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Circular economy · Packaging EPR

Extended producer responsibility for packaging: who reports, who pays

Extended producer responsibility for packaging makes the businesses that supply packaging in the UK pay for managing it once it is thrown away.

It is set by SI 2024/1332, which replaced the 2007 packaging regulations, and it bites on producers above £1 million turnover and 25 tonnes of packaging.

This guide covers the producer tests, the packaging data you report and when, how EPR fees are set, and how it fits with the Plastic Packaging Tax and deposit return.

Checked against 22 sources fromlegislation.gov.ukDefra / Environment AgencyDefraDefra / environmental regulatorsDefra / PackUKPackUKSee the sources

The regime

What packaging EPR is, and who runs it

Packaging EPR rests on two powers in Part 3 of the Environment Act 2021: producer responsibility obligations, and producer responsibility for disposal costs.

The rules themselves are in SI 2024/1332, which applies across the four nations and was amended from 1 January 2026 by SI 2025/1369.

The Producer Responsibility Obligations (Packaging Waste) Regulations 2007 were revoked on 1 January 2026, so any guidance citing them is out of date.

The scheme administrator is PackUK, which describes itself as “a Defra hosted function” acting for the four nations, not a separate company.

UK Packaging PRO was appointed as the producer responsibility organisation from 1 April 2026, with PackUK keeping final decisions on producer fees and local authority payments, according to the appointment announcement.

  1. 1 Jan 2025
    SI 2024/1332 in force

    Data reporting under the new regime.

  2. 21 Jan 2025
    PackUK launches

    The scheme administrator, a Defra-hosted function.

  3. Oct 2025
    First notices of liability

    Year 1 disposal fees invoiced.

  4. 1 Jan 2026
    Amendments in force; 2007 regime revoked

    SI 2025/1369.

  5. 1 Apr 2026
    UK Packaging PRO appointed

    PackUK keeps fee decisions.

  6. End Nov 2026
    Year 2 notices intended

    The first modulated fees.

Sources: SI 2024/1332; PackUK news (16 Jan 2025, 23 Mar 2026); PackUK operational plan

Am I a producer?

The producer tests: two limbs, two different years

Regulation 24 sets two tiers, and each has two limbs that must both be met.

A large producer had turnover of more than £2 million and supplied more than 50 tonnes of packaging; a small producer, more than £1 million and more than 25 tonnes.

So a business with £3 million turnover supplying 40 tonnes is a small producer, and a business with turnover of £1 million or less is outside both tiers whatever its tonnage.

The two limbs are measured in different years: turnover in the last financial year ending before 7 April in the year before the obligation year, from filed accounts, and tonnage two years before the obligation year.

Groups aggregate: under Schedule 9 paragraph 2, where the relevant group members together meet the test, every one of them is a large producer.

“More than”, not “or more”

Defra’s who is affected guidance says “£2 million or more”; the regulations say “more than £2,000,000”.

The regulations govern; the difference matters only at exactly £1 million or £2 million.

Producer tier checker

Small producer

Small producer under regulation 24(2)

  • Register, pay the annual registration fee, and report packaging data annually, by 1 April for the previous calendar year.
  • No disposal fees and no recycling obligations.

Indicative only. Tests from SI 2024/1332 reg 24: turnover is measured in the last financial year ending before 7 April in the year before the obligation year, tonnage two years before it. Group aggregation and producer class are not modelled. Nothing you entered was stored or sent.

Who pays what

Seven producer classes, different duties

Being a producer is only half the question: the class of producer decides which duties apply.

Sources: SI 2024/1332 regs 25, 35, 36, 60, as amended from 1 January 2026.
DutyLarge producerSmall producerProvision
Register and pay an annual registration feeYesYesSch 1 (charges)
Report packaging dataSix-monthly, plus annual dataAnnual, by 1 AprilRegs 35, 36
Recycling obligations (PRNs/PERNs)Yes, except where the only class is sellerNoReg 25(2)
Disposal feesOnly if household packaging was supplied, in a class other than sellerNoReg 60(1)
Recyclability assessmentWhere a liable producerNoReg 25(3)

Regulation 15(1) lists seven classes: brand owner, packer/filler, importer or first UK owner, distributor, online marketplace operator, service provider and seller.

