Selling to the UK from the EU — who carries packaging EPR, and what to prepare

At a glance

Why the obligation is usually not yours

Being established in the UK is one of the criteria. Without a UK entity, 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: disposal fees (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. 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 packaging with plastic layers of no more than 5% by weight is reported as paper or card, with evidence (SI 2025/1369). Civil sanctions and offences exist; they depend on the breach and the authority, and are not automatic.

This is not the EU logic, where an authorised representative can carry the obligation for a seller established elsewhere. In the UK there is no representative to appoint: whether a UK business is obligated follows from its own activity, packaging and size — not from a contract between you.

What the UK business will ask you for

• The packaging per unit: components, material of each, weight of each — the data is reported per material.
• The units placed on the UK market per period — large producers report per semester (January to June, July to December), small producers once a year.
• Your assessment under the UK recyclability methodology (RAM: green, amber or red) if you are the one who knows the packaging and the producer needs it — the rating is declared, never derived from an EU grade, and not every small producer needs one.
• Whether the packaging is household or 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.
• For a large producer, two separate costs follow from that data: disposal fees and packaging recycling evidence (PRN/PERN). A small producer reports data only.

The calendar

• 2026-10-01 — Large producer — packaging data for January to June
• 2027-04-01 — Packaging data — July to December (large producers) or the full previous year (small producers)

Indicative dates from our seed, read from the reporting rule; confirm on the register before filing.

How PPWR Connect helps here

One packaging record per unit; the UK export gives your figures by PackUK material category (8 categories) and household / non-household (primary and shipment packaging presumed household), per semester or per calendar year, with the RAM rating you declared on each packaging version. It helps you prepare the data; it is not yet a file ready to submit: the activity, packaging type, packaging class and sub-types such as rigid / flexible are not captured per component. We do not register or report for you, and we never state a fee: PackUK administers the disposal fees, and we link the current schedule.

Five questions

I sell online to UK consumers directly, with no UK entity. Am I obligated?

Under the UK rules the obligated producer must be established in the UK, so the obligation does not sit with you. Whether your fulfilment partner, the first UK owner or a marketplace operator is obligated depends on its own activity and size — a direct sale from abroad does not create an obligated importer; check it against the regulator’s guidance.

Do the EU authorised-representative rules apply in the UK?

No. The UK is outside the Union; the PPWR does not apply there, and the UK scheme has no representative regime — an approved compliance scheme may register and report for its members.

What are the size tests?

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 (group rule: only the group companies established in the UK that supply or import packaging count). Reference years for 2026: 2025 data, latest accounts available before 7 April 2026. Large producer: more than 50 tonnes AND more than £2 million — large producers report every six months, pay disposal fees, and separately have recycling obligations evidenced by PRN/PERN; small producers report once a year and do neither.

Who reports per semester?

Large producers report every six months (period Jan–Jun due 1 October, period Jul–Dec due 1 April). Small producers report once a year, due 1 April for the previous calendar year. Registration is annual: in principle 1 October for large producers and 1 April for small producers, with special cases (for example a seller whose only activity is selling filled packaging to the end user applies for 2027 by 1 April 2027). Keep the evidence behind the data for at least 7 years. Nation-of-sale data is NOT a current deadline: in England, RPS 330 (updated 25 August 2026, a conditional non-enforcement position, not a repeal) has nation and bag data collected from 1 January 2028 and reported by 1 April 2029, and self-managed organisational waste collected in 2028 and reported by 1 October 2028; the Welsh, Scottish and Northern Irish positions are not read — not seeded.

Does PPWR Connect derive the RAM rating from the recyclability grade?

No. The RAM rating is your assessment under the UK methodology, declared per packaging version; it is stored as declared and shown as such in the export.

Primary sources

• United Kingdom — www.gov.uk (2026-09-12)
• gov.uk — check if you must comply (2026-08-23)
• Report packaging data (environmental regulator: EA, NRW, NIEA, SEPA)