Extended Producer Responsibility (EPR) for Packaging

Extended Producer Responsibility (EPR) is a game-changer for UK businesses dealing with packaging. This regulation shifts the responsibility for packaging waste management—from local councils and taxpayers—to the companies that produce, import, and sell packaged goods. If your business is affected, understanding what’s required is key to staying compliant and managing costs effectively.

EPR is designed to make packaging waste management more sustainable and fair. Here’s what it aims to achieve:

• Make producers financially responsible – Companies placing packaging on the market must cover the costs of its collection, recycling, and disposal.
• Encourage better packaging design – The system rewards recyclable and sustainable packaging choices.
• Boost recycling rates – More packaging will be collected, processed, and reused.
• Support a circular economy – Packaging materials should be kept in use for as long as possible rather than being sent to landfill.
• Increase transparency – Companies must track and report packaging data to improve waste management across the supply chain.

These changes mean businesses need to rethink their packaging strategies, not just for compliance, but for long-term sustainability and cost-effectiveness.

EPR doesn’t apply to everyone—but if you handle packaging in the UK, chances are it affects you. You must take action to comply if ALL of the following apply:

• You operate as an individual business, subsidiary, or group registered in the UK (excluding charities).
• Your annual UK turnover is £1 million or more.
• You import or supply more than 25 tonnes of packaging to the UK market within a calendar year.
• You are involved in any of the packaging activities* identified in legislation.

If your business ticks these boxes, you have reporting obligations under EPR.

Your obligations under EPR depend on your company’s size.

Small Organisations

A business is classified as small organization if it meets one of the following criteria:

• Turnover between £1M and £2M and handles more than 25 tonnes of packaging annually.
• Turnover above £1M and handles between 25 and 50 tonnes of packaging annually.

Large Organisations

You are classified as a large organisation if:

• Your annual turnover is £2 million or more, and
• You handle more than 50 tonnes of packaging annually.

The Extended Producer Responsibility (EPR) scheme affects businesses differently based on their size and packaging volume. Smaller organisations must submit detailed reports* on the packaging they place on the market and how the waste is managed. Larger businesses have additional responsibilities. They must report data biannually and are financially accountable for the full costs associated with managing and recycling their packaging waste.

Producers now cover household packaging waste disposal costs. Organizations needs to report packaging volumes separately for household and non-household packaging, as each has different regulatory requirements*

• Household Packaging: This is packaging that typically ends up in residential waste bins (e.g., food wrappers, drink bottles, detergent bottles). This type of packaging carries additional financial obligations.

• Non-Household Packaging: This includes packaging used in business-to-business transactions, industrial supply chains, and transit packaging.

ERP legislation is increasingly prioritizing recyclable materials, directly linking packaging design to compliance costs. The more recyclable and reusable the packaging, the lower the financial burden on producers, whereas higher waste volumes will drive up costs. While redesigning packaging may involve upfront investment, proactively optimizing materials now can significantly reduce long-term EPR liabilities.

Organizations must familiarize themselves with the reporting requirements for branded products and packaging destined for public disposal. A more strategic approach is to categorize products by brand, identifying which will be classified as household waste and documenting their material composition. This proactive step streamlines reporting and compliance, providing a head start in adapting to EPR obligations.

EPR will increase costs for many businesses—but understanding the fee structure can help manage the impact. EPR doesn’t just mean new responsibilities—it also presents opportunities to cut costs and improve sustainability.

Reducing EPR fees doesn’t have to be complicated – it’s about making smart choices in packaging design, materials, and reporting. Since fees are based on the weight of packaging placed on the market, lightweighting is one of the easiest ways to lower costs. That said, it’s important to strike a balance—especially for food packaging—so that reducing material use doesn’t compromise product protection.

In terms of material selection, switching to mono-materials from complex laminates and avoiding hard-to-recycle options like black plastic can improve recyclability without a major overhaul. On top of that, smart packaging design—removing unnecessary components, optimizing sizes, and reducing overpacking can make a real difference in both costs and sustainability. While these steps may not immediately change organization’s fees, they’ll help to stay ahead of the curve when eco-modulation kicks in, making compliance smoother and more cost-effective in the long run.

While ERP brings added responsibilities and costs, it’s also an opportunity to rethink packaging strategies, cut waste, and improve sustainability. Businesses that stay ahead of the curve—by adopting recyclable materials, improving data accuracy, and preparing for labelling changes—will benefit the most.

Now is the time to review your packaging approach and ensure your business is EPR-ready. The sooner you adapt, the easier compliance (and cost savings) will be.

Get in touch with us on +44 (0) 1233 281 460 or send us an email at info@aropack.co.uk for more information.