Disposal fees fall only on a large producer that supplied household packaging in one of the first six classes, under regulation 60, so a large producer supplying only business-to-business packaging pays none.

Once packaging has been supplied by its first producer, a further supply does not make anyone else a producer of it, except a seller, under regulation 15(8).

The 2026 registration charges set by SI 2025/1369 regulation 12 are £2,842 for a large producer and £1,303 for a small one, or £1,803 and £696 through a compliance scheme, and the regulations provide for annual inflation increases from 2027.

Registration is with the environmental regulator for your nation, as Defra’s registration guidance explains, and Defra’s guidance for large producers says a compliance scheme cannot pay a producer’s disposal fees.

Packaging data

What you report, and when

Regulation 35 sets the reporting calendar for large producers, and regulation 36 the annual deadline for small ones.

The next statutory deadline is 1 October 2026, for large producers’ January to June 2026 data.

Data is reported by packaging material and weight, and liable producers must also assess the recyclability of what they supply, under regulation 25(3).

PackUK’s RAM 2027 announcement sets the version to use: RAM 1.1 covers packaging supplied in 2026, with submissions due 1 October 2026 and 1 April 2027, and RAM 2027 covers 2027 and is not retrospective.

The data is the same data a circular economy programme or a Scope 3 inventory needs, which is why many businesses build one system for all three.

Source: SI 2024/1332 regs 35(2)–(4), 36(2)
DeadlineWhoData
1 OctoberLarge producersJanuary–June of the same year
1 AprilLarge producersJuly–December of the previous year, and the annual data
1 AprilSmall producersThe previous calendar year

EPR fees

How packaging EPR fees are set

The 2025/26 base fees are the only final per-material fees; 2026/27 fees will be the first modulated by recyclability.

Source: Defra / PackUK, Extended producer responsibility for packaging: 2025 base fees.
Material2025/26 base fee (£ per tonne)
Glass192
Paper and card196
Steel259
Other259
Aluminium266
Wood280
Plastic423
Fibre-based composite461

Fees are charged on household packaging, per tonne and by material, and the fee year runs from 1 April to 31 March under regulation 57(1).

PackUK’s operational plan says it issued the first notices of liability in October 2025 and invoiced £1.46 billion for year 1.

For 2026/27 it forecasts total fees of £1.558 billion, but says it cannot calculate confirmed year 2 disposal fees until all producer data is received and checked, and intends to issue notices by the end of November 2026.

Illustrative 2026/27 figures published in December 2025 carried the warning that they were likely to change significantly, so this page does not reproduce them as a price.

From 2026/27, fees are modulated by recyclability rating: red-rated packaging carries a factor of 1.2, rising to 1.6 in 2027/28 and 2.0 in 2028/29, and green-rated packaging is discounted.

Fees are paid in quarterly instalments unless the notice says otherwise, and regulation 68 makes non-payment 50 days after the due date a breach open to civil sanctions.

Recycling obligations

PRNs and PERNs: the second liability

Source: SI 2024/1332 Schedule 5, Tables 1 and 2.
Material202520262027202820292030
Plastic55%57%59%61%63%65%
Wood45%46%47%48%49%50%
Aluminium61%62%63%64%65%67%
Steel80%81%82%83%84%85%
Paper, board and fibre-based composite75%77%79%81%83%85%
Glass74%76%78%80%82%85%
Glass by re-melt75%76%77%78%79%80%

Packaging EPR did not replace the recycling obligations: a large producer, other than one acting only as seller, must still recycle a share of its packaging by material.

It proves compliance only by acquiring packaging waste recycling notes or export notes, under regulation 40, and notes for one material cannot be used for another.

The obligation is last year’s tonnage multiplied by this year’s target in Schedule 5, so a 2026 obligation uses 2025 tonnage.

Notes for waste received in December can count towards that year or the next.

The seams

Plastic Packaging Tax and deposit return alongside EPR

The Plastic Packaging Tax is a separate regime, run by HMRC under the Finance Act 2021, with its own 10-tonne registration threshold and no offset against EPR.

The same tonne of plastic packaging can therefore carry both an EPR fee and the tax.

PET plastic, steel and aluminium drinks containers of 150 ml to 3 litres already pay no EPR disposal fee and need no recyclability assessment, because they will move to the deposit return scheme that starts on 1 October 2027.

