UK Extended Producer Responsibility (EPR) - what you need to know

What is the UK Extended Producer Responsibility (EPR) for packaging?

The UK Extended Producer Responsibility (EPR) for packaging is legislation that makes businesses legally and financially responsible for the collection, sorting, treatment, recycling, and disposal of the packaging they place on the UK market.

The EPR transfers the responsibility and the net cost of managing packaging waste from the taxpayer to brand owners and producers. The aim is that the direct cost of packaging recycling should be met by those placing the packaging onto the UK market.

From 2025, producers will cover the full costs of packaging waste management through new fees, reporting obligations and modulated charges based on recyclability.

Producers and importers will continue to fund the recycling of their packaging waste through purchasing of Packaging Recovery Notes (PRNs). The EPR will fund the collection, treatment and sorting costs of packaging waste through direct payments from those producers.

The EPR aims to incentivise more sustainable packaging choices by producers. The EPR will also support local authorities by funding more effective management of packaging waste and will help the UK meet their objectives under the Circular Economy Package (CEP).

Who must comply with UK EPR packaging regulations?

You need to take action if all of the following apply:

• you’re an individual business, subsidiary or group
• you have an annual turnover of £1 million or more
• you’re responsible for over 25 tonnes of packaging in a calendar year
• you carry out any of these:
  • packaging own-brand products to sell to UK consumers
  • using a third party to package and sell own-brand goods to UK consumers
  • using 'transit packaging' to protect goods during transport so they can be sold to UK consumers
  • hiring or loaning out reusable packaging to UK third parties

How to comply with the UK EPR scheme: Compliance Rules

Small organisations

Definition: If your annual turnover is between £1m and 2 m and you supply less than 25m tonnes of packaging, OR, your packaged goods are less than £1m and you supply between 25-50 tonnes of packaging or packaged goods.

• You should create or already have an online account for your organisation on the EPR packaging online service. 
• You must collect, record and submit data on the empty packaging and packaged goods you handle and supply through the UK market annually.
• 1st April 2025 - was the deadline to register for the EPR packaging online service and submit 2024 data 
• 1st April 2026 - is the deadline to submit 2025 data.

Large organisations

Definition:  If your annual turnover is £2 million or more AND you are handling and supplying more than 50 tonnes of empty packaging or packaged goods in the UK.

• You should create or already have an online account for your organisation on the EPR packaging online service. 
• You must collect, record and submit data on the empty packaging and packaged goods you handle and supply through the UK market every 6 months.
• 1st October 2024 - was the deadline for submitting 2024 data.
• 1st April 2025 - was the deadline to submit your data from Jul 24 to Dec 24.
• 1st October 2025 - was the deadline to submit your data from Jan 25 to Jun 25. 

Contact your environmental regulator if you have missed any deadlines.

EPR Fees for UK Businesses 

From 2025 you may have to do the following based on your 2024 data. 

• Pay a registration fee to the environmental regulator.
• Obtain PRNs or PERNs to meet your recycling obligations.
• Pay a waste management fee
• Pay scheme administrator costs. 

Source: Packaging waste - prepare for extended producer responsibility

How Much Are EPR Registration Fees? 

What you have to pay depends on the size of your organisation. In 2025, large organisations pay £2,620 and small organisations £1,216. If you register after the deadline you have to pay an additional fee of £332. 

There are different registration fees if you join a compliance scheme and extra fees for groups and subsidiaries as well as online marketplaces. Read more about EPR registration fees from the gov.uk website. 

How Much Are Waste Management Fees?

Waste management fees are the charges you pay for the packaging you put on the market. They’re worked out using the information you report. For  2025, the fees will be based on your 2024 packaging data, with invoices sent from autumn 2025. The cost depends on the type of material your packaging is made from and how much it weighs. Base fees per tonne for packaging include paper/card (£196), plastic (£423), aluminium (£266), and wood (£280). Find a full list of base fees. 

In April 2026 modulated fees will be introduced. The Recyclability Assessment methodology (RAM) assigns red, amber or green rating to materials. Higher fees will be charged for red materials and lower for green.

EPR Costs Shift: UK Businesses Face Up to 5x Higher Compliance Fees 

Under EPR legislation, responsibility now sits with one company. Producers will fund the net cost of the collection, sorting and treatment of packaging waste. These costs are  estimated to be around £1.4bn.

Under the previous producer responsibility system, compliance and recycling  costs were shared throughout the supply chain, with a percentage responsibility allocated at different points. The biggest change under the EPR framework is the percentage responsibility for PRNs are no longer spread throughout the supply chain. Therefore, some larger businesses are likely to see their compliance costs rise to more than five times their current obligations, if not more.

It is estimated that EPR could generate up to £1.8bn in revenue. £1.2bn of which will be passed to Local Authorities to fund the collecting, managing, recycling and disposing of household packaging waste. 

How it Works in Practice: Extended Producer Responsibility Example

The example below shows how much EPR fees could increase for a large business: 

Imagine a company with a £5 million turnover that puts 100 tonnes of packaging on the market each year, 70 tonnes recyclable and 30 tonnes which is harder to recycle. 

In 2024, it would only need to buy recycling certificates (PRNs), costing around £10,000 in total. 

