Packaging EPR in the United Kingdom — who is the obligated producer, and what to declare

Who is the obligated producer in the United Kingdom

Qualification depends on the activity and the packaging, not on a single linear cascade. Activities in the regulations: supplying filled packaging under your own brand; packing or filling; importing filled packaging; supplying unfilled packaging; hiring or loaning reusable packaging; owning an online marketplace through which packaging is supplied into the UK from outside; selling filled packaging to the end user. Being a producer and being obligated are two different things. A producer (regulation 15) is established in the UK (regulation 4) and performs, in the UK and in the course of business, the functions of one of those classes. The obligations (regulation 25) fall on large and small producers (regulation 23), that is on a producer that meets the size tests of regulation 24 — all of them: more than 25 tonnes of packaging supplied or imported in the UK, and a turnover of more than £1 million. The tonnage is the total for the year, calculated in tonnes to the nearest tonne before the comparison (regulation 24(6)). In a group, count only the group companies established in the UK that supply or import packaging — not the whole international group; a group company can also be a large or small producer through the group rules of Schedule 9 (regulation 23), without meeting the tests on its own figures. Reference years (regulation 24(1), (2) and (5)): for a relevant year Y, the tonnage is the packaging supplied in year Y-2, and the turnover is that of the last financial year that ended before 7 April in year Y-1 for which accounts are available. The gov.uk guidance uses another anchor — for 2026 packaging data, the tonnage supplied in 2025 and the last accounts available before 7 April 2026 — so check the year against both before relying on it. Charities are outside the registration, record-keeping and reporting obligations and the disposal and administration fees (regulation 12, referring to regulation 25, Part 3 and regulation 60) — not outside the obligations of reprocessors and exporters (Part 6); a trading subsidiary that is not itself a charity is not; being non-profit is not in itself an exclusion.

There is no EU-style authorised-representative regime in the United Kingdom. Without a local establishment, whether a local importer, first owner or marketplace operator carries the obligation depends on its own activity and size — or, where the law says so, the brand owner carries it wherever it is established.

Being established in the United Kingdom is one of the criteria: without a local entity you are not the obligated producer there, and whether the local business that imports or supplies your packaged goods is obligated depends on its own activity and size.

Watch out: Being established in the UK is one of the cumulative criteria, and regulation 4 defines it widely: habitually resident in the UK; a registered office, head office or principal place of business in the UK; or a branch or a postal address in the UK — the guidance gives a PO box and a returns address as examples. It is not the tax notion of a permanent establishment, and having no company incorporated in the UK never settles it. Settle that point before concluding the obligation is not yours. If you are indeed not established in the UK, check separately who may be obligated: the UK importer or first UK owner, or the online marketplace operator — their activity, their size and the packaging concerned. A direct sale from abroad does not create an obligated UK importer, and a contract organises tasks between the parties but does not designate the obligated party for the regulator. Two separate obligations for large producers, each with its own scope: disposal fees for those that supplied household packaging (regulation 60; first fee year 2025-26, first invoices October 2025, modulated by the Recyclability Assessment Methodology from 2026-27 — RAM 1.1 for packaging supplied in 2026, RAM 2027 for 2027, with no automatic conversion from an A/B/C grade), and recycling obligations evidenced by PRN/PERN (regulation 25(2)). A small producer carries neither, but it still registers and pays the registration fee. RAM assessment is not required of every small producer. Household / non-household: primary and shipment packaging are presumed household unless the conditions and evidence for non-household are met; a B2B channel alone is not enough. Fibre-based composite: paper or board fibres with one or more plastic layers forming a single unit that cannot be separated by hand. It is reported as paper or board if the producer can provide evidence that the plastic layers are not more than 5% of the packaging material by mass (regulation 7(5A)). Civil sanctions and offences exist; they depend on the breach and the authority, and are not automatic.

Thresholds in the United Kingdom

The United Kingdom sets an entry threshold below which the producer is exempt or lighter. The figures below are the legal thresholds — never a fee.

