The e-commerce seller’s guide to EPR in the UK

At the end of June 2025, the UK government published the 2025 base fees for the EPR scheme and the first Fee Modulation Policy Statement (PDF), outlining how fees will be adjusted from 2026 based on how recyclable a producer’s packaging is.

Based on 2024 packaging data, these charges mark a major shift in how packaging waste is managed and paid for. With new rules, new responsibilities, and new costs, it’s more important than ever for e-commerce sellers and other producers to understand what EPR means, who it applies to, and how to stay compliant – which we’ll outline in this guide.

When did the UK introduce EPR? 

The UK introduced EPR for packaging in stages starting in 2023, replacing older legislation. If your business sells products in packaging (like boxes or bottles) in the UK, you may be required to register and follow EPR rules. This is especially important for large online sellers who use a lot of packaging.

To comply, you must: 

• Track how much packaging you use 

• Report it to the government 

• Pay fees to support recycling and waste services 

What is EPR and how does it apply to packaging? 

Extended Producer Responsibility (EPR) is a framework, part of the wider circular economy push, that makes businesses responsible for the packaging they use – from when it’s made to when it’s thrown away.  Read our full introduction to EPR legislation.

In the UK, this means companies must pay for the full cost of dealing with their packaging waste, including collecting, recycling, or disposing of it. The aim is to encourage more eco-friendly packaging and ensure businesses, not customers, cover the costs. 

Who’s defined as a packaging producer under UK EPR law? 

Not every business that handles packaging must follow EPR rules. The law applies to certain roles and activities.

You are a packaging producer if your business does any of the following: 

• Brand owner – You make or sell products under your own brand name in the UK. You are responsible for the packaging. If you make products for someone else’s brand, they are responsible. 

• Packer or filler – You put products into packaging, either for your own business or for others. For instance, if you run a fulfilment centre, you may be responsible. 

• Importer – You bring packaged goods into the UK from abroad and sell or supply them into the UK. You are responsible for the packaging, even if you remove some of it before selling. 

• Distributor of empty packaging – You make or import empty packaging (like boxes or bottles) and sell it to someone who isn’t already responsible under EPR. In that case, you may be responsible. 

• Online marketplace that lets non-UK sellers sell to UK customers – If those sellers don’t have a UK presence, you are responsible for their packaging. This doesn’t apply if all your sellers are UK-based, but you might still have other obligations. 

• Service provider (reusable packaging) – You rent or lend reusable packaging (like pallets or crates) to other businesses. Under EPR, you are responsible for that packaging. 

• Seller to UK end user – Sometimes, the retailer selling to the final customer is responsible. For example, if the brand owner is not based in the UK, the first UK seller may be considered the producer. 

What are the thresholds for UK EPR obligation and registration?

Even if your business does activities covered by EPR, you only need to follow the rules if you meet certain size limits. These are based on your annual turnover and how much packaging you handle (by ton): 

Lower threshold 

You must follow EPR rules if your business had both: 

1. a turnover of at least £1 million (based on your latest accounts up to April)
2. handled more than 25 tonnes of packaging in the previous calendar year. 

If you’re below either of these, you don’t need to comply. 

Small and large producers – which are you?

• Small producer – If your turnover is between £1 million and £2 million, and you handled more than 25 but no more than 50 tonnes of packaging.

• Large producer – If your turnover is £2 million or more, and you handled over 50 tonnes of packaging. Large producers have to meet all EPR requirements and pay full fees. 

💡As an example: An online shop with £5 million turnover and 40 tonnes of packaging in 2024 is a small producer. If their packaging goes over 50 tonnes, they become a large producer. 

Groups and parent-subsidiaries 

If your business has several UK companies under one group, the rules apply to the whole group. You can choose to register as a group or separately, but the size limits are based on the total across all companies. You can’t avoid EPR by splitting into smaller parts.  

If the group goes over £1 million and 25 tonnes, all parts that handle packaging must comply—even if some are under the limit on their own. 

Packaging data collection and reporting: a key EPR requirement 

You must regularly collect and report data about your packaging to the regulators. This helps the government calculate recycling fees and track progress with recycling targets.  

