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Guidance


EXTENDED PRODUCER RESPONSIBILITY FOR PACKAGING: WHO IS AFFECTED AND WHAT TO DO

 * English
 * Cymraeg

How UK organisations that supply or import packaging should comply with extended
producer responsibility (EPR) for packaging.

From: Department for Environment, Food & Rural Affairs and Environment Agency
Published 7 June 2022 Last updated 17 October 2024 — See all updates

Get emails about this page


CONTENTS

 1.  Check if you need to take action
 2.  Packaging definition
 3.  Packaging activities
 4.  What you may need to do
 5.  Period you must report on
 6.  Deadlines for reporting packaging data
 7.  If you’re a parent company, group or subsidiary
 8.  Check if you need to collect nation data
 9.  Collecting and reporting your packaging data
 10. Information about fees
 11. Getting help from a third party (compliance scheme)
 12. Get help and give feedback

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The way UK organisations responsible for packaging must carry out their
recycling responsibilities has changed.   

If you’re affected by extended producer responsibility (EPR) for packaging, you
may need to report your packaging data from 2023 onward, and in the future pay
fees based on your data .

EPR for packaging fees have been deferred for a year. You will not have to pay
any EPR packaging fees in 2024. However, you must still follow this guidance and
report your packaging data for 2023, and will be required to pay any related
fees in 2025 based on 2024 data. You must also continue to pay any fees due
under previous regulations. 

A separate guidance collection covers existing producer responsibility
regulations – you may need to meet both sets of regulations depending on your
situation.   


CHECK IF YOU NEED TO TAKE ACTION   

The regulations will apply to all obligated UK organisations that import or
supply packaging.    

You need to collect and report packaging data for a given year if all the
following apply:   

 * you’re an individual business, subsidiary or group (but not a charity)   
 * you have an annual turnover of £1 million or more, based on your most recent
   annual accounts up to 7 April   
 * you were responsible for importing or supplying more than 25 tonnes of
   packaging to the UK market in the previous calendar year  
 * you carry out any of the packaging activities   

If this guidance says you may need to take action, check the rest of the
guidance on packaging data - this will help you confirm whether you must record
and submit your data, and what you must submit.    


PACKAGING DEFINITION   

Packaging is any material that is used to cover or protect goods that are
supplied. It makes handling and delivering goods easier and safer. It includes
anything that’s designed to be filled at the point of sale, such as a coffee
cup.    

Find out more about what constitutes primary, secondary, tertiary and shipment
packaging. 

Packaging also makes goods look appealing for sale and may display a company’s
logo or brand. ‘Goods’ could include raw materials or manufactured items.   

There are detailed illustrations and examples in the ‘agreed positions and
technical interpretations’ guidance, produced by the environmental regulators. 

There are 2 versions of this document, both stored on the National Packaging
Waste Database: 

 * for data submissions for 2023, check version 3 
 * for data submissions from 2024 onwards, check version 5 


PACKAGING ACTIVITIES   

You may need to act if you do any of the following:   

 * supply packaged goods to the UK market under your own brand   
 * place goods into packaging 
 * import products in packaging   
 * own an online marketplace   
 * hire or loan out reusable packaging   
 * supply empty packaging   

Organisations that supply packaged goods to end users in the UK may need to
collect ‘nation data’. You can find out more about this in the ‘check if you
need to report nation data’ section.    


SUPPLYING GOODS TO THE UK MARKET UNDER YOUR OWN BRAND   

You may need to take action if packaged goods labelled with your own brand are
supplied to the UK market. A brand includes any of the following:   

 * a name  
 * a trademark   
 * any distinguishing mark   

For example, a UK confectionery company manufactures and packages sweets under
their own brand. It sells these sweets to a UK supermarket. The supermarket goes
on to sell the sweets to UK end users. In this instance, the confectionery
company must take action.  

However, the UK confectionery company would not need to take action if it
produced and packaged sweets under the UK supermarket’s brand, which the
supermarket then sold to UK end users. In this instance, the UK supermarket must
take action.   

You may also need to take action if you pay or license another company to do any
of the following for you:   

 * produce branded packaged goods that will be sold under your brand name   
 * pack branded packaged goods that will be sold under your brand name   
 * place your branded packaged goods on the UK market   
 * import branded packaged goods for you  


PLACING GOODS INTO PACKAGING 

If you place goods into packaging you may need to take action. This could be
goods you packaged for your own organisation or for another organisation. 


