Extended Producer Responsibility for Packaging Waste – EPR Scheme

Packaging compliance is where businesses, that meet criteria set by the Packaging Waste Regulations, have taken steps to comply with the requirements of this piece of legislation.

Take our quick obligation test to find out if your business needs to comply.

In 1997, when the Packaging Waste Regulations first came into force, a group of obligated businesses collaborated to create the UK’s first ever packaging compliance scheme (Valpak) as a means to outsource legal compliance to a third party.

If your business is obligated and you’re considering outsourcing compliance to a scheme, our blog provides a list of key questions to evaluate the scheme you’re exploring. These questions are designed to assist in making an informed decision.

The updated Packaging Waste Regulations are designed to:

• Promote a circular economy – Encouraging producers to design more sustainable packaging, improve recyclability, and reduce overall waste.
• Increase recycling rates – Ensuring that more packaging waste is collected, sorted, and recycled rather than sent to landfill or incineration.
• Encourage sustainable packaging design – Incentivising businesses to use materials that are easier to recycle or have a lower environmental impact.
• Shift the cost burden to producers – Requiring businesses, rather than taxpayers, to cover the costs of packaging waste management.

Your business, depending on its size and the activities it performs, may need to pay four sets of fees in order to become compliant with the Regulations:

1. Agency fees – every business has to pay a set environment agency registration fee each year
2. Annual membership fee – this covers our administration costs of checking and verifying data
3. EPR fees – the costs associated with managing packaging waste
4. PRN fees – the cost of procuring recycling evidence notes needed to meet the business’s obligation

We can support businesses in reducing EPR fees by optimising packaging data submissions, ensuring accurate reporting, and identifying opportunities to minimise financial obligations through strategic compliance solutions.

You must submit half-year 1 (HY1) data for 2024 by October of that year. Half-Year 2 (HY2) data is due in April 2025, while HY1 data for the period from 1 January to 30 June 2025, must be submitted by 1 October 2025.

Large producers will receive their invoice for the 2024 data submission period in October 2025, based on their 2024 data. This invoice will be payable either as a lump sum or in quarterly installments in November 2025, and January, April, and June 2026.

Gathering and submitting packaging data can be a demanding and time-consuming process. Businesses have the option to fully outsource data collection and submission to our Data Management Team.

We can offer support and help to collect packaging weights information, or the entire data submission process can be outsourced to us. Our service can be tailored to suit your business’s needs.

Visit our Data Management web page for further information, or contact us today for a free quote or to discuss your business’s requirements.

The Recyclability Assessment Methodology (RAM) is a tool designed by the government to help businesses assess the recyclability of their packaging under the UK’s Packaging Extended Producer Responsibility (pEPR) regulations. By using the RAM, businesses can:

• Identify which packaging materials are recyclable and where improvements can be made
• Reduce EPR costs by optimising packaging design for recyclability
• Gain insights into sustainable packaging choices to align with circular economy goals

For a more in-depth look at the RAM and how we can support your business with its requirements, visit our dedicated RAM page or download a copy of our RAM brochure.

Under UK Packaging Extended Producer Responsibility (pEPR) legislation, businesses must provide clear and accurate information to consumers about how to dispose of packaging correctly. This includes:

• Labelling requirements – Ensuring packaging is marked with correct recycling instructions to help consumers dispose of it properly.
• Recycling guidance – Informing consumers about what packaging materials are recyclable and how they should be sorted.
• Transparency on environmental impact – Providing information on the sustainability of packaging materials and efforts to improve recyclability.
• Compliance deadlines – Businesses must ensure packaging labelling meets the new pEPR standards by 2027.

Valpak is the only compliance scheme to offer a consumer-facing platform, www.recycle-more, which helps its members meet their Consumer Information Obligations (CIOs) by providing recycling information to the public.

Non-compliance with the UK’s Packaging Extended Producer Responsibility (pEPR) regulations can result in serious consequences, including:

• Fines and Civil Sanctions – Businesses that fail to meet their obligations may face financial penalties.
• Increased compliance costs – If packaging is not designed for recyclability, businesses may incur higher EPR fees.
• Regulatory enforcement actions – The Environment Agency can conduct audits, issue enforcement notices, and take legal action against non-compliant businesses.

