Identify if your organisation is impacted by packaging EPR | Ecosurety
Introduction
Packaging Extended Producer Responsibility (EPR) affects UK organisations that handle or supply packaging. This article explains how to determine if it impacts your organisation.
EPR obligation criteria
Your organisation has packaging EPR obligations if ALL of the following apply:
You’re an individual business, subsidiary or group (but not a charity)
Your annual turnover is £1 million or more (based on your most recent annual accounts)
You were responsible for supplying more than 25 tonnes of packaging to the UK market in the previous calendar year
You carry out any of the packaging activities listed below
All packaging supplied through the UK market counts towards the 25-tonne threshold. The definition of supply includes the activities listed below, any packaging discarded after import and any packaging sold to an end-user.
Packaging activities
If you carry out any of the government‑defined packaging activities, you may have obligations:
Supply packaged goods to the UK market under your own brand - This includes selling packaged goods with your logo, trademark, or other distinctive mark. The legal owner of the registered trademark (listed on the gov.uk registered trademark register) is usually responsible. This also applies if you pay another company to produce or pack goods under your brand, or place your branded goods on the UK market, or import goods for you.
Place goods into packaging when supplied - This includes packaging goods for your own or another organisation where the packaging is unbranded, as well as filling branded packaging where the brand owner is not UK‑established or is classed as a small organisation.
We improved and simplified this entire article to make the information easier to digest.
23 April 2025
We updated the section 'Packaging activities' with various clarifications for 'Place goods into packaging that’s unbranded when it’s supplied', 'Import products in packaging' and 'Sell empty packaging'. We also removed the link to the gov.uk EPR checker tool as is has been down for a significant amount of time.
25 February 2025
We added a new section 'Paper and plastic bag reporting'.
23 January 2025
We updated the Nation data guidance as it applies to any organisation that meets the criteria, not only those already obligated under EPR.
Packaging EPR basics
Identify if your organisation is impacted by packaging EPR
Extended Producer Responsibility (EPR) impacts most UK organisations handling packaging - find out if it applies to you.
9 January 2026
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Import products in packaging - This applies if you import packaged products from outside the UK and supply them to the UK market, even if you discard the packaging before sale. It does not apply if you import filled branded packaging for a large UK‑based brand owner, or filled unbranded packaging that a large UK producer later brands or fills before supply.
Own an online marketplace - This applies if you operate a website or app that allows non‑UK organisations to sell goods into the UK. Online marketplaces selling goods only from UK organisations are not included, and you should check whether other packaging activities apply.
Hire or loan out reusable packaging - This includes hiring or lending reusable packaging, such as pallets or food containers, to other UK organisations via a reuse system you manage.
Sell empty packaging - This includes any unfilled packaging you have manufactured or imported and then supplied, other than (directly or indirectly) to a large organisation that brands or pack/fills the packaging.
Sell filled packaging to an end user - If you sell filled packaging to a business or consumer end user and do not carry out any of the other six activities, it does not need to be reported under main EPR data submissions and will not incur compliance costs. This activity is subject to a separate nation of sale reporting requirement. However, this packaging still counts toward the packaging handled thresholds and should be counted only once if another activity applies.
Under EPR, one organisation takes full responsibility for each piece of packaging, including reporting and costs. Another organisation may separately report the same packaging under nation of sale data if it sells it directly to consumers. In most cases, overall responsibility sits with the brand owner or importer.
Packaging definition
For the purposes of EPR, packaging means all products made of any materials, of any nature, where the products are intended to be used to perform at least one packaging function:
Containment: restraining or enclosing, for example, bottles and cans
Protection: defence from harm, for example, bubble wrap
Handling: facilitating movement, for example carpet cores
Delivery: aiding the conveyance of products to the final user or consumer, for example a pallet
Presentation: for exhibition or display, including attracting attention, for example, a label or a brightly coloured box
Packaging or components are reportable once they have undergone their last substantial modification before pack/filling. A substantial modification changes the nature or features of the component (e.g., moulding, printing, laminating). Processes like blowing or sealing are not considered substantial modifications.
De minimis threshold
If your organisation does not meet ALL of the EPR criteria, you fall below the de minimis threshold and have obligations. Future mandatory labelling requirements may still apply, subject to government confirmation.
If you are below the threshold, continue to review your status as changes to your turnover, sales, or packaging activities may make you obligated in the future.
Charities are exempt under EPR and are treated as below the de minimis threshold, meaning other organisations in their packaging supply chain take on the obligations instead.
Groups and subsidiaries
Groups of companies can register and comply either individually or through a parent company on behalf of all or part of the group. A group is defined as a holding company and one or more subsidiaries. If their combined turnover and packaging handled meet the small or large producer thresholds, each relevant company is classed as obligated.
Where the combined group exceeds the large producer thresholds, all packaging‑handling companies in the group are large producers; if only the small producer threshold is met, they are all classed as small producers. Subsidiaries that meet thresholds only when combined should be registered under a parent group account.
A separate nation of sale data requirement may apply, requiring you to report which UK nation your packaging is supplied to. This can apply even if you are not obligated under the main EPR criteria.
You must submit nation data if you:
Supply filled or empty packaging directly to UK end users
Supply empty packaging to UK organisations that are small or not legally obligated
Hire or loan reusable packaging
Operate an online marketplace enabling non‑UK sellers to supply packaging or packaged goods to UK consumers
Import packaged goods for your own use and discard the packaging
Paper and plastic bag reporting
Large and small producers supplying paper or plastic bags in England must report the number supplied for the previous calendar year to the Environment Agency by 1 April.
This includes single‑use carrier bags, wholly or partly plastic food bags (for items such as bread or fruit), and unsealed paper bags with handles.
Next steps
Once you confirm you have an obligation, you must determine whether you are classed as a small or large organisation under packaging EPR, as this affects your reporting and financial obligations.