IMPORTING PRODUCTS IN PACKAGING   

You may need to take action if your organisation imports products from outside
the UK that are in packaging and goes on to supply these products to the UK
market.   

You may need to take action if you sell imported goods that are packed or filled
by a UK third party on behalf of a company that is not established in the UK. 

You may need to take action even if you discard packaging before selling the
goods.  

You do not need to take action if you import filled packaging that is:   

 * branded, and you’ve imported it on behalf of a brand owner that is
   established in the UK  
 * unbranded, and you go on to supply it to a ‘large’ organisation that applies
   its brand before supplying it on  

The ‘check if you’re a large or small organisation’ section explains which
organisations are classed as ‘large’.   

You can check a list of large producers who have submitted data to the
regulators. The list will be regularly updated.  


OWNING AN ONLINE MARKETPLACE   

Under EPR for packaging, you’re classed as carrying out the ‘owning an online
marketplace’ activity if you operate a website or app that allows non-UK
businesses to sell their goods into the UK. If you own an online marketplace,
you may need to take action.   

If your organisation owns a website or app that sells goods from UK
organisations only, this is not classed as carrying out the ‘owning an online
marketplace’ activity. However, you should check if you carry out any of the
other packaging activities.   


HIRING OR LOANING OUT REUSABLE PACKAGING   

If you hire or loan out reusable packaging, you may need to take action.

For example, some organisations hire or loan out wooden pallets to other
organisations for transporting goods. The wooden pallets are returned after use
and loaned out again.


SUPPLYING EMPTY PACKAGING   

You may need to take action if you manufacture or import empty packaging and
then supply it to a business that is not classed as a large organisation, or
supply this packaging to a large producer that does not fill the packaging. 

You can find out what the criteria are for a large organisation in the ‘check if
you’re a large or small organisation’ section.  


WHAT YOU MAY NEED TO DO   

You may need to:    

 * collect and report data on the packaging you supply or import  
 * pay a waste management fee  
 * pay scheme administrator costs 
 * pay a charge to the environmental regulator  
 * get packaging waste recycling notes (PRNs) or packaging waste export
   recycling notes (PERNs) to meet your recycling obligations   
 * report information about which nation in the UK packaging is supplied in and
   which nation in the UK packaging is discarded in – this is called ‘nation
   data’  

What you need to do depends on whether you’re classed as a ‘small’ or ‘large’
organisation. This is based on:   

 * your annual turnover   
 * how much packaging you supply or import each year   


CHECK IF YOU’RE A LARGE OR SMALL ORGANISATION   

You’re classed as a small organisation if either of the following apply:   

 * your annual turnover is between £1 million and £2 million and you’re
   responsible for supplying or importing more than 25 tonnes of packaging in
   the UK  
 * your annual turnover is over £1 million and you’re responsible for supplying
   or importing between 25 tonnes and 50 tonnes of packaging in the UK   

You will be classed as a large organisation if both of the following apply:   

 * you have an annual turnover of £2 million or more   
 * you’re responsible for supplying or importing more than 50 tonnes of
   packaging in the UK   

For 2023 data:

 * base your annual turnover on your business turnover up to 7 April 2023
 * base your packaging weight on  the amount you supplied or imported in the
   2022 calendar year

For 2024 data:

 * base your annual turnover on your business turnover up to 7 April 2024 
 * base your packaging weight on  the amount you supplied or imported in the
   2023 calendar year


IF YOU’RE A SMALL ORGANISATION   

To comply with the regulations, you should have recorded data about the
packaging you supply or import in the UK from either 1 January 2023 or 1 March
2023 - find out what period you must collect data on and the deadlines for
reporting. 

You will need to report your 2024 data by 1 April 2025.


IF YOU’RE A LARGE ORGANISATION   

To comply with the regulations, you may need to:   

 * record data about the empty packaging and packaged goods you supply or import
   in the UK from either 1 January 2023 or 1 March 2023 - find out what period
   you must report on  
 * create an account for your organisation 

From 2025, you may need to do the following, based on your 2024 data: 

 * pay a waste management fee  
 * pay scheme administrator costs  
 * pay a registration charge to the environmental regulator  
 * get PRNs or PERNs to meet your recycling obligations  
 * report data about packaging you supplied or imported – this includes
   packaging around raw materials 

Your waste management fee will initially be calculated based on packaging you’ve
reported as ‘household packaging’. Find out more about what’s classed as
household packaging.  