All criteria must be met, and each is strict (regulation 24): established in the UK, MORE THAN 25 tonnes of packaging supplied or imported in the UK, and turnover of MORE THAN £1 million. The tonnage is the total for the year, rounded to the nearest tonne before the comparison (regulation 24(6)): 25.4 tonnes is 25 — not above; 25.6 tonnes is 26 — above. The regulations do not say which way an exact half-tonne rounds. Exactly £1 million is not above the threshold. The gov.uk guidance writes "your annual turnover worldwide was £1 million or more" and a band "from 25 tonnes to 50 tonnes"; regulation 24 says "more than", and the regulation governs the comparison. Group rule: only the group companies established in the UK that supply or import packaging count. Reference years (regulation 24): for a relevant year Y, the tonnage of year Y-2 and the last financial year ended before 7 April of year Y-1; the gov.uk guidance anchors on the data year instead — see the reference-period note. Large producer: more than 50 tonnes AND more than £2 million. A large producer reports most of its data every six months, but not all of it (regulation 35); if it supplied household packaging as a brand owner, packer/filler, importer, distributor, online marketplace operator or service provider, it pays disposal fees (regulation 60), and outside the seller-only case it has recycling obligations evidenced by PRN/PERN (regulation 25(2)). Small producers report once a year and carry neither fees nor recycling obligations, but they register like everyone else and pay the registration fee.

Source: https://www.gov.uk/guidance/check-if-you-must-comply-with-epr-for-packaging--2 · 2026-08-23

Register and schemes in the United Kingdom

Register: Report packaging data (environmental regulator: EA, NRW, NIEA, SEPA) — https://www.gov.uk/guidance/report-packaging-data

• PackUK — scheme administrator: disposal fees and payments (keeps the final decisions); not a scheme you join — https://www.gov.uk/government/collections/extended-producer-responsibility-for-packaging (all packaging)
• UK Packaging PRO — named 23 March 2026, in effect from 1 April 2026; supports specified scheme functions, transferred progressively; no producer has to join it — https://www.gov.uk/government/news/uk-packaging-proappointed-to-deliver-extended-producer-responsibilityfor-packagingscheme (all packaging)
• Approved and registered compliance scheme (optional — may register and report for members when the conditions of regulation 42 are met) — https://www.gov.uk/guidance/epr-for-packaging-what-you-must-do-as-a-small-producer (all packaging)

Legal basis: The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024, SI 2024/1332 (adopted text, read with its amendments, incl. SI 2025/1369 in force 1 January 2026)

Fees invoiced from 2025-10 (date of first billing, as published — amounts are never stated here).

Fee modulation applies from the 2026-27 year (a period, never an amount).

What and when to report in the United Kingdom

Cadence: mixed — depends on producer size — Large producers report most of their data every six months — January to June by 1 October, July to December by 1 April (regulation 35(2)) — but not all of it: some descriptions of data are reported every 12 months, by 1 April for the previous calendar year (regulation 35(3)), and a large producer whose only class is seller reports once a year. Small producers report once a year, by 1 April for the previous calendar year (regulation 36(2)). Registration is annual and it looks forward (regulation 28(1)(b)): a large producer of any class other than seller only applies by 1 October of the year before — by 1 October 2026 at the latest for 2027; small producers, and large producers whose only class is seller, apply by 1 April of the year itself — by 1 April 2027 for 2027. Applying is not being registered: an application can be refused (regulation 28(3)(b)). A member of a registered compliance scheme is registered and reports through its scheme (regulations 42 and 43). Keep the evidence behind the data for at least 7 years. Nation-of-sale and bag data are existing legal obligations which, in England and under conditions, benefit from RPS 330 (updated 25 August 2026): a conditional non-enforcement position, not a repeal, and one that can be withdrawn. Under it, collection runs from 1 January 2028 and reporting is due by 1 April 2029, and self-managed organisational waste is collected in 2028 and reported by 1 October 2028. RPS 330 is an English position and does not extend to Wales, Scotland or Northern Ireland, whose positions are not read — not seeded.