Ensuring compliance is essential to avoid financial and legal risks. Valpak can help businesses navigate EPR requirements and minimise costs.

Large producer – any business that handled/supplied 50 tonnes or more of packaging in the previous calendar year and had an annual turnover of £2m or more.

Small producer – any business with a turnover in the previous calendar year between £1m-2m which handled/supplied 25 tonnes or more of packaging, or any business that had an annual turnover of £1m or more which handled between 25 and 50 tonnes of packaging. Businesses not meeting one of the small producer definitions are not obligated under EPR.

Small producers must submit data once annually. Small producers incur no financial obligations to support recycling (i.e., they do not need to purchase PRNs or pay EPR fees).

Large producers must submit data every six months on the packaging they have placed on the market. In the future, large producers will also have to pay enhanced fees towards the waste management costs of the packaging they report.

All those exceeding the small producer thresholds must also, once a year, report packaging supplied by them to its end user directly by which UK nation the customer was in.

Self-managed waste comes in 2 distinct categories – consumer and organisation waste.

Self-managed organisation waste refers to any packaging waste generated at sites under your control that you send for recycling. Reporting this packaging waste does not directly impact your financial obligations under EPR.

Self-managed consumer waste is any household packaging waste not commonly collected by local authorities for recycling (75% or more) which an obligated producer collects and arranges to be recycled themselves. It is also any reusable packaging within a dedicated reuse system run by an obligated producer, that has reached end of life and the obligated producer has arranged the collection and recycling of.

The corresponding weight of both types of self-managed consumer packaging is able to be discounted from a producer’s EPR fee obligation provided they have evidence confirming the weight of packaging that has been recycled.

Looking for support?

If you’re struggling to gather this information, we can help by contacting your waste contractors, collating the information and discerning what is packaging waste, provide you the data required for the submission plus access to the Rio platform, which enables you to monitor your waste production for other environmental targets and reporting. Please contact us on 0333 253 4406 or email [email protected]

Being obligated as a brand owner or as an importer makes little difference to a business’s obligations under EPR.

However, it does affect which data field on the EPR submission the business must input its data into. In this scenario, a business would report any branded packaging under the brand owner category, and any unbranded packaging around the branded packaging under the importer category.

PRN fees represent a contribution by a producer of any packaging to the costs associated with recycling. Contributions go directly to reprocessors or exporters accredited to issue PRNs. As PRN prices are determined by market forces, PRN contributions by producers can be price-variable.

pEPR fees will be set at levels that ensure producers of household packaging additionally cover the net costs to local authorities of collecting and managing household packaging waste. As producer funding will be distributed to local authorities by the scheme administrator, dependent on costs they incurred during the previous quarter, EPR fees are likely to be fixed across a compliance year.

If you wish to determine your potential pEPR fees following Defra’s base fees announcement, we have developed a pEPR fees calculator.

Those placing non-household packaging onto the UK market will need to report it in line with the new EPR requirements and purchase PRNs in line with their subsequent recycling obligation.

Non-household primary and shipment packaging won’t incur EPR fees where the obligated producer can provide evidence to regulators that the packaging is being supplied directly to a business end user, or it can be demonstrated that the packaging is for items that are for use in non-household settings and is therefore unlikely to become household waste.

EPR fees payable by producers will first be subject to eco-modulation from October 2026. This means the characteristics of packaging placed on the UK market in 2025 will dictate the modulation factor applied to producers’ EPR fee invoices in 2026.

Where producers use packaging that is more costly to recycle than other similar formats or is unrecyclable, this will incur higher EPR fees than similar types of packaging that are easy to recycle.

At least initially, producers are not expected to report the recyclability of their packaging, only more details on materials used, such as format. Instead, the EPR administrator will determine this based on the data submitted for 2025.

Looking to reduce pEPR fees?

We offer a suite of packaging and data analysis services that can help businesses to mitigate pEPR costs. Vist our “Reduce EPR Fees” web page for more information.

If your business is obligated to comply with the Packaging Waste Regulations it may also be obligated to comply with the Packaging (Essential Requirements) Regulations.