Packaging extended producer responsibility, usually shortened to pEPR, changes who pays for dealing with packaging waste in the UK. Instead of councils and taxpayers carrying the cost of collecting and recycling household packaging, the businesses that put packaging on the market are being asked to pay for it. The system is run through the Packaging Waste (Extended Producer Responsibility for Packaging) Regulations 2024, and reporting began on 1 January 2025.
Most waste carriers and skip hire firms are not the main target. But many of them have some packaging obligation without realising it, and almost all of them have customers who do. This guide explains the system in plain terms, who is covered, what has to be reported, what the money pays for, and where waste businesses fit in. Rates, thresholds and deadlines are set by the regulations and by the scheme administrator, so check the current gov.uk guidance before you act on any detail here.
What pEPR Is
Extended producer responsibility is the idea that whoever creates a product, or in this case the packaging around it, should bear the cost of dealing with it at the end of its life. For packaging in the UK, that has been done for years through the packaging recycling note (PRN) system, where producers buy evidence that a tonnage of packaging has been recycled. That system continues.
What is new is a second layer: producers pay fees towards the cost of local authority collection, sorting and recycling of household packaging waste, and in due course for packaging that ends up in litter bins. The money is collected by a scheme administrator, PackUK, and passed to councils. The four UK environmental regulators, the Environment Agency, Natural Resources Wales, SEPA and the Northern Ireland Environment Agency, enforce the regulations in their own nations.
The principle is that fees should also push producers to design packaging that is easier to recycle. The regulations provide for fees to vary by how recyclable the packaging is, with the intention of charging more for materials that are harder to recycle. Check PackUK for the current fee tables and when any variation applies, because that part has been phased in.
Who Counts as a Producer
The regulations place the obligation on businesses based on what they do with packaging, not on what they sell. You can be covered if you:
- supply packaged goods under your own brand;
- pack or fill packaging, for example a food manufacturer or a contract packer;
- import packaged goods or packaging into the UK;
- sell packaging empty, such as bags, boxes, pallets or wrap, to someone else to use;
- hire or loan out reusable packaging; or
- run an online marketplace through which other sellers supply packaging.
The guidance explains each activity, and a business often has more than one. Where several businesses handle the same piece of packaging, the regulations allocate responsibility between them by activity, so read the activity definitions carefully.
Thresholds: Do the Rules Apply to You?
The regulations draw a line by turnover and by tonnage of packaging handled in a year. Businesses below the lower thresholds have no obligation under the regulations. Above them there are two tiers:
- Small producers have a lower turnover and tonnage and have reporting duties, but they do not pay the disposal fees.
- Large producers have both higher turnover and higher tonnage. They must report more often and in more detail, and they pay the fees.
The exact turnover and tonnage figures, and how turnover is measured, are set out in the regulations and on gov.uk. We have not repeated numbers here because a mistake could cost you a missed report. Do the check yourself on the current guidance, using your last full financial year.
Two cautions. Turnover is usually measured for the whole group, not just one company in it. And tonnage is the weight of packaging you handle, not the weight of the goods inside, so a business with a low turnover that handles a lot of heavy packaging can still be caught.
What Has to Be Reported
Reporting is about data. For each type of packaging you handle, you need to be able to say what it is made of, how much of it there is by weight, which of the activities above it relates to, and where it ends up: household, or non-household such as hospitality, workplaces or industrial use. Packaging is grouped by material, such as aluminium, glass, paper and card, plastic, steel and wood, with further breakdown for some materials.
Large producers report more often than small ones, and the reporting dates are set out in the regulations. Small producers report once a year. Reporting is done online, and the regulators can audit the figures.
Practical steps for getting the data right:
- List your packaging. Go through your products, your supply chain and your deliveries. Include transit packaging such as pallet wrap and cartons, not only what the customer sees.
- Get supplier data. Ask suppliers for the weight and material of packaging they supply. Where they cannot tell you, weigh samples.
- Work out who the responsible party is. Check which activity covers each item, so you do not report packaging that another business is responsible for, and do not miss packaging that is yours.
- Keep your working. Records of how you reached the numbers need to be kept in case the regulator asks.
What the Fees Pay For
The fees are used mainly to pay local authorities for the cost of collecting and managing household packaging waste, so that councils are paid for services they used to fund themselves. Over time the money is also meant to pay for packaging in public litter bins. The regulations also support a separate scheme for drinks containers, which is covered by the planned deposit return scheme in England, Scotland and Northern Ireland.
This is why a business that sells to other businesses, with little consumer packaging, can still have obligations. The regulations distinguish between household and non-household packaging in the data, and the early focus of the fees is household packaging. Check the current guidance on whether non-household packaging is within the fee scope for your activities, and on how your packaging should be classified.
Where Waste Carriers and Skip Hire Firms Fit
Most waste firms do not produce packaged consumer goods, so there is nothing to report on that side. There are a few places where the regulations can still reach you:
- Selling empty packaging. A skip hire company that sells dumpy bags, pallet wrap or boxes to customers is supplying empty packaging. Whether that makes you a producer depends on your turnover and the tonnage you handle, so run the threshold check.
- Own-use packaging. Packaging that your business uses in its own operations, such as wrap on parts or pallets, can fall within the data if the other criteria are met.
- Retail or trade counters. If you also run a trade counter selling materials in packaging under another brand, you may be a seller in a way that matters.
The other angle is your customers. Retailers, manufacturers and food businesses that are producers will increasingly ask what happens to the packaging waste they send for collection. That is where a waste transfer note with an accurate waste description, correct EWC code and a clear separation of streams helps. If you can tell a customer exactly which stream is paper and card, which is plastic film and which is residual, you have an advantage over a carrier who writes “mixed waste” on everything.
For commercial customers in England, the workplace separation rules explained in our Simpler Recycling guide push in the same direction, as do the Welsh rules in our article on workplace recycling in Wales. The common thread is cleaner, better-separated streams.
PRNs and Recycling Evidence
If you hear the terms PRN and PERN, they refer to evidence notes that accredited reprocessors and exporters issue when packaging waste is recycled. Producers with a recycling obligation buy them to show that the tonnage they are responsible for has been recycled. The money paid for these notes helps fund recycling infrastructure. They sit alongside the new fees rather than replace them.
For waste businesses, the relevant point is that reprocessors and exporters need proper evidence of what they have received and its source. If your waste description and transfer notes are poor, you are making their job harder and your waste less attractive to buy. Keep transfer notes complete and consistent.
What To Do Now
- Check whether you or your customers are producers, using the current thresholds on gov.uk.
- If you may be covered, register with the regulator for your nation and start collecting packaging data for each reporting period.
- If you sell empty packaging, add it to your data and check the activity definitions.
- Review how you describe packaging waste on transfer notes, and keep separated streams separate.
- Put the reporting dates in your diary and check PackUK for updates on fees.
Try it yourself
Create a one-off transfer note without an account.