Get set for the EPR Policy for Packaging! Are you prepared to make a difference?

Helping you meet your Extended Producer Responsibility packaging obligations

What is the Extended Producer Responsibility (EPR) Policy?

The Extended Producer Responsibility (EPR) for packaging is a regulatory framework that puts the spotlight on producers, making them accountable for the environmental impact of their products, especially when it comes to packaging waste. With EPR, businesses that bring packaged goods to market in the UK, will be required to chip in for the costs of collecting, recycling, and disposing of that packaging.

This scheme is all about championing a circular economy, nudging businesses to craft packaging that’s not only easier to recycle but also kinder to our planet. However, understandably some companies are a bit worried about the financial impact and the logistical challenges they might encounter while adapting to these new requirements.

The new EPR for packaging system will replace the old Packaging Waste Regulations.  Alongside Simpler Recycling and the Deposit Return Scheme for drinks containers, the EPR scheme is estimated to stimulate an estimated £10 billion investment in recycling services and infrastructure across the UK over the next 10 years, setting the stage for a brighter, more sustainable future.

What Packaging is included in the EPR Policy?

The EPR generally covers any packaging designed to protect, contain, deliver, or present products to consumers. Here are some examples:

• Plastic Packaging (like bottles, trays, wrappers, and more)
• Cardboard & Paper Packaging (such as boxes, envelopes, cartons)
• Glass Packaging (think bottles or jars)
• Metal Packaging (including cans, tins, aluminium foil)
• Wooden Packaging (like pallets or crates)

The ‘Packaging Definition’ outlined for this scheme on gov.uk is:

“Packaging is any material that is used to cover or protect goods that are supplied. It makes handling and delivering goods easier and safer. It includes anything that’s designed to be filled at the point of sale, such as a coffee cup.”  

Who will the EPR Scheme affect?

The Extended Producer Responsibility is set to touch a broad spectrum of businesses, if you do any of the following, you may need to act:

• Supply packaged goods to the UK market under your own brand

This includes goods that are labelled with your own brand and supplied to the UK market.  A brand includes a name, a trademark or any other distinguishing brand mark

• Place goods into packaging

Packaging goods for your own organisation or on behalf of another organisation

• Import products in packaging

If you import products in packaging destined for the UK market or if you sell imported goods that are packed or filled by a UK third-party

• Own an online marketplace

If you allow a non-UK business to sell their goods into the UK through your marketplace

• Hire or loan out reusable packaging

If you hire or loan out reusable packaging

• Supply empty packaging

If you are a manufacturer or import empty packaging and then supply it to a business that is not classed as a ‘large organisation’, or supply this packaging to a large producer that does not fill the packaging

A ‘Large Organisation’ for this scheme is classified as:

“You have an annual turnover of £2 million or more, AND you’re responsible for supplying or importing more than 50 tonnes of packaging in the UK”   

A ‘Small Organisation for this scheme is classified as:

“Your annual turnover is between £1 million and £2 million and you’re responsible for supplying or importing more than 25 tonnes of packaging in the UK, OR your annual turnover is over £1 million and you’re responsible for supplying or importing between 25 tonnes and 50 tonnes of packaging in the UK”   

What are the criteria for complying with the scheme?

Your business will need to hop on board with the EPR scheme if all of the following apply:

• You are an individual business, subsidiary or group (excluding charity)
• Your annual turnover hits £1 million or more
• You imported or supplied more than 25 tonnes of packaging in a calendar year
• You carry out any of the packaging activities above

If all of the above apply to you, you can dive deeper into your responsibilities here.

For smaller businesses managing less packaging, a simple registration and reporting might be all you need.

Meanwhile, larger organisations will have to pay fees based on your turnover and the weight of the packaging you handle annually.

Timeline: When Will the EPR Policy Take Effect?

Countries worldwide are gradually introducing EPR regulations. In the UK, the journey began with reporting in 2023, and by October 2025, businesses will fully embrace the costs.

To oversea the scheme’s rollout, the Department for Environment, Food & Rural Affairs (Defra) has established PackUK as the scheme administrator.  PackUK launched to deliver this scheme on 21st January 2025.

How to register for EPR

To get started with the UK’s Extended Producer Responsibility (EPR), you’ll want to hop onto the National Packaging Waste Database (NPWD) and register your companies details.

Other EPR changes to watch our for

The UK government is gearing up to give the Extended Producer Responsibility (EPR) a boost by introducing a new requirement: all packaging must be clearly labelled with ‘Recycle’ or ‘Do Not Recycle’. This change is all about empowering businesses and consumers to make smarter, more eco-friendly choices when it comes to recycling. Initially, this was part of the EPR policy in 2023, but it hit a few bumps and was set to roll out in 2025. However, Defra has decided to push this back even further to April 2027. For many businesses, this delay is a bit of a breather, helping to keep unnecessary costs at bay during the initial phase.