As the UK moves closer to a circular economy, Extended Producer Responsibility (EPR) for packaging is reshaping how businesses manage and report the environmental impact of the materials they use. If your organisation produces, imports or supplies packaging, these rules may apply to you.
This explains what EPR is, who it affects, and what steps you should take, including specific notes for Northern Ireland businesses.
What Is Extended Producer Responsibility?
EPR shifts the responsibility for packaging waste from local authorities to the organisations that place packaging on the UK market. The goal is to make producers financially responsible for the collection, recycling and disposal of their packaging once it becomes waste.
Ultimately, the scheme aims to:
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Encourage the use of more sustainable packaging materials
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Reduce waste going to landfill
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Improve recycling rates across the UK
Who Is Affected by EPR?
You may need to take action under EPR if all the following apply to your organisation:
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Your business (including groups or subsidiaries) is established in the UK
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Your annual turnover is £1 million or more
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You handled or supplied more than 25 tonnes of packaging in the previous calendar year
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You carried out one or more packaging activities (see below)
Charities are excluded from these requirements.
What Counts as a Packaging Activity?
EPR applies to organisations that:
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Supply packaged goods under their own brand
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Place goods into packaging
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Import packaged products into the UK
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Own or operate an online marketplace that enables non-UK sellers to supply UK customers
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Hire or loan reusable packaging
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Supply empty packaging
Even if the packaging is discarded before it reaches the end user, for example secondary or transport packaging, it may still need to be reported.
Large and Small Organisations
EPR obligations depend on your organisation’s size.
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Small organisation: turnover between £1 million and £2 million, and handled 25–50 tonnes of packaging
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Large organisation: turnover of £2 million or more, and handled over 50 tonnes of packaging
Large organisations must register, collect detailed data, report packaging information and pay fees.
Small organisations must still record and submit some data, but their obligations are lighter.
If you are part of a group or parent-subsidiary structure, you can choose to report collectively or individually, provided the data is complete and consistent.
Your Key Obligations
If your business meets the EPR criteria, you will need to:
1. Collect and Report Data
Record details about all packaging you supply or import, including material type, weight and the UK nation where it is supplied and discarded. Reporting takes place every six months.
2. Pay EPR Fees
These fees fund waste collection, sorting and recycling services. Costs depend on the amount and type of packaging you place on the market, and whether it is easy to recycle.
3. Obtain PRNs or PERNs
Packaging Waste Recycling Notes (PRNs) and Packaging Waste Export Recycling Notes (PERNs) provide evidence that equivalent amounts of packaging waste have been recycled.
4. Report “Nation Data”
Businesses must specify which UK nation each item of packaging is sold in and where it is likely to be discarded. This helps track recycling performance across the UK.
5. Meet Reporting Deadlines
EPR reporting periods are every six months. Missing a deadline can result in late fees or enforcement action from your environmental regulator.
Practical Steps to Take Now
| Step | Action | Notes |
|---|---|---|
| 1. Check if EPR applies | Review turnover, packaging volume and activities | Under the thresholds? You may not need to report yet |
| 2. Identify your organisation size | Small or large | Determines your specific obligations |
| 3. Collect accurate packaging data | Record materials, weight and nation data | Ensure consistency across all sites |
| 4. Register your organisation | Use the government’s EPR reporting service | Choose the correct environmental regulator |
| 5. Consider a compliance scheme | These can manage reporting and PRN/PERN purchases | You remain legally responsible |
| 6. Submit reports and pay fees on time | Every six months | Avoid late charges or penalties |
Northern Ireland
For organisations based in or supplying to Northern Ireland, EPR applies in much the same way as in the rest of the UK, but there are some important administrative differences.
Businesses in Northern Ireland must:
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Register and report through the UK EPR system, selecting the Northern Ireland Environment Agency (NIEA) as their regulator
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Continue to meet obligations under the Producer Responsibility Obligations (Packaging Waste) Regulations (Northern Ireland) until they are fully replaced by EPR
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Include nation data showing how much packaging is placed on the market in NI and where it is discarded
This approach keeps Northern Ireland aligned with the UK-wide framework while ensuring regional oversight and accountability.
Why It Matters
EPR is more than a compliance requirement. It is a step towards a fairer, more sustainable system where the true cost of packaging waste is reflected in business decisions.
For companies, it is an opportunity to:
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Rethink packaging design and materials
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Improve sustainability credentials
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Strengthen reporting accuracy and supply chain transparency
For the environment, it means more recycling, less landfill and real progress towards a circular economy.
In Summary
If your organisation handles packaging in the UK, especially in Northern Ireland, now is the time to act.
Understanding your responsibilities, gathering accurate data and planning ahead will not only ensure compliance but also demonstrate your commitment to environmental responsibility.
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