part of their operations within the supply chain

Businesses are then classed as either a large or small organisation, which determines their EPR regulations and reporting requirements.

Small organisations

A business is usually considered a small organisation if it:

• Has a business turnover between £1 million and £2 million
• Handles between 25 and 50 tonnes of packaging materials annually

Small organisations must still collect packaging data and report packaging data, but they are not required to pay the full waste management fees under the extended producer responsibility EPR scheme.

Large producers

Large producers face greater responsibilities under extended producer responsibility legislation. A company is normally classed as a large organisation if it:

• Has a business turnover above £2 million
• Handles more than 50 tonnes of packaging materials each year

These large producers must report packaging data, submit nation data, and contribute financially to waste management systems for household packaging waste.

Household Packaging vs Non-Household Packaging

Understanding whether packaging is classed as household packaging is an important part of extended producer responsibility (EPR).

In simple terms, household packaging refers to packaging that is likely to end up in homes or public bins after a product is used. This type of packaging waste forms a major part of the extended producer responsibility system, as businesses must help fund the waste management of these materials.

Examples of household packaging include:

• Food containers and drink bottles
• Delivery and cardboard boxes used for online orders
• Product wrapping and protective packaging
• Packaging used to sell packaged goods directly to consumers

By contrast, non household packaging typically refers to packaging used within business environments.

Examples include:

• Secondary packaging used to group products together
• Tertiary packaging or tertiary packaging material, such as pallets or shrink wrap used during transportation
• Packaging used within warehouses or distribution centres

While tertiary packaging and other business-use materials may not incur the same waste management fees, businesses must still include them when they collect packaging data and report packaging data under EPR compliance rules.

Correctly identifying whether packaging is household or non-household is essential when reporting packaging data and nation data, as it determines how extended producer responsibility obligations apply.

Packaging Activities That May Require Action

If your business carries out certain packaging activities, you may need to follow extended producer responsibility (EPR) rules and report packaging data.

Common packaging activities that may require action include:

• Placing packaged goods on the UK market under your own brand
• Packaging goods or handling packaging directly within your operations
• Import packaging or import packaged goods from outside the UK
• Supplying empty packaging to other businesses
• Operating an online marketplace that allows overseas sellers to reach UK customers
• Providing or managing reusable packaging or reusable packaging supply systems
• Hiring or loaning packaging through an online marketplace hire model

Own brand products

If you sell packaged goods under your own brand, your organisation may be responsible for the packaging placed on the UK market. This includes products manufactured by another company but labelled with your brand.

Importing products in packaging

If your organisation imports products or import packaging, you may still be responsible for the packaging supplied to the UK market, even if another company filled or packaged the goods.

Supplying empty packaging

Businesses that manufacture or supply empty packaging such as boxes, trays, or other packaging materials may also fall within the extended producer responsibility EPR framework.

Understanding these packaging activities is important for identifying your obligations under the extended producer responsibility legislation.

Key EPR Data Reporting Deadlines

Under extended producer responsibility regulations, businesses must report packaging data and complete data reporting within specific timeframes. These deadlines form part of the official packaging data submission process.

Date	Obligation
1 October 2023	Large producers submit January–June 2023 packaging data
1 April 2024	Large producers submit July–December 2023 packaging data
1 October 2024	Large producers submit January–June 2024 packaging data
1 April 2025	Large producers submit July–December 2024 packaging data
April 2025	Small organisations report packaging data for all 2024 activities
October 2025	Large producers begin paying waste management fees under EPR

Businesses must ensure they collect data, report data, and submit nation data correctly and on time to maintain EPR compliance.

Failure to meet these data reporting requirements could lead to penalties or regulatory action.

What Do Businesses Need to Do Under EPR?

If your organisation supplies packaging, imports products, or places packaged goods on the UK market, you may need to follow several requirements under extended producer responsibility (EPR).

Businesses affected by EPR regulations may need to:

• Collect packaging data on the packaging materials they use
• Record data on packaging weight and packaging components
• Report packaging data through official data submission systems
• Submit nation data showing where packaging is sold or discarded
• Pay waste management fees linked to household packaging waste
• Continue to purchase packaging recovery notes to meet recycling obligations

Accurate data collection and data reporting are essential to the extended producer responsibility system, helping regulators understand how packaging waste moves through the supply chain.

By improving packaging data reporting and encouraging more sustainable packaging, the UK government aims to strengthen recycling infrastructure and reduce the environmental impact of packaging waste.

How Kite Packaging Can Help

Navigating extended producer responsibility (EPR) and meeting packaging data and data reporting requirements can be challenging for many businesses. Working with a trusted compliance scheme can make the process much easier, helping organisations manage packaging waste, meet reporting deadlines, and stay aligned with extended producer responsibility legislation.

Through Kite Environmental Solutions, our specialist compliance scheme, we support businesses with EPR compliance, including guidance on packaging data submission, purchasing packaging recovery notes, and understanding waste management fees. If you need help understanding your obligations under extended producer responsibility, contact our team today to discuss how we can support your business.