• 2026-10-01 — Large producer — packaging data for January to June (PackUK / environmental regulator) · Large producers only (more than 50 tonnes AND more than £2 million). Large-producer registration is also due on 1 October in principle — check the special cases. Cadence depends on your size/contribution. · indicative date from our seed, confirm on the register
• 2027-04-01 — Packaging data — July to December (large producers) or the full previous year (small producers) (PackUK / environmental regulator) · Small producers report once a year, on this date, for the previous calendar year; small-producer registration is also due on 1 April in principle — check the special cases. Cadence depends on your size/contribution. · indicative date from our seed, confirm on the register

Material categories: PPWR Connect maps your component record to the 8 PackUK material categories and to household / non-household; the activity, packaging type, class (P1–P6) and rigid / flexible are not captured yet.

If you sell into the United Kingdom from the EU

No authorised representative is required in the United Kingdom. As an EU exporter without a local entity, check whether your importer, the first local owner or a marketplace operator is obligated — unless the law names the brand owner. A contract organises who does what between you; it does not designate the obligated party. Either way, give them the packaging data per unit.

Steps: Check the three criteria together — UK establishment, more than 25 tonnes supplied or imported in the UK, turnover of more than £1 million; in a group, only the companies established in the UK that supply or import count. Each borderline is strict, and the tonnage is rounded to the nearest tonne first: 25.4 tonnes is 25, below the threshold. Take the years from regulation 24 — the tonnage of year Y-2, the last financial year ended before 7 April of year Y-1 — and compare with the guidance, which anchors differently. Missing one criterion means you are not obligated — but "no UK company" does not settle the establishment criterion: a branch or a postal address in the UK is enough (regulation 4). → Work out whether you are a small or a large producer: large means more than 50 tonnes AND more than £2 million. A small producer is not "data only": it registers like everyone else and pays the registration fee — what it does not carry is the disposal fees and the recycling obligations. A large producer reports most of its data every six months, but not all of it (regulation 35); it pays disposal fees if it supplied household packaging (regulation 60), and outside the seller-only case it has recycling obligations evidenced by PRN/PERN (regulation 25(2)). → Register with your environmental regulator through the "Report packaging data" service — yourself, or through a registered compliance scheme: a member of the scheme is registered by the scheme operator and is exempt from registering itself (regulations 42 and 43). One registration, by one of the two routes. Registration is annual and it looks forward (regulation 28(1)(b)): a large producer of any class other than seller only applies by 1 October of the year before — by 1 October 2026 at the latest for 2027; small producers, and large producers whose only class is seller, apply by 1 April of the year itself — by 1 April 2027 for 2027. → Report your packaging data on the rhythm of your size, and keep the evidence behind it for at least 7 years. PPWR Connect helps you prepare your figures by PackUK material category and household / non-household; it is not a file ready to submit. The official data file also asks for the activity, the packaging type and the packaging class, and for sub-types your SKU register does not hold per component: rigid or flexible for plastic (PL) in the household (HH) and public-bin (PB) packaging types, for large producers only, and a material precision when the code is OT. Check who is responsible, the household classification and any RAM assessment before you submit.

How PPWR Connect answers here

Guided: rule read from the official source, a step-by-step registration guide, and a documentary approval given by a named person within the last 18 months.

Declarations for the United Kingdom give your figures by PackUK material category (8 categories) and household / non-household. The full data file also asks for the activity, the packaging type, the packaging class (P1–P6) and rigid / flexible, which are not captured per component yet — so this is not yet a PackUK-format file.

We do not file for you and we do not quote fee amounts: you sign into the register in your own name, with the figures prepared from your packaging record.

Five questions about packaging EPR in the United Kingdom

Who is the obligated producer for packaging in the United Kingdom?

