What is Extended Producer Responsibility UK? (Updated 2025)

But what is Extended Producer Responsibility? When does it come into effect and how does it affect the packaging industry? In this article, we will explore all there is to know about Extended Producer Responsibility.

What is Extended Producer Responsibility (EPR)

Extended Producer Responsibility (EPR) is a new UK legislation that will replace the current Packaging Waste Regulations with a phased implementation from 2023. It is an environmental policy that requires producers to pay the full costs of dealing with the waste they produce from when it is placed onto the market, through to the end of its life.

It is hoped that this will achieve a reduction in the environmental impact of products throughout their life cycle. The idea is that if you produce the pollution, then you should pay for the costs of the impact it can have on the environment as well as on people’s health. So, under EPR proposals, packaging producers will be responsible for the entire cost of recycling the packaging they place on the market including the cost of collection, treatment, and of course recycling.

Research has already been conducted into EPR's impact on seven paper and packaging recycling programs around the world. The results showed that EPR policy accelerated the collection and recycling of target materials to over 75% in British Columbia, Belgium, Spain, Netherlands and South Korea, with Portugal and Quebec over 60%. This shows that the Extended Producer Responsibility is achieving what it is set out to do.

 

Extended Producer Responsibility: 2025 updates

In a significant step forward for the packaging industry, PackUK has released several new publications central to the delivery of the UK's Extended Producer for Packaging (pEPR) scheme. This includes:

The 2025 base fees for the pEDR scheme to provide certainty to producers

Nearly all fees have been reduced compared with the illustrative base fees published in December. These reductions result from high levels of industry compliance with reporting obligations and extensive work across the regulators and PackUK to issue and validate the data provided.

The first Fee Modulation Policy Statement on driving sustainable packaging choices

The new modulation policy establishes a clear 3-year framework that will adjust producer fees based on packaging recyclability, as assessed through the Recyclability Assessment Methodology (RAM) ratings. Starting from the 2026/27 financial year, the policy will apply escalating modulation factors of 1.2x, 1.6x and 2.0x over consecutive years.

This means in practice:

• Producers of RAM Green-rated packaging will benefit from steadily decreasing fees
• Producers of RAM Red-rated packaging will face progressively higher fees
• Special provisions apply for medical packaging where regulatory requirements limit recyclability options

A Regulatory Position Statement addressing producers' concerns around the recyclability assessment obligations

This statement is a response to industry feedback regarding time and resource to meet their 2025 recyclability assessment obligations. The Regulatory Position Statement provides additional flexibility for producers during this transition.

This aims to ease the burden while maintaining the commitment to introduce modulated pEPR fees from the 2026 to 2027 assessment year.

Producers must still report tonnages for the first half of 2025, including flexible and rigid plastics separately. Their recyclability assessment obligations for this period can be extrapolated from second-half data.

The PackUK interim strategy

As part of its role administering the packaging EPR scheme, PackUK has published an interim strategy, approved by all four UK nations. This sets the foundation ahead of a full strategy due later in 2025. Key upcoming developments include:

• Appointment of a CEO and Chief Strategy Officer
• New UK-wide policies on reuse and local authority outcomes
• Establishment of a Producer Responsibility Organisation by March 2026

These initiatives form part of the government's broader packaging reforms, aiming to create 25,000 jobs and drive £10 billion in recycling investment over the next decade.

Will the Extended Producer Responsibility affect my business?

The guidance expresses that this change will affect all UK organisations that handle or supply packaging. For some further information, handling activities are explained under the current Producer Responsibility Obligations (Packaging Waste) Regulation 2007.

The actions that will need to be taken all depend on the size of your organisation. A small organisation is classified as the following:

• A small organisation's annual turnover that is between £1 million and £2 million and is responsible for handling and supplying 25 + tonnes of empty packaging or packaged items throughout the UK in a calendar year.
• Alternatively, a small organisation's annual turnover is over £1 million and so is responsible for handling and supplying between 25 tonnes – 50 tonnes of empty packaging or packaged items through the UK market in a calendar year.

