The UK’s Extended Producer Responsibility (EPR) scheme for packaging is a government policy that shifts the full financial responsibility for managing packaging waste (including collection, sorting, and recycling) from local authorities and taxpayers onto the businesses that first place the packaging on the UK market (the ‘producers’).

This document summarises who is affected and outlines the core obligations, with a focus on employer responsibilities.

Who is Affected? (The Obligation Thresholds)

Your organisation is likely considered a packaging “producer” and has legal obligations under EPR if all the following criteria apply:

• Business Type: You are an individual business, subsidiary, or group (but not a registered charity).
• Turnover: You have an annual turnover of 1 million or more (based on your most recent annual accounts).
• Tonnage: You were responsible for handling or supplying more than 25 tonnes of empty packaging or packaged goods to the UK market in the preceding calendar year.

Packaging Activities that Trigger Obligation

Even if you meet the turnover and tonnage thresholds, you are only obligated if you carry out one or more of the following activities in relation to the UK market:

• Brand Owner: You supply packaged goods under your own brand name.
• Packer/Filler: You pack or fill goods in packaging that is unbranded when supplied.
• Importer: You import packaged products into the UK for onward supply.
• Online Marketplace Operator: You operate a website or app that allows non-UK businesses to sell packaged goods directly to UK consumers.
• Supplier of Empty Packaging: You supply empty packaging to an organisation that is not legally obligated under EPR.
• Reusable Packaging: You hire or loan out reusable packaging (e.g. pallets).

Producer Categories and Core Obligations

Obligated producers are divided into two categories, Small Producers and Large Producers, which determine the extent of their obligations.

Category	Turnover Threshold	Tonnage Threshold	Key Obligations
Small Producer	£1 million +	25 to 50 tonnes	Reporting Only (Annual Data Submission, must register).
Large Producer	£2 million +	50 tonnes +	Reporting and Financial Obligation (Biannual Data, Pay Fees, Purchase PRNs).

Specific Employer Obligations (The ‘What to Do’)

The core obligations for an affected employer fall into four main areas:

Mandatory Registration

All obligated producers (both small and large) must:

• Enrol: Register on the Report Packaging Data (RPD) service on the Gov.uk portal to obtain an Organisation ID.
• Approved Person: Ensure this registration is completed by an approved individual, typically a Director or Company Secretary listed on Companies House.

Detailed Data Collection and Reporting

This is the foundation of the EPR scheme and is the primary task required of the employer (the producer). You must meticulously track and record data for all packaging handled or supplied throughout the UK.

Data Requirement	Description
Activity	How the packaging was put on the market (e.g. as a brand owner, importer, etc.).
Material & Weight	The weight (in kilograms) of all materials used (e.g. plastic, paper/card, glass, aluminium, wood).
Packaging Class	Whether the packaging is Primary (sells the product), Secondary (groups items), Shipment (delivery box), or Transit/Tertiary (transport protection).
Waste Stream	Whether the packaging is household (likely to end up in local authority bins) or non-household (commercial/industrial waste).
Nation Data	Large producers must report which UK nation (England, Scotland, Wales, or Northern Ireland) the packaging was supplied in and where it is likely to be discarded.

Financial Obligations (For Large Producers Only)

Large producers must comply with two primary financial obligations:

• Waste Management Fees: Payment of fees to the Scheme Administrator (PackUK) to cover the full cost of collection, sorting, and disposal for all household packaging. These fees are calculated based on the type and weight of packaging reported and are modulated to be cheaper for packaging that is easier to recycle (the “polluter pays” principle).
• Recycling Obligations (PRNs):Producers must continue to purchase Packaging Recovery Notes (PRNs) or Packaging Export Recovery Notes (PERNs) to demonstrate that they have met their legal requirement to ensure a specific weight of packaging is actually recycled.

Consumer Information (Future Obligation) 

Employers are responsible for ensuring that packaging is clearly labelled with appropriate recycling instructions to inform consumers how to correctly dispose of the packaging (known as the Bin Labelling Requirement, expected to become mandatory from 2027). 

Contact sally@giraffeassociates.com to understand how we can support you on this.