EPR UK: current obligations for retailers in relation to packaging

The Extended Producer Responsibility for packaging (pEPR) has been in force in the United Kingdom since January 2025. The regulation came into force as part of the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024. The pEPR UK was introduced to transfer the financial and operational responsibility for packaging waste from consumers and local authorities to producers, as we are seeing in many EU countries and Germany. The goal also sounds familiar: To incentivize sustainable packaging practices and increase recycling rates.

Not only has EPR UK been rethought, but a new government agency, PackUK, has also been launched. It manages the emerging waste disposal system. PackUK’s area of responsibility covers the four nations: England, Scotland, Northern Ireland and Wales. In Wales it is called PecynUK. PackUK’s responsibilities include setting EPR charges, collecting payments and distributing the available funds to local authorities, who in turn provide collection and recycling services.

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 UK 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 EPR 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 Large Producer 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.

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.

The Department for Environment, Food and Rural Affairs is the UK Government department responsible for environment, agriculture, fisheries and rural development. It is also responsible for PackUK and all EPR UK issues.

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.

In general, the UK seems to be taking its cue from its EU neighbors and, despite leaving the EU, is following suit when it comes to the EPR. It is therefore worth taking a regular look at the latest EPR Packaging UK updates so as not to get left behind.

You can find out what other regulations apply to other countries within the EU here.

In addition to the very fundamental UK EPR changes, mandatory labeling for primary and shipping packaging is to be introduced from March 31, 2026. 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 will apply to all types of packaging, regardless of whether it is plastic film or cardboard.