Extended Producer Responsibility, usually shortened to EPR, puts waste costs and reporting duties on businesses that place certain products or packaging on the market. Your responsibility depends on what you supply, how it reaches the UK and which legal entity carries out the activity.
UK businesses often use “EPR” as shorthand for packaging EPR. Producer responsibility also covers electrical equipment, batteries and end-of-life vehicles. Registering for packaging does not settle your duties for the product inside it.
What packaging EPR changes
Under packaging EPR, producers fund the management of household packaging waste. An obligated business registers, reports packaging data and pays the charges for its producer tier. Large producers also acquire PRNs or PERNs for their recycling obligations and pay household waste disposal fees to PackUK.
The producer is a legal role
Responsibility can follow the brand owner, importer, packer, empty-packaging supplier or online marketplace. The business physically handling the pack is not necessarily the producer.
The return follows the packaging
You report material, activity, class and type. Some packaging also needs nation data, a plastic subtype or a RAM rating.
The 2026 packaging threshold test
Start with annual turnover and the weight of packaging supplied or imported. For 2026 reporting, use packaging handled from 1 January to 31 December 2025. A corporate group must test the relevant UK companies together, not subsidiary by subsidiary.
| Annual turnover | Packaging supplied or imported | 2026 position |
|---|---|---|
| £1 million or less | Any amount | No obligation under this threshold test |
| More than £1 million | Less than 25 tonnes | No obligation under this threshold test |
| More than £1 million | 25 to 50 tonnes | Small producer |
| More than £1 million to £2 million | More than 50 tonnes | Small producer |
| More than £2 million | More than 50 tonnes | Large producer |
Large producers report every six months. The deadline for data covering 1 January to 30 June 2026 is 1 October 2026. Small producers report annually, with the next deadline on 1 April 2027. Registration is annual for both tiers.
One product, four different questions
Consider a UK business importing a cordless kitchen appliance in a printed box. Its product record supports four compliance calculations. The business still files and pays for each obligation separately.
| Rules | What they examine | Useful source record | Destination |
|---|---|---|---|
| Packaging EPR | Box, insert, film, labels and shipment packaging | Packaging bill of materials plus UK supply data | RPD service, environmental regulator and PackUK |
| RAM | Recyclability of relevant household packaging | Construction, size, colour and test evidence | Reported within packaging EPR data |
| Plastic Packaging Tax | Finished plastic packaging and recycled content | Component mass and recycled-content evidence | HMRC |
| WEEE | The electrical appliance placed on the UK market | EEE category, weight, units and household status | Environmental regulator or compliance scheme |
RAM sits inside packaging EPR
Large producers use the Recyclability Assessment Methodology to rate relevant household packaging red, amber or green. PackUK uses the ratings to modulate fees, which can make less recyclable packaging more expensive. RAM forms part of packaging EPR and does not replace the packaging return.
For household packaging supplied during 2026, producers use RAM 1.1 for the 2026 reporting period. PackUK published RAM 2027 for packaging supplied in 2027. Choosing a version by submission date instead of supply period can attach the wrong assessment to a component.
Assess separable components with the evidence required by the methodology. A bottle may receive a different rating from its closure or sleeve. Keep the answers, supporting evidence and effective date so that a redesign does not overwrite an earlier assessment. Our 2026 RAM guide covers the component workflow.
Plastic Packaging Tax uses a different test
Plastic Packaging Tax, or PPT, is an HMRC tax on qualifying finished plastic packaging components containing less than 30% recycled plastic. Registration applies when a business manufactures or imports 10 tonnes or more within the relevant forward-looking 30-day or backward-looking 12-month test. From 1 April 2026, the rate is £228.82 per tonne.
The same plastic tray can fall within PPT and packaging EPR. For EPR, you establish the producer activity and packaging classification. HMRC looks at who manufactured or imported the finished component, any exclusion or exemption, and its recycled-plastic content.
WEEE follows the equipment
Businesses placing electrical or electronic equipment on the UK market register each year. A producer placing less than 5 tonnes on the market can register directly as a small producer. At 5 tonnes or more, it joins a producer compliance scheme. The WEEE record covers equipment category, units, weight and household status. Packaging weight belongs in the packaging return.
The 2025 WEEE amendments changed producer responsibility for some sales made by non-UK suppliers through online marketplaces. Marketplace operators should test their position instead of assuming the overseas seller holds every obligation. Read the UK WEEE compliance guide or compare packaging, WEEE and battery data.
Build one product record, then separate the calculations
Give each SKU a stable identifier and version date. Link its product specification, packaging components and battery data. Match sales and imports by legal entity, market route and date. Your reporting process can reuse the source records while keeping each legal calculation separate.
- Identify the legal entity and its role for each route to market.
- Version the product, packaging and component weights.
- Store RAM evidence and recycled-content evidence as different records.
- Generate packaging EPR, PPT and WEEE outputs separately.
- Reconcile each output to units supplied, imported or manufactured.
A missing closure weight affects packaging EPR and may affect PPT. A missing net appliance weight affects WEEE but should not be filled with the gross packed weight. Reusing source data cuts collection work, while separate calculations prevent one error from spreading across several returns.
Questions people ask about EPR
Does EPR apply only to manufacturers?
No. Packaging obligations can arise from brand ownership, importing, packing, supplying empty packaging or marketplace activity. Apply the producer activity rules to the legal entity and sales route.
Is Plastic Packaging Tax included in an EPR fee?
No. HMRC administers PPT. Packaging EPR registration, reporting, recycling evidence and waste disposal fees follow the packaging regulations. Budget for both when the same component meets both sets of conditions.
Does a compliance scheme remove legal responsibility?
A scheme can perform specified work, but the producer should retain source evidence, review submitted figures and understand which payments it must make directly.
Prepare accurate EPR reports without rebuilding spreadsheets
Remedy EPR automates data imports and calculations, detects compliance errors and keeps evidence ready for review.
Requirements checked against current GOV.UK guidance for packaging EPR, producer thresholds, RAM, Plastic Packaging Tax and WEEE producer responsibilities. Check the latest guidance before filing because requirements may change.