Extended Producer Responsibility for packaging waste – small producer obligations

Under EPR for packaging there are new obligations for a wider range of businesses than has been the case previously

Small producer packaging reporting under the 2025 packaging EPR Regulations

Since 2025, the updated packaging Extended Producer Responsibility (pEPR) Regulations for 2024 packaging activities have come into effect, replacing the previous reporting requirements. Under these rules, small producers are required to report the type, amount, and handling of packaging on an annual basis.

If your business falls under this category, you should already be collecting accurate packaging data to ensure compliance with the current pEPR reporting framework. This includes tracking packaging by material, class (primary, secondary, tertiary, or shipment), weight, and household drink containers. Proper data collection now will make future pEPR submissions faster and more accurate.

Question Mark

Is your business classed as a 'small producer' under Packaging EPR Regulations?

Under the UK Packaging Waste Regulations, a ‘small producer‘ is any business that is:

  • Established in the UK
  • Performs a packaging producer activity*
  • Has an annual turnover that exceeds £1m
  • Handles more than 25 tonnes of packaging and/or packaging materials

Any business that handles over 50 tonnes of packaging that has been placed on the UK market and has an annual turnover that exceeds £2m a year is classed as a ‘large producer’. These producers have greater responsibilities under EPR.

Take the obligation test

*A business has handled packaging if it:

  • Supplies (either directly or indirectly) packaging carrying its brand, name, trademark, or other distinctive mark
  • Imports filled packaging that carries no distinctive markings denoting ownership
  • Imports or manufactures empty packaging and supplies it for another business that is not a large producer to use
  • Fills packaging which is not the responsibility of a large producer to report
  • Leases out reusable packaging for others to use
  • Imports packaging and discards it in the UK
  • Is the first UK owner of packaging
  • Operates an online marketplace through which foreign companies supply packaging or packaged goods to the UK market
  • Sells packaged goods, even if they carry another obligated business’s branding, to UK consumers
Data Reporting

Small producers are required to report, in April, the packaging data they have collected on the type and amount of packaging they handled in the previous calendar year. The first report was due in Q1 2025, covering activities from 2024.

Data must be reported in kilograms (kg) and include the following details:

  • Packaging activity – e.g., selling, filling, brand owner, importer

  • Packaging class – primary, secondary, tertiary, or shipment packaging

  • Packaging material – e.g., plastic, paper, metal

  • Packaging weight in kilograms (kg)

  • Household drink containers – any packaging likely to end up as beverage containers in households

Small producers do not need to split plastic into rigid or flexible categories; all plastic should simply be reported under “plastic.”

To report their data, small producers must first register for EPR via the new government portal, ‘Report Packaging Data’.

In some cases, small producers may also be required to submit additional reports about where they supplied packaging in the UK.

This approach simplifies reporting while ensuring compliance with packaging Extended Producer Responsibility requirements.

Fees

Unlike large producers, small producers do not have to pay fees to regulators that will be spent on ensuring packaging waste is collected and recycled. Small producers will still need to pay a small fee to register with the environmental agency of the UK nation(s) they operate in.

For a more detailed explanation of how Extended Producer Responsibility for Packaging will work and what it might mean for your business, request a copy of our white paper.

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Why Valpak?

With 25 years’ experience as the UK’s largest producer compliance scheme, we have data knowledge and the systems in place to assist with the varying requirements of this legislation, plus the experience to handle compliance on our customers’ behalf.

We provide the following services to help affected businesses ensure they are in the best possible position ahead of the implementation of this new legislation:

  • Free EPR webinars
  • Free, high-level cost implication assessment
  • Detailed EPR assessment, including cost modelling and benchmarking
  • Data collection service via Data Insights (where data is not sufficient)
  • Data visibility via the Valpak Insight Platform
  • Consultancy – A detailed look at assessment recommendations, end market research, and advice on the next steps

Our service is bespoke, which means we can offer as much or as little support as required. Contact us today!

 

Make an Enquiry

To find out more about how we can help your business to prepare for Extended Producer Responsibility, contact one of our experts on 03450 682 572 or complete our enquiry form.