Here’s what you need to do: 

• Track your packaging and collect specific data – You must record the type and weight of all packaging you supply or import. Break it down by: 

• material (like plastic, paper, or glass) 

• type (household or business use)  

• class (primary, secondary, tertiary, or transport packaging).  

You must also note your role (e.g. brand owner or importer) for each item. 

When do you need to report your data according to the government’s deadlines?

• Large producers must report twice a year: 1 October (for January–June data)  and 1 April (for July–December data) 

• Small producers report once a year by 1 April (for the previous calendar year). 

• Report ‘nation data’ – You must also report where in the UK your packaging is sold and likely thrown away (England, Scotland, Wales, or Northern Ireland). This ‘nation data’ helps divide recycling costs fairly. Your systems will need to track customers’ locations or distribution of sales by country. The first nation data report (for 2024) is due by 1 December 2025. After that, it’s due every April. 

• Keep good records – You must keep all data and evidence (like weights, invoices, and calculations) for at least 7 years. A responsible person (like a director or approved compliance manager) must confirm that your data is accurate. Mistakes or false reports can lead to penalties, so double-check everything and keep a clear record of how you worked it out. 

What are the financial responsibilities and recycling costs of EPR? 

EPR is mainly about making businesses pay for the environmental impact of their packaging. If you’re a large producer, you’ll need to budget for several types of fees: 

• Waste management fees – This is the main EPR charge. It covers the cost of collecting, sorting, and recycling your packaging waste. The government has developed a Recyclability Assessment Methodology to determine fee rates for different packaging materials. From 2024, you’ll be charged based on how much household packaging you use and how recyclable it is. For example, cardboard is cheaper to recycle than plastic pouches, costing less. DEFRA (Department for Environment, Food and Rural Affairs) updates their illustrative fees every year so you can plan ahead.  

• Environment Agency registration fee – Every business that must follow EPR rules has to pay a flat yearly fee to the environmental regulator. This fee is separate from the recycling costs. If you’re in a compliance scheme, they might pay it for you, but you’ll still be charged. 

• Scheme administrator costs – The UK government has set up a central EPR scheme administrator body, PackUK, to manage EPR funds and reimburse local councils for recycling. A small part of your waste fee goes towards running this system. 

• Recycling evidence under the Packaging Recovery Note (PRNs/PERNs) systems – This is a longstanding feature of UK packaging law that still exists under EPR. You still need to prove that a certain amount of your packaging has been recycled. This is done by buying PRNs (or PERNs for exports) from approved recyclers. You can do this yourself or through a compliance scheme (more on those shortly), but you’ll still need to be legally compliant. These costs are on top of your waste fees.  

• Compliance scheme membership fees – If you join a compliance scheme, they’ll charge you for their services. This includes help with data reporting, buying PRNs, and general support. You’re not legally required to join a scheme, but many businesses do this to ease the workload.  

Who are the agencies and compliance schemes involved with packaging EPR in the UK? 

Several organisations help run and enforce the EPR system. Environmental regulators are the official bodies that make sure businesses follow the rules. Depending on where you’re based, your regulator will be: 

• Environment Agency (England) 

• Natural Resources Wales

• Scottish Environment Protection Agency

• Northern Ireland Environment Agency

They monitor registrations, reports, and recycling targets. They can also audit your business and issue penalties. When you register online, your details go to the right regulator. You would contact the regulator for compliance questions or if you need to report any issues, such as missed deadlines. 

What does the EPR scheme administrator do?

As we’ve mentioned, PackUK is the central scheme administrator managing the EPR programme in the UK. It collects producer fees and pays local councils to cover household recycling costs. It also helps set EPR for packaging (pEPR) fee rates.

You won’t usually deal with them directly, but part of your fees goes towards their work. 