The deadline for reporting depends on which nation your organisation is based
in. Find out  more about the deadlines for reporting 

If you miss the deadline, you may need to pay a late fee.    

You’ll need to report data every 6 months.   

You may also need to collect and report nation data. Find out more about nation
data. 


PRNS AND PERNS   

A PRN (packaging waste recycling note) or PERN (packaging waste export recycling
note) is evidence that packaging waste has been recycled.   

You can get PRNs from accredited reprocessors. Reprocessors are responsible for
recycling packaging waste. You can also get PERNs from accredited exporters.  

By getting PRNs and PERNs, you work towards meeting your recycling
obligations.   

Recyling obligations will apply from 2025 onwards based on your 2024 data. 


PERIOD YOU MUST REPORT ON 

There are different reporting periods depending on what year you will be
reporting for. 


REPORTING PERIODS FOR 2023 

If you have all the required data recorded from 1 January 2023, you should
report this data. 

If you do not have all the required data recorded from 1 January, you must
report all of your data from 1 March 2023. If you report data that covers a
period starting from 1 March, this will be used to calculate a full year’s worth
of data.   


IF YOUR ORGANISATION IS BASED IN WALES 

Large and small organisations in Wales should comply with this reporting
schedule if they have the required data.  

If you do not have all the required data recorded from 1 January, you must
report all of your data from 17 July 2023. If you report data that covers a
period starting from 17 July, this will be used to calculate a full year’s worth
of data. 


REPORTING PERIODS FOR 2024 

Some of the rules are changing for reporting data from 2024 onwards. Find out
more about what you must report. 

If you have all the data under the new rules for 2024, you should report it in 2
batches: 

 * report your January to June data from 9 August 2024 and before 1 October
 * report your July to December data from January 2025 and before 1 April 2025 

If you do not have all the data required under the new rules, you should still
report in 2 batches: 

 * do not report any data relating to packaging supplied between 1 January and
   30 March 2024 
 * report data collected under the new rules from 1 April to 30 June – do this
   from 9 August 2024 
 * report your 1 July to 31 December data from 1 January 2025 – this data must
   follow the new 2024 rules 

If you do this, the data submitted will be used to calculate the 3 missing
months (January, February and March 2024). 


DEADLINES FOR REPORTING PACKAGING DATA 

Small organisations should have collected their 2023 packaging data but they do
not have to report it.

They should collect their 2024 data and submit it by 1 April 2025. 


LARGE ORGANISATIONS 

In England, Scotland and Northern Ireland you should submit by: 

 * 1 October 2023 to report for January to June 2023  
 * 1 April 2024 to report for July to December 2023  
 * 1 October 2024 to report for January to June 2024
 * 1 April 2025 to report for July to December 2024 

If you have not reported your data by the appropriate deadline, contact the
environmental regulator.

In Wales, you should have submitted data for July to December 2023 by 1 April
2024. You can include data from January to June 2023 if you have it. 


IF YOU’RE A PARENT COMPANY, GROUP OR SUBSIDIARY    

Parent companies and their subsidiaries can comply with EPR for packaging in
different ways. They can comply as:   

 * a whole group – the parent group creates an account and reports packaging
   data on behalf of each subsidiary that supplies packaging
 * individual subsidiaries – each subsidiary that supplies packaging creates an
   account and reports independently
 * a mix of the other ways – the parent company reports on behalf of some parts
   of the group, while other subsidiaries report for themselves   

If the parent group is reporting on behalf of some or all of its subsidiaries,
you’ll need separate packaging data for each subsidiary. Check the guidance on
creating your packaging data file for more information.  


IF YOU’RE PART OF A GROUP OF COMPANIES  

If you’re part of a group of companies, add up the turnover and weight of
packaging supplied or imported for all members of the group that supply or
import any packaging at all. If these totals meet the criteria for a small or
for a large organisation, then each of these members must comply with EPR for
packaging. It does not matter whether they meet the criteria individually.    

When calculating a total, do not include the turnover of any parts of the group
that do not supply or import packaging. These parts of the group do not need to
report packaging data.    


IF YOU’RE COMPLYING AS AN INDIVIDUAL SUBSIDIARY   

Create an account and report packaging data as an individual subsidiary, rather
than as part of your parent company.   