As for a large organisation -

• Annual turnover is £2 million or more and so large organisations are responsible for handling and supplying more than 50 tonnes of empty packaging or packaged products within a calendar year.

To assist producers in understanding whether they are obligated under Extended Producer Responsibility, DEFRA has developed an online EPR Obligation Checker. This interactive tool will help you access whether you meet the requirements.

In order to use the tool, you will need to know your annual turnover, how your organisation handles and supplies packaging, and the total weight (in tonnes) of packaging you handled and supplied in 2022.

What actions need to be taken under Extended Producer Responsibility?

The actions that will need to be taken depends on the size of your business.

Small organisations

In order to comply:

• Continue recording packaging data: You must collect data on all empty packaging and packaged products you handle or supply in the UK. This started from 1 January 2023.
• Register for the EPR online service: Registration opened in 2024, and all small organisations must register once eligible.
• Submit 2023 packaging data: You should have submitted your 2023 data between 1 January and 1 April 2024. Late submissions may result in penalty charges.
• Prepare for future reporting requirements: While small organisations don't currently pay full fees or PRN/PERN costs, you should monitor updates, as your obligations may evolve from 2026 onwards.

The data for 2023 will need to be submitted between 1st January 2024 and 1st April 2024. Any missed payments will result in a penalty charge.

Large organisations

Large producers have additional and ongoing responsibilities. To remain compliant:

• Record packaging data: You must track all empty packaging and packaged goods handled or supplied in the UK, beginning 1 January 2023.
• Register for the EPR online service: Registration has been mandatory since April 2023.
  Submit data every six months: Packaging data must be reported biannually. The current reporting windows are:
  • H1 (Jan-June): Submit by October
  • H2 (July-Dec): Summit by April (following year)
• Submit Nation Data: If you sell, hire, loan or distribute packaging in the UK, you must report where in the UK the packaging ends up.
• Pay the environmental regulator fee
• Purchase PRNs or PERNs: These help meet your recycling obligations under the scheme.
• Prepare for recyclability fee modulation (from 2026/27): From 2026, fees will vary based on how recyclable your packaging is, using the new RAM.

What packaging activities come under the Extended Producer Responsibility regulation?

So you may be wondering what packaging activities will be coming under this new regulation. You may need to act if your business does any of the following:

• Supply packaged goods to the UK market under your own brand
• Place goods into packaging that’s unbranded when it’s supplied
• Import products in packaging
• Own an online marketplace
• Hire or loan out reusable packaging
• Supply empty packaging

What should the data submission include?

To comply with EPR requirements, your packaging data submission must include the following key information:

• Packaging activity – this is how you supplied the packaging
• Packaging type – for example, if the packaging is household or non-household
• Packaging class - whether the packaging is primary, secondary, shipment or tertiary
• Packaging material and weight

For large organisations, you will also need to supply:

• Nation data - where in the UK the packaging was sold, hired or loaned
• Recyclability details - data on the recyclability of packaging components, which will inform future modulated fees

The scheme administrator will then use your data to calculate your waste management fees for the upcoming compliance year.

It will then use your data to calculate the amount of PRNS and PERNS you need to buy to cover your recycling operations for the following year.

Then from 2026/27, the scheme administrator will adjust your waste management fees - and this depends on the cost of recycling the materials used in the packaging you handle and supply.

Latest update: This article has been updated to reflect the latest announcements from DEFRA and PackUK on the EPR scheme. Modulated fees begin in 2026, not 2025. Base fees for 2025 have now been published.

For the full information and guidance about the Extended Producer Responsibility regulation, visit Gov.UK.

What are the environmental benefits of EPR?

Research showed that EPR policy accelerated the collection and recycling of target materials to over 75% in British Columbia, Belgium, Spain, Netherlands, and South Korea, with Portugal and Quebec following closely behind at over 60%.