Glass drinks containers stay in EPR in England and Northern Ireland.

Regulation 136 is the fallback: if no deposit scheme is running anywhere in the UK by 1 January 2028, the drinks container carve-outs fall away, with fees from the 2028/29 assessment year.

£228.82/t
Plastic Packaging Tax from 1 April 2026, on components under 30% recycled plastic
FA 2021 s.45
1 Oct 2027
Deposit return scheme starts in England and Northern Ireland
SI 2025/67 reg 1(2)

What changes

Packaging EPR in 2026 and 2027: the dates to plan for

All dates from the instruments and PackUK publications cited on this page.
DateWhat happensSource
1 October 2026Large producers report January–June 2026 data (RAM 1.1)SI 2024/1332 reg 35(2); PackUK
End of November 2026PackUK intends to issue 2026/27 notices of liability, the first modulated feesPackUK operational plan
1 January 2027RAM 2027 applies to packaging supplied from this datePackUK, 1 July 2026
1 April 2027Annual and H2 2026 data due; Plastic Packaging Tax mass balance and pre-consumer changesRegs 35–36; FA 2026 s.107
1 October 2027Deposit return scheme starts in all four nationsSI 2025/67 and devolved equivalents
1 January 2028Regulation 136 fallback date if no deposit scheme is runningSI 2024/1332 reg 136

For where EPR sits in circular economy policy, see is there a UK Circular Economy Act and the Circular Economy Growth Plan tracker.

For packaging redesign or data systems, our circular economy consultancy guide covers what outside support delivers, and every UK disclosure duty is on the ESG reporting requirements map.

To talk your producer position through, you can book a free 15-minute call.

Frequently asked

Questions people ask

What is extended producer responsibility for packaging?

Extended producer responsibility (EPR) for packaging makes the businesses that supply packaging pay for managing it once it becomes waste. In the UK it is set by the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024, SI 2024/1332, across all four nations. Producers report packaging data; large producers also meet recycling obligations and, if they supplied household packaging, pay disposal fees to the scheme administrator, PackUK.

Who has to comply with packaging EPR?

A business is a large producer if its turnover was more than £2 million and it supplied more than 50 tonnes of packaging, and a small producer if its turnover was more than £1 million and it supplied more than 25 tonnes. Both limbs must be met. Turnover is taken from the last financial year ending before 7 April in the year before the obligation year, and tonnage from two years before it.

When are packaging EPR reports due?

Large producers report six-monthly: by 1 October for January to June of that year, and by 1 April for July to December of the previous year, with their annual data also due by 1 April. Small producers report once a year, by 1 April, for the previous calendar year. The next deadline is 1 October 2026 for large producers' January to June 2026 data.

How much are packaging EPR fees?

The only final per-material base fees are those for 2025/26, in pounds per tonne: glass 192, paper and card 196, steel 259, other 259, aluminium 266, wood 280, plastic 423 and fibre-based composite 461. Fees for 2026/27 have not been confirmed; PackUK intends to issue notices of liability by the end of November 2026, and published illustrative figures are likely to change.

Do small producers pay EPR fees?

Small producers pay no disposal fees and buy no packaging recycling notes, but they must register, pay a registration fee each year and report their packaging data annually. Disposal fees fall only on large producers that supplied household packaging, in a producer class other than seller.

What is RAM in packaging EPR?

The recyclability assessment methodology rates packaging red, amber or green for recyclability, and fees are modulated by that rating from 2026/27. RAM version 1.1 applies to packaging supplied in 2025 and 2026; RAM 2027 applies to packaging supplied in 2027 and is not retrospective. The red-rating factor is 1.2 for 2026/27, rising to 1.6 and then 2.0.

Did EPR replace PRNs?

No. Large producers still have recycling obligations, met by buying packaging waste recycling notes (PRNs) or export notes (PERNs), on top of any disposal fees. The two are separate liabilities under the same regulations. The obligation is calculated on the previous year's tonnage multiplied by that year's recycling target.

How does packaging EPR interact with the Plastic Packaging Tax?

They are separate regimes with no offset. The Plastic Packaging Tax, run by HMRC, charges £228.82 per tonne from 1 April 2026 on plastic packaging with less than 30% recycled plastic, and has its own 10-tonne registration threshold. The same tonne of plastic packaging can be caught by both.