If you supply or import any packaging at all, you must report packaging data,
regardless of your annual turnover.   


IF YOU’RE COMPLYING AS A PARENT COMPANY FOR PART OF THE GROUP   

If some of your subsidiaries are going to report independently and some as part
of the group, you can create an account as a parent company for part of the
group and report on that part’s behalf.    

Do not include any subsidiaries that are creating an account independently.    

Every subsidiary that supplies or imports any packaging at all must report its
packaging data, regardless of its annual turnover.   


MORE INFORMATION AND EXAMPLES

There are detailed illustrations and examples in the ‘agreed positions and
technical interpretations’ guidance, produced by the environmental regulators. 

There are 2 versions of this document, both stored on the National Packaging
Waste Database: 

 * for data submissions for 2023, check version 3 
 * for data submissions from 2024 onwards, check version 5


CHECK IF YOU NEED TO COLLECT NATION DATA   

Nation data is information about which nation in the UK packaging is supplied in
and which nation in the UK packaging is discarded in.   

If your organisation must act under EPR for packaging, you must submit nation
data if you also do any of the following:  

 * supply filled or empty packaging directly to customers in the UK, where they
   are the end user of the packaging  
 * supply empty packaging to UK organisations that are either not legally
   obligated, or are classed as a small organisation   
 * hire or loan out reusable packaging  
 * own an online marketplace where organisations that are based outside the UK
   sell their empty packaging and packaged goods to UK users  
 * import packaged goods into the UK for your own use and discard the
   packaging   

You will need to submit your nation data for the 2024 calendar year by 1
December 2025.

Nation data should show where in the UK you’ve supplied packaging to a person or
business who’s gone on to discard it.   

Supplying packaging includes:  

 * selling  
 * hiring  
 * loaning  
 * gifting  

This also includes packaging that you’ve imported and then discarded.   

If you miss the deadline, you may need to pay a late fee.   


COLLECTING AND REPORTING YOUR PACKAGING DATA    

Your data submission must include the information about the:  

 * packaging activity – this is how you supplied the packaging   
 * packaging type – for example, if the packaging is household or
   non-household  
 * packaging class - whether the packaging is primary, secondary, shipment or
   tertiary  
 * packaging material and weight    

Find out more about how to collect your packaging data.  


INFORMATION ABOUT FEES   

EPR for packaging fees have been deferred for 1 year. Fees for packaging placed
on the market in 2024 were starting in October 2024. They will now start in
October 2025. 

Illustrative base fees for EPR are now available. The illustrative fees are a
first estimate, based on the best available evidence to date, and are not final
figures.

In future, the waste management fee will also vary depending on how easily the
packaging can be recycled. Your fee will be lower if you use packaging that is
easier to recycle. 

You will also have to pay a registration fee when you register your
organisation.

You must still report your packaging data for 2023. 


GETTING HELP FROM A THIRD PARTY (COMPLIANCE SCHEME)   

Compliance schemes are third parties that help organisations meet the EPR for
packaging requirements.   

Compliance schemes can:   

 * pay your registration fees on your behalf   
 * report your packaging data   
 * get PRNs or PERNs to meet your recycling obligations   

A compliance scheme cannot register your organisation on the service and you
will have make your waste management payments yourself.     

If you choose to work with a compliance scheme, you should make sure they appear
on the compliance scheme public register.    


GET HELP AND GIVE FEEDBACK 

If you have any questions, contact the packaging team.  

Email: packaging@defra.gov.uk

Defra is looking for waste and packaging professionals to join a user panel to
help improve our services. Find out more information and how to take part in
resources and waste research sessions.


UPDATES TO THIS PAGE

Published 7 June 2022
Last updated 17 October 2024 + show all updates
 1.  17 October 2024
     
     A new edition of the regulators' ‘agreed positions and technical
     interpretations’ guidance has been published - this updates the version
     number where it is mentioned.

 2.  15 August 2024
     
     This updates dates and deadlines for reporting 2024 data. It adds a link to
     the illustrative base fees, which have now been published separately.

 3.  31 July 2024
     
     Updated reporting start date for the 1 January to 30 June period to from 1
     July to 9 August 2024. Defra is looking for waste and packaging
     professionals to join a user research panel to help improve our services. A
     link to more information about how to take part has been added.

