EPR regulations in the UK: current obligations for retailers in relation to packaging
Extended Producer Responsibility (EPR) is a European regulation that makes manufacturers, importers and companies responsible for the life cycle of their products and packaging in accordance with the polluter-pays principle. EU countries can interpret the EPR regulations differently, which is why your obligations may vary from country to country. If you are shipping goods to the UK, you should therefore familiarize yourself with the exact regulations in the country in advance in order to avoid sanctions and be compliant. In the following article, we will give you an overview of the current EPR obligations in the UK and take a look at upcoming changes.
When am I obliged to register in the UK?
Unlike in Germany, where every company that places packaging on the market to private end customers is obliged to license and register the packaging, there are so-called volume and turnover thresholds in the UK with regard to compliance with extended producer responsibility. If you ship goods to the UK, you are obliged under the EPR to register your packaging if you have a branch there, generate an annual turnover of over 1 million pounds and put over 25 tons of packaging material into circulation.
The UK also differentiates between “Small Producers” (SP) and “Large Producers” (LP). Small producers fall under the listed volume and turnover thresholds and are only obliged to submit their packaging data at the beginning of the year.
You count as an LP if you have an annual turnover of more than 2 million pounds and put more than 50 tons of packaging material into circulation. Large Producers have been obliged to prepare an EPR report every six months since 2023 and will also be required to pay an EPR fee from October 1, 2025. This fee is based on the individual packaging types and quantities of the distributor.
Obligation to register and EPR fee in the UK
Both LPs and SPs in the UK are obliged to report information on their packaging types and quantities to the Department for Environment Food & Rural Affairs.
To do this, you must register online with the regulatory authority and submit your packaging quantities collectively. There is a fee for registration. In the UK, only traders declared as Large Producers are obliged to pay EPR fees.
Current developments
In addition to packaging, the current EPR areas in the UK also include electronic goods, batteries and vehicles. In future, these categories are to be expanded to include furniture and textiles. The current recycling targets for the existing categories are also to be increased in order to reduce the amount of waste. These measures will be accompanied by product adjustments on the part of companies.
You can find out which other regulations apply within the EU here.
Outlook: Mandatory labeling in the UK
From March 31, 2026, mandatory labeling for primary and shipping packaging is to be introduced in the UK. This obligation is to apply to all manufacturers without a threshold and inform consumers about the disposal of packaging. Plastic films are initially to be excluded from the introduction of mandatory labeling. From March 31, 2027, the obligation is to apply to all types of packaging.
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Waste separation in Denmark, Norway & Co.: standardised symbols used in the Nordic countries
A lot has happened in the Nordic countries in terms of waste separation in recent years: standardised symbols have been used in Denmark since 2017 to simplify waste separation for consumers and businesses. The use of the pictograms is voluntary. Norway, Sweden, Finland and Iceland have followed suit and have also introduced the ‘Nordic Pictograms’ system for waste separation. The symbols can be found not only on packaging, but also at recycling stations and in public spaces. The clear labelling makes it easier to dispose of waste correctly and ensures that more recyclable materials are reused.
PPWR update: an overview of recent developments
The European Union wants to implement more measures to promote sustainable packaging solutions. This is reflected in the currently hotly debated draft of the Packaging & Packaging Waste Regulation (PPWR), which was presented in November 2022. This regulation contains binding rules for packaging and packaging waste in the European single market and significantly expands the existing EU directives. However, the PPWR is not yet a done deal; it still has a few hurdles to overcome before it finally comes into force. We will keep you up to date on the latest status in this article.
Mandatory labelling comes into force in Spain in 2025
From 1 January 2025, a new labelling requirement for packaging will apply in Spain, which was introduced by Royal Decree 1055/2022. Companies that place household packaging on the market in Spain must then ensure that their packaging is correctly labelled. After 1 January 2025, no packaging may be placed on the market in Spain without a label. The aim of this new regulation is to promote recycling in Spain and to support consumers by providing clear separation information.