Qualification depends on the activity and the packaging, not on a single linear cascade. Activities in the regulations: supplying filled packaging under your own brand; packing or filling; importing filled packaging; supplying unfilled packaging; hiring or loaning reusable packaging; owning an online marketplace through which packaging is supplied into the UK from outside; selling filled packaging to the end user. Being a producer and being obligated are two different things. A producer (regulation 15) is established in the UK (regulation 4) and performs, in the UK and in the course of business, the functions of one of those classes. The obligations (regulation 25) fall on large and small producers (regulation 23), that is on a producer that meets the size tests of regulation 24 — all of them: more than 25 tonnes of packaging supplied or imported in the UK, and a turnover of more than £1 million. The tonnage is the total for the year, calculated in tonnes to the nearest tonne before the comparison (regulation 24(6)). In a group, count only the group companies established in the UK that supply or import packaging — not the whole international group; a group company can also be a large or small producer through the group rules of Schedule 9 (regulation 23), without meeting the tests on its own figures. Reference years (regulation 24(1), (2) and (5)): for a relevant year Y, the tonnage is the packaging supplied in year Y-2, and the turnover is that of the last financial year that ended before 7 April in year Y-1 for which accounts are available. The gov.uk guidance uses another anchor — for 2026 packaging data, the tonnage supplied in 2025 and the last accounts available before 7 April 2026 — so check the year against both before relying on it. Charities are outside the registration, record-keeping and reporting obligations and the disposal and administration fees (regulation 12, referring to regulation 25, Part 3 and regulation 60) — not outside the obligations of reprocessors and exporters (Part 6); a trading subsidiary that is not itself a charity is not; being non-profit is not in itself an exclusion. There is no EU-style authorised-representative regime in the United Kingdom. Without a local establishment, whether a local importer, first owner or marketplace operator carries the obligation depends on its own activity and size — or, where the law says so, the brand owner carries it wherever it is established. Being established in the United Kingdom is one of the criteria: without a local entity you are not the obligated producer there, and whether the local business that imports or supplies your packaged goods is obligated depends on its own activity and size.

Is there a threshold in the United Kingdom?

The United Kingdom sets an entry threshold below which the producer is exempt or lighter. The figures below are the legal thresholds — never a fee. Turnover: £1,000,000 — worldwide turnover; Packaging placed on the market: 25 t; Rule: all criteria must be met; Large-producer threshold: £2,000,000 / 50 t.

Where do I register in the United Kingdom?

Report packaging data (environmental regulator: EA, NRW, NIEA, SEPA) — https://www.gov.uk/guidance/report-packaging-data

When do I report in the United Kingdom?

mixed — depends on producer size Large producers report most of their data every six months — January to June by 1 October, July to December by 1 April (regulation 35(2)) — but not all of it: some descriptions of data are reported every 12 months, by 1 April for the previous calendar year (regulation 35(3)), and a large producer whose only class is seller reports once a year. Small producers report once a year, by 1 April for the previous calendar year (regulation 36(2)). Registration is annual and it looks forward (regulation 28(1)(b)): a large producer of any class other than seller only applies by 1 October of the year before — by 1 October 2026 at the latest for 2027; small producers, and large producers whose only class is seller, apply by 1 April of the year itself — by 1 April 2027 for 2027. Applying is not being registered: an application can be refused (regulation 28(3)(b)). A member of a registered compliance scheme is registered and reports through its scheme (regulations 42 and 43). Keep the evidence behind the data for at least 7 years. Nation-of-sale and bag data are existing legal obligations which, in England and under conditions, benefit from RPS 330 (updated 25 August 2026): a conditional non-enforcement position, not a repeal, and one that can be withdrawn. Under it, collection runs from 1 January 2028 and reporting is due by 1 April 2029, and self-managed organisational waste is collected in 2028 and reported by 1 October 2028. RPS 330 is an English position and does not extend to Wales, Scotland or Northern Ireland, whose positions are not read — not seeded.

Does PPWR Connect file the declaration for me?

Guided: rule read from the official source, a step-by-step registration guide, and a documentary approval given by a named person within the last 18 months. Declarations for the United Kingdom give your figures by PackUK material category (8 categories) and household / non-household. The full data file also asks for the activity, the packaging type, the packaging class (P1–P6) and rigid / flexible, which are not captured per component yet — so this is not yet a PackUK-format file. We do not file for you and we do not quote fee amounts: you sign into the register in your own name, with the figures prepared from your packaging record.