Extended Producer Responsibility (EPR): What UK Packaging Producers Need to Know
Extended Producer Responsibility (EPR) represents one of the most significant changes to UK packaging legislation in recent years. Introduced to replace the previous Producer Responsibility Packaging Regulations, EPR places greater accountability on businesses for the full life cycle of the packaging they place on the UK market.
At SystemPAK, we work closely with food producers, manufacturers and packers across the UK, so we understand how these changes affect real businesses in practical terms. This guide explains what EPR is, who it applies to, what data must be reported and how to stay compliant.
What is Extended Producer Responsibility (EPR)?
Extended Producer Responsibility is a UK government scheme designed to improve recycling outcomes by shifting the full net cost of packaging waste management onto producers.
Under EPR, businesses that place packaging onto the UK market are responsible for the costs associated with managing that packaging once it becomes waste. This includes collection, sorting, recycling and disposal.
The aim is to encourage:
- Better packaging design
- Increased recyclability
- Reduced environmental impact across the supply chain
EPR officially replaced the previous PRN-based Producer Responsibility Packaging Regulations, introducing more detailed reporting and new cost structures.
Who needs to comply with EPR (Extended Producer Responsibility)?
EPR applies to UK organisations that handle or supply packaging, including:
- Food and drink manufacturers
- Ready-meal producers
- Delis and food processors
- Pet food manufacturers
- Importers and brand owners
- Businesses selling packaged goods to UK households
Compliance is based on turnover and tonnage of packaging handled, assessed at group level.
Small Producer vs Large Producer: What’s the difference?
Small Producer
You are classed as a Small Producer if:
- Your latest annual turnover is over ÂŁ1 million, and
- You handle more than 25 tonnes of packaging per year, and
- Either your turnover is below ÂŁ2 million or your packaging tonnage is below 50 tonnes
Reporting requirement:
- Annual reporting only
Large Producer
You are classed as a Large Producer if:
- Your latest annual turnover is over ÂŁ2 million, and
- You handle more than 50 tonnes of packaging per year
Reporting requirement:
- Biannual reporting
- Full obligation applies
What packaging data must be reported?
Producers must report their obligated packaging data for the period 1 January to 31 December.
All data must be:
- Reported in kilograms
- Split by packaging class
- Split by material type
- Identified by whether it carries your own branding
Packaging classes you must report
- Primary packaging – packaging directly around a single sales unit
- Secondary packaging – packaging grouping multiple sales units
- Tertiary packaging – pallet-level or distribution packaging
- Shipment packaging – outer or transit packaging supplied to households
This level of detail is essential under EPR and applies regardless of packaging format, including rigid containers, tubs, trays, films and sleeves.
When do you need to report?
Small Producers
- Annual submission
- Deadline: 1 April following the obligation year
Large Producers
- Biannual submissions
- 1 January to 30 June → due by 1 October
- 1 July to 31 December → due by 1 April of the following year
All submissions are made through the government’s Report Packaging Data (RPD) platform.
What costs are introduced under EPR?
EPR introduces a revised cost structure made up of:
- Existing recycling obligations (PRN-related costs)
- Modulated disposal fees (for household packaging only)
These fees are designed to reflect how recyclable packaging is, meaning material choice and packaging design now have a direct financial impact.
How SystemPAK supports EPR-ready packaging
While SystemPAK does not provide regulatory advice, we support our customers by supplying:
- Clearly specified packaging materials
- Consistent product data to support accurate reporting
- Packaging formats suitable for recycling streams
- Advice on selecting packaging aligned with sustainability goals
From tamper-evident containers and freezer-grade tubs to trays, buckets and sleeves, our range is designed with real-world compliance and performance in mind.
Choosing the right packaging from the outset can simplify reporting, improve recyclability and reduce long-term cost exposure under EPR.
Key takeaways for producers
- EPR applies to most businesses handling packaging in the UK
- Reporting obligations depend on turnover and packaging tonnage
- Detailed material and packaging class data is mandatory
- Deadlines are strict and apply annually or biannually
- Packaging design now directly impacts compliance costs
If you would like support selecting packaging formats that align with EPR reporting requirements or sustainability objectives, the SystemPAK team is always happy to help guide you through your options.
