Extended Producer Responsibility Explained: Who’s Affected and What to Do

Extended Producer Responsibility (“EPR”) is one of a number of policies being introduced in the UK. The Environment Act 2021 introduced EPR, as it contains a framework for introducing the scheme, which builds on existing waste laws, and gives producers of packaging more responsibility for the cost of managing products.

What is EPR and why is it important?

EPR will hold producers of packaging responsible for the collection, sorting, recycling, and disposal of the packaging they have placed on the market. Essentially, packaging producers will be responsible for the whole life cycle of packaging, all the way through to disposal.

Also, they will be responsible for funding the total cost of managing packaging waste on top of current obligations that already apply. This means that they will have to pay for all packaging they produce or import to the UK market, as well as the additional fees for waste disposal via households. Think of online retailers for example, they will now be responsible for the lifecycle and total costs of the packaging they send their goods out in.

These rules not only hold those responsible for packaging to account but also encourages those responsible to minimise the environmental impact of their packaging throughout its lifecycle and encouraging the use of circular economy principles.

It is estimated that in the UK, we dispose of approximately 12 million tonnes of packaging waste every year, with 64.8% of UK packaging waste in 2023 estimated to have been recycled (source). By putting the financial responsibility onto businesses, there will be greater incentives for producers of packaging to use recyclable materials and think about the environment within their processes.

Is your business obligated to comply with EPR?

The UK Government has specified that the EPR regulations will apply to all UK organisations that import or supply packaging.

Your business has a packaging waste obligation if ALL of the following points apply:

• You’re an individual business, subsidiary or group (but not a charity)   
• You have an annual turnover of £1 million or more
• You were responsible for importing or supplying more than 25 tonnes of packaging to the UK market in the previous calendar year  
• You carry out any of the packaging activities (as described on the UK Government website) 

What are your responsibilities under EPR?

EPR obligations differ for large and small organisations.

Large organisations may need to record data on packaging from 2023 to comply, as well as creating an account to report this data. From 2025, large organisations will need to comply with the following (based on 2024 data):

• Pay a waste management fee
• Pay scheme administrator costs
• Pay a registration charge to the environmental regulator (e.g. Environment Agency)
• Get packaging waste recycling notes (PRNs) or packaging waste export recycling notes (PERNs) to meet recycling objectives
• Report data about packaging that has been supplied or imported

Large organisations will also be required to report data every six months

For small organisations, to comply with EPR, you will need to report your 2024 data by 1 April 2025, with data being reported on an annual basis. Small organisations will NOT be required to pay the administration costs.

Both large and small organisations will be required to register with the Environment Agency and pay an annual fee.

What will the fees be for EPR?

DEFRA has published updated illustrative fees for year 1 of EPR.  It is important to note that fees will be additional to charges imposed by other environmental regulations across the UK.

The 2025/26 base fee rates vary depending on the material – The fee ranges by material types include:

• Aluminium packaging – £435 per tonne
• Fibre-based composite – £455 per tonne
• Glass – £240 per tonne
• Paper and card – £215 per tonne
• Plastic – £485 per tonne
• Steel – £305 per tonne
• Wood – £320 per tonne
• Other materials – £280 per tonne

The UK Government is currently in the process of calculating local authority costs to manage household packaging waste. This means that the range of fees reflects a current range of scenarios being considered for these costs.

What can your business do?

1. If you are a business who will be required to report under EPR, you may be required to report data in 2025, for packaging data from 2023 and/or 2024. It is important that you have this information, so make sure you are collecting this in advance, to prevent a last minute rush closer to the deadline.
2. Look at the products you are producing or importing to the UK market and identify hot spots and areas for improvement.
3. Where possible, incorporate the principles of the waste hierarchy and the circular economy – prevent packaging where it is not needed and encourage reuse and recycling.
4. Engage and collaborate with your supply chain to ensure everyone is aware of the new regulations and see where there are opportunities to improve efficiency.

For more information or to explore how Action Sustainability can support your organisation, please contact our team.