Based on the fact that the new regulations should hold UK producers more accountable for their environmental decisions, and that positive change has been seen across the world already, the benefits of EPR include:

1. Incentivising sustainable practices

EPR offers a powerful incentive for the adoption of more sustainable practices throughout the entire lifecycle of your products. By holding producers financially responsible for the end-of-life management of all packaging, EPR encourages businesses to explore eco-friendly materials, design products with easier recyclability in mind, and implement efficient waste reduction strategies.

2. Promoting innovation in packaging design

With the introduction of EPR, packaging producers are driven to think creatively and innovate. The further development of innovative packaging will have a positive environmental impact while still ensuring product protection and market appeal. As a result, we can expect to see a surge in sustainable packaging solutions, such as biodegradable materials, reusable packaging, and reduced material usage.

3. Reducing waste generation

By choosing more sustainable materials and designing products with less excess packaging, overall waste generation can be minimised. As producers take responsibility for the recycling and proper disposal of packaging waste, it reduces the burden on local waste management facilities.

What are the potential challenges and concerns with EPR?

While ERR offers several environmental benefits, certain challenges and concerns are likely to surface for those affected. Some of the potential issues include:

1. Potential cost burdens on businesses

One of the main concerns surrounding the implementation of Extended Producer Responsibility is the potential increase in costs for your business. Compliance with EPR regulations might require additional investments in tracking and reporting systems, waste management infrastructure, and recycling processes. It’s crucial to find a balance that ensures environmental responsibility without imposing excessive financial burdens.

The cost to business will rise substantially, with the current system said to be costing UK companies between £200-300 million a year. Extended Producer Responsibility (EPR) is predicted to cost around £2.7bn, which will mean costs for companies could increase 10 to 30 times more.

2. Administrative complexities

EPR implementation involves intricate administrative processes, data collection, and reporting requirements. For businesses, navigating the complexities of EPR compliance can be daunting with businesses having to categorise the packaging into this new categories Simplified and clear guidelines, as well as support from government agencies, will be essential to help businesses adapt smoothly to the new regulations.

At Swiftpak, we understand the need for greater data collection and reporting. That’s why we’ve been working hard to implement a brand-new online tool for our customers. Designed to help track waste types, packaging activity, and waste amounts over set periods, our EPR tool allows you to categorise packaging and download data . For more on this, speak to our friendly team at Swiftpak today – we’d be more than happy to give you a demonstration and answer any questions you may have.

A phased approach: What changes are expected to come?

The UK Government plan to implement the new regulations in a phased approach. So, what can we expect to see following the initial implementation?

• Modulated fees - From the 2026/27 financial year, producers will pay fees based on the environmental / recycling qualities of their products. For example, how widely recycled or recyclable a material is. This will require more in-depth data on your packaging materials than is reported in the current system.
• More detailed reporting – As mentioned above, plans to introduce fees based on environmental qualities of materials will require greater reporting capabilities. The first round of EPR is going into a lot more detail than the previous annual waste reports. It’s expected that the second round of EPR would require even more details – such as:
  1) Packaging components – This follows the Plastic Packaging Tax where packaging must be declared by its individual component. For example, a lid, label, and bottle are all declared as separate packaging components.
  2) Recycling disruptors – UV inks, metal component, varnishes, carbon black colouring etc.
  3) Recycling enablers – think detectable inks that allow for enhanced sorting and reprocessing.
  4) Format of packaging – Is it a box, bottle, jar, bag?
  5) Colour of material
  6) Additional material information – such as plastic polymer type, treated/untreated wood, or paper lamination
• More frequent reporting – On top of the added details required, data reporting has moved to a bi-annual reporting structure (April and October).

Extended Producer Responsibility UK and Swiftpak

With 45 years of experience in the packaging industry, at Swiftpak we wanted to explore the Extended Producer Responsibility UK so that our customers will know what to expect. If you have any questions about this new regulation, you can either visit the gov.uk website or contact us today and we will be happy to help you as much as we can.