Are drinks containers in packaging EPR?

Glass drinks containers are. PET plastic, steel and aluminium drinks containers of 150 ml to 3 litres are already outside EPR disposal fees and the recyclability assessment, because they will fall under the deposit return scheme from 1 October 2027. If no UK deposit scheme is running by 1 January 2028, the regulations bring them back into EPR.

Who is PackUK?

PackUK is the scheme administrator for packaging EPR, appointed by the four UK governments and launched in January 2025. It is a Defra-hosted function, not a separate company. UK Packaging PRO was appointed as the producer responsibility organisation from 1 April 2026, with PackUK keeping decisions on fees and payments to local authorities.

Sources

Primary sources

Every figure, date and status on this page traces to the instrument’s owner. Secondary commentary is never the source for a number.

  1. legislation.gov.uk
    SI 2024/1332 — Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024

    The regime, as amended from 1 January 2026 by SI 2025/1369.

  2. legislation.gov.uk
    SI 2024/1332, regulation 15 — classes of producer

    The seven classes; reg 15(8) on resupply.

  3. legislation.gov.uk
    SI 2024/1332, regulation 24 — large and small producers

    "More than £2,000,000" and "more than 50 tonnes"; "more than £1,000,000" and "more than 25 tonnes".

  4. legislation.gov.uk
    SI 2024/1332, regulation 35 — reporting by large producers

    1 October and 1 April deadlines; sellers report 12-monthly.

  5. legislation.gov.uk
    SI 2024/1332, regulation 40 — PRNs and PERNs

    Compliance only through notes; December evidence can be carried forward.

  6. legislation.gov.uk
    SI 2024/1332, regulations 57 and 60 — assessment year and liable producers

    Disposal fees for large producers that supplied household packaging, not sellers.

  7. legislation.gov.uk
    SI 2024/1332, regulation 68 — payment of fees

    Quarterly instalments; civil sanctions after 50 days.

  8. legislation.gov.uk
    SI 2024/1332, regulation 136 — if no deposit scheme by 1 January 2028

    The fallback that would bring drinks containers back into EPR.

  9. legislation.gov.uk
    SI 2024/1332, Schedule 5 — recycling targets

    Targets by material, 2025 to 2030.

  10. legislation.gov.uk
    SI 2024/1332, Schedule 9 paragraph 2 — groups

    Every relevant group member is a large producer where the group meets the test.

  11. legislation.gov.uk
    SI 2025/1369, regulation 12 — registration charges

    £2,842 and £1,303; £1,803 and £696 through a compliance scheme.

  12. legislation.gov.uk
    Environment Act 2021, sections 50–51 and Schedules 4–5

    Producer responsibility obligations and producer responsibility for disposal costs.

  13. Defra / Environment Agency
    EPR for packaging: who is affected and what to do (updated 20 April 2026)

    Guidance; its "or more" threshold wording differs from the regulations, which govern.

  14. Defra
    EPR for packaging: what you must do as a small producer

    No disposal fees or PRNs for small producers.

  15. Defra / environmental regulators
    Register with the environmental regulator for EPR for packaging

    Registration and the annual fee.

  16. Defra / PackUK
    Extended producer responsibility for packaging: 2025 base fees

    Final 2025/26 fees per tonne, by material.

  17. PackUK
    Operational plan 2026 to 2027 (10 August 2026)

    Year 1 invoicing; year 2 forecast; notices by end of November 2026.

  18. PackUK
    PackUK: the new scheme administrator (16 January 2025)

    "A Defra hosted function, delivering on behalf of the four UK nations."

  19. PackUK
    UK Packaging PRO appointed (23 March 2026)

    Appointment from 1 April 2026; PackUK keeps fee decisions.

  20. PackUK
    PackUK publishes RAM 2027 (1 July 2026)

    RAM 1.1 for 2026 data; RAM 2027 for 2027, not retrospective.

  21. legislation.gov.uk
    Finance Act 2021, section 45 (revised) — Plastic Packaging Tax

    £228.82 per tonne from 1 April 2026.

  22. legislation.gov.uk
    SI 2025/67, regulation 1 — deposit return scheme commencement

    1 October 2027 in England and Northern Ireland.

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