However in 2025, new waste management fees will be added on top. At current estimates, that could mean an extra £14,700 for the recyclable packaging and £15,000 for the harder-to-recycle materials.  In this example, the company’s annual costs could rise to nearly £40,000, almost four times more than the year before.

By contrast, a smaller business with a turnover between £1 million and £2 million that places 25–50 tonnes of packaging on the market only needs to report its packaging data under the current EPR rules. 

This means no PRN purchases and no waste management fees. For these businesses, compliance is more about paperwork than direct cost, making the financial impact of EPR far lighter compared to large producers.

Extended Producer Responsibility (EPR) in the EU – What You Need to Know

The UK is not the only region implementing Extended Producer Responsibility (EPR) regulations. The European Union has introduced EPR schemes as part of its Circular Economy Action Plan, focusing on reducing waste and ensuring that producers take financial and operational responsibility for the entire lifecycle of their products.

Key Areas of Regulation:

Packaging:

EU's Packaging and Packaging Waste Regulation (PPWR) which was adopted on 24th April 2024, is a significant development. It aims to harmonise packaging rules across the EU, increase recycling rates, and reduce packaging waste.   

It includes requirements for packaging recyclability, recycled content, and labeling.   

All EU Member States must implement EPR for packaging waste in line with the Packaging and Packaging Waste Directive. However, individual countries may have different regulations, reporting requirements, and fee structures. The key objectives of the EU EPR framework include:

Ensuring producers cover the full costs of waste management – This includes collection, sorting, and recycling, with costs varying based on recyclability.

Encouraging eco-design and waste prevention – By linking fees to recyclability, the EU EPR scheme incentivises businesses to adopt more sustainable packaging solutions.

Standardising labelling and consumer information – Several countries, including France, require clear sorting instructions on packaging to improve recycling rates.

Boosting recycling targets – The EU has set ambitious recycling targets, including a 65% recycling rate for packaging waste by 2025 and 70% by 2030.

Waste Electrical and Electronic Equipment (WEEE):

The EU Waste Electrical and Electronic Equipment (WEEE) Directive is another key EPR regulation focused on the lifecycle management of electronic products. Producers of electrical and electronic equipment (EEE) are required to finance the collection, recycling, and disposal of electronic waste (e-waste). Additionally, products must be designed for durability, repairability, and recyclability to minimize waste generation. 

Batteries:

Batteries Regulation (which entered into force 17 August 2023) imposes EPR obligations on manufacturers and importers of batteries, ensuring they take responsibility for end-of-life battery collection and recycling.

Textiles

The European Union is leading the way in implementing EPR for textiles as part of its EU Strategy for Sustainable and Circular Textiles. The EU Waste Framework Directive is being revised to make EPR for textiles mandatory in all Member States by 2025.

The framework is designed to make producers responsible for the entire lifecycle of their textile products, from design and production to post-consumer disposal and recycling. The aim is to reduce textile waste, promote circularity, and encourage sustainable practices within the fashion and textile industries.

Key Differences Between UK and EU EPR

While both the UK and EU EPR regulations aim to shift financial responsibility onto producers, there are key differences:

Scope and Fees: The EU EPR framework applies across all Member States, but national variations exist. Some countries charge eco-modulated fees, meaning businesses pay more for packaging that is harder to recycle.

Reporting Obligations: Businesses selling products across multiple EU markets must comply with each country’s specific reporting and registration requirements, which can vary significantly.

Obligations for Online Retailers: In the EU, online marketplaces may be considered producers and could be required to take responsibility for compliance, whereas the UK primarily holds brand owners accountable.

What UK Businesses Selling in the EU Need to Do?

If your business sells packaged goods in the EU, you must ensure compliance with EPR requirements in each country where your products are placed on the market. This may include:

1. Registering with national EPR schemes in the relevant EU countries.
2. Paying producer responsibility fees based on the type and quantity of packaging used.
3. Providing clear labelling and consumer disposal information to meet local regulations.
4. Tracking and reporting packaging waste data according to each country’s deadlines.

Failure to comply with EU EPR regulations can lead to penalties, sales restrictions, and reputational risks. Therefore, UK businesses operating in the EU should take proactive steps to understand their obligations and implement compliance strategies.

Simplify EPR compliance through smarter packaging data management

EPR means businesses have to collect more complex data on their packaging, likely introduce a new reporting format and submit data more frequently. 

Ensure you are capturing the data you need in an easy to use format, automated wherever possible. Our team can help you streamline your compliance process under EPR.

With the right solution, compliance and compliance reporting can quickly become second nature.

How Segura can help

Download our UK EPR Factsheet. We have outlined the key elements of the regulation with a recommended  roadmap to compliance in one handy document. 

Data Collection

Through Segura’s order management module retailers can identify and track packaging orders and facilitate real-time orders through nominated suppliers. In addition, the platform can capture the necessary data such as packaging weight, material, type and class. Capturing the necessary product information required for the Due Diligence Statement.

Reporting

Segura’s business intelligence tool makes it easy to capture, manage and export packaging data.

About Segura

Segura Systems is a UK-based SaaS company enabling ethical, sustainable and efficient multi-tier supply chains.

Segura provides n-tier mapping, transparency, traceability, visualisation, compliance and reporting. Segura sits in the centre of your supply chain management structure creating a central repository for all your supply chain, ESG-related data and evidence, including from third-party data sources.

To learn more why not contact us today.