How do compliance schemes help with EPR compliance

These third-party organisations help you meet your EPR duties. If you join one, they can: 

• Submit your data 

• Register you with the regulator 

• Buy PRNs (proof of recycling) for you 

• Offer advice and tools to stay compliant 

Even with a scheme, you still have some responsibilities: 

• You must register yourself on the government EPR portal 

• You usually pay your EPR fees directly to the authorities 

• You are legally responsible for compliance, even if a scheme helps you 

Make sure any scheme you join is accredited and reports accurately on your behalf. Check the list of accredited schemes on the National Packaging Waste Database. 

❗What are the penalties for non-compliance with EPR in the UK? 

If you don’t follow the UK’s EPR rules, you could face serious penalties, which can include: 

• Fines (civil penalties) – For not registering, not reporting data, or not paying fees. 

• Criminal charges – For more serious or repeated offences. 

The Environment Agency and other regulators have the power to issue these penalties. 

• Late fees – If you miss a reporting deadline (like for nation data), you may be charged a late fee and asked to submit the data quickly. 

• Ongoing issues – If you keep missing deadlines or your data is wrong, the penalties can become more severe. 

UK EPR compliance: key dates, timeline and deadlines

Here’s a quick overview of important dates for the UK’s packaging EPR scheme: 

2023 – Transition year 

EPR for packaging officially began, and large producers started collecting packaging data that January. They had to submit their first reports later that year.

The government delayed EPR fees for a year until 2024, but data collection still had to happen. Small producers were told to start tracking data, even though they didn’t need to report until 2024. 

2024 – Reporting begins 

All affected businesses should have registered on the EPR portal. 

Large producers submitted two reports: 

• January–June data by 1 October 2024 

• July–December data by 1 April 2025 

Small producers submitted their first full-year report (for 2024) by 1 April 2025.  No EPR fees were charged yet – 2024 data is used to calculate 2025 fees. 

2025 – First EPR fees 

This is the first year producers must pay EPR waste fees:

• Fees are based on 2024 data

• Invoices are expected by late 2025

• Large producers must report January–June 2025 data by 1 October 2025

• All producers report 2025 data by 1 April 2026

• The first “nation data” report (for 2024) is due by 1 December 2025

2026 and beyond 

The EPR system will be fully up and running:

• Reporting continues every year. 

• Fees are charged based on the previous year’s data. 

• New requirements may be added—for example, clearer recycling labels are expected by 2027. 

♻️ UK EPR: your 9 strategies for compliance

1. Identify whether your business is a packaging producer under EPR rules – such as a brand owner, importer, packer, or online marketplace.
2. Check if you meet the thresholds for the the size limits (turnover and packaging tonnage) that trigger EPR obligations. This helps you know whether you’re classed as a small or large producer.
3. Register on the EPR portal: All obligated producers must register with the government’s EPR system. Even if you join a compliance scheme, you must complete this step yourself.
4. Track your packaging data on the type, weight, and use of all packaging you supply or import. Break it down by material, packaging type (household or business), and class (primary, secondary, etc.).
5. Report on time and send in your data by the required deadlines:
   • Large producers: twice a year (1 April and 1 October)
   • Small producers: once a year (1 April)
   • Nation data: by 1 December each year
6. Keep accurate records such as supporting documents (like invoices and weight calculations) for at least 7 years. A responsible person must confirm the accuracy of your reports.
7. Budget for EPR-related costs, including:
   • Waste management fees (based on recyclability)
   • Registration fees
   • PRNs/PERNs (proof of recycling)
   • Compliance scheme membership (if applicable)
8. Consider joining a compliance scheme which could help manage your reporting, PRN purchases, and data submissions (but you remain legally responsible)
9. Stay informed on updates to EPR rules, fee rates, and future requirements like recyclability labelling or digital product passports.

EPR in the UK: your key takeaways

Ensuring compliance with the UK’s EPR requirements will be a continuous process, integrated into your business operations year after year.

If your business places packaging on the UK market and meets particular criteria, you may now be legally required to register, report detailed data, and cover the full cost of recycling and disposal.

With the first official fees announced in 2025 and more changes expected in the years ahead, staying informed and compliant is essential. Whether you’re a small seller or a large online retailer, understanding your role, tracking your packaging, and meeting deadlines will help you avoid penalties and contribute to a more sustainable future.