Rule read on 2026-08-23 · From gov.uk and legislation.gov.uk; documentary review integrated 13 September 2026 — verified by PPWR Connect on 25 September 2026.
At a glance
| Question | Answer | Verified |
|---|---|---|
| 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) | 2026-08-23 |
| Who is the producer | 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. | 2026-08-23 |
| Entry threshold | £1,000,000 (worldwide) · 25 t · all criteria must be met | 2026-08-23 |
| Register | Report packaging data (environmental regulator: EA, NRW, NIEA, SEPA) — https://www.gov.uk/guidance/report-packaging-data | 2026-09-12 |
| Reporting | 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. | 2026-08-23 |
| Authorised representative | Not applicable in the EU sense — there is no representative to appoint; a member of a registered compliance scheme is registered and reports through it, and is exempt from doing so itself (regulation 42) | 2026-08-23 |
When the obligation is not yours
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.
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 most of their data per half-year (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, each with its own scope: disposal fees if it supplied household packaging, and packaging recycling evidence (PRN/PERN). A small producer carries neither, but it registers and pays the registration fee.
The calendar
- 2027-04-01 — Packaging data — July to December (large producers) or the full previous year (small producers)
- 2027-10-01 — Large producer — packaging data for January to June
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 branch and no address in the UK. Am I obligated?
- Under the UK rules the obligated producer must be established in the UK — and a branch or a postal address there, a PO box or a returns address included, is enough (regulation 4). With none of them, 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 — a member of a registered compliance scheme is registered and reports through it (regulation 42).
- 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. 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.
- Who reports per semester?
- 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 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
What the sourced rule implies for an EU exporter — an indication provided for information, not legal advice. UK rules change every year: verify with the regulator before acting.