 4.  9 July 2024
     
     Minor updates around deadlines and definitions for clarity, based on user
     research feedback. Linking to the agreed positions guidance from the
     section on how parent companies should report data, for examples.

 5.  2 May 2024
     
     Adding link to the newly published list of large producers on the report
     packaging data service.

 6.  16 April 2024
     
     This small update fixes the collection period and reporting deadlines for
     nation data - the first report of nation data will be for the 2024 calendar
     year and must be submitted by 1 December 2025

 7.  28 March 2024
     
     This change explains that the list of large producers on RPD will be
     published once the data is ready.

 8.  11 March 2024
     
     New reporting regulations come into force on 1 April. This guidance has
     been updated to with some small changes of wording to align with these
     regulations, and a link to guidance that gives more detail on the changes.

 9.  23 January 2024
     
     Changed detail about small producers under ‘What you may need to do’,
     specifying more clearly that they should collect data but don’t yet have to
     report.

 10. 19 December 2023
     
     Clarification in the deadlines section that small organisations are only
     obligated to collect the data, not report it, and giving early warning that
     they'll have to collect and report in 2024. Signposting the specific period
     obligated to report in Wales from July to December, but that data for
     January to June 2023 can also be reported in April 2024. Changing 'they' to
     'you' when appropriate for style. Fixed typo in the contact email link.

 11. 18 October 2023
     
     We've added a link so that you can give feedback about this guidance.

 12. 21 September 2023
     
     An update to match regulations: where packaging is decribed as 'imported,
     emptied and then discarded', that's been changed to 'imported and
     discarded' throughout.

 13. 13 September 2023
     
     This update adds a recent decision by the English and Scottish regulators:
     they will take no enforcement action as long as organisations submit
     packaging data by 31 May 2024.

 14. 16 August 2023
     
     The report packaging data service is now live. This update adds a link to
     that service.

 15. 25 July 2023
     
     There's been a decision to defer extended producer responsibility for
     packaging fees for one year. This update reflects that, and also explains
     that other timescales have not changed - producers still have to report
     packaging data for 2023.

 16. 28 June 2023
     
     The service for reporting data is now scheduled to go live in August 2023.
     This update reflects that.

 17. 6 June 2023
     
     Added Welsh translation

 18. 17 March 2023
     
     We’ve changed the title of the guidance as the regulations are now in
     force. We’ve made minor changes to the style, order, and some terminology
     to make the guidance clearer and to reflect the fact that the regulations
     are now in force. We’ve also updated the following sections, to make them
     clearer: Packaging activities; What you may need to do; PRNs and PERNs;
     Check if you need to report nation data; Collecting and reporting your
     packaging data; Information about fees. We’ve added a new section titled
     ‘When to collect and report your data for 2023’.

 19. 17 January 2023
     
     We've added a link to the compliance scheme public register.

 20. 22 December 2022
     
     We've added a link to a service that helps you to check if you need to
     report packaging data.

 21. 24 November 2022
     
     We’ve made minor changes throughout the guidance to make it clearer. The
     second packaging activity has been updated to say: ‘pack or fill packaging
     that’s unbranded when it’s sold’. We’ve made it clear that you will not
     need to take action if you import packaged goods on behalf of another
     organisation. In this case, the organisation who you import the goods for
     will need to take action. Small organisations must create an account and
     register from January 2024. Large organisations must create an account and
     register from July 2023. We’ve removed text about ‘collecting and
     submitting your packaging data’ and added a link to new guidance on how to
     collect your packaging data.

 22. 10 October 2022
     
     Added translation

 23. 6 October 2022
     
     There are minor format and style changes throughout to make the guidance
     clearer and easier for people to use. We’ve added a packaging definition,
     information about PRNs and PERNs, street bin waste, and compliance schemes.
     We’ve updated the packaging activities section and the information about
     nation data. We’ve also updated the packaging categories, the household and
     non-household waste section, the ‘get help’ email address. We’ve clarified
     that the regulations apply to packaging that’s supplied to consumers and
     businesses. We’ve also clarified how to submit information about reusable
     packaging and how parent companies, groups and subsidiaries can comply with
     the regulations.

 24. 7 June 2022
     
     First published.


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 * Packaging (Essential Requirements) Regulations: guidance notes
 * Packaging data: what to collect for extended producer responsibility
 * Packaging waste: producer responsibilities
 * Check if you need to report packaging data
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