EPR meaning: what it is and what it means for your business

EPR meaning: EPR refers to UK legislation that holds businesses accountable for the end-of-life costs of the packaging they place on the market. If your business handles or supplies packaging above set thresholds, you’ll be required to register, report and contribute financially to the cost of collecting and recycling that packaging.

This legislation is already in force. If you haven’t started tracking your packaging data, you need to act now.

In this article, we’ll cover:

What EPR means and why it was introduced
Which businesses are affected by UK EPR regulations
Small and large producer thresholds and what they mean in practice
Your reporting obligations and key deadlines
How to reduce your EPR fees through smarter packaging choices

What does EPR mean? A clear definition

EPR stands for Extended Producer Responsibility. It’s a policy approach that holds producers financially responsible for what happens to their packaging after consumers finish with it.

Under the UK EPR scheme, businesses that supply or handle packaging above certain thresholds must register with the relevant authority, report their packaging data and pay fees that contribute to local authority collection and recycling costs. The policy is grounded in the Environment Act 2021 and is administered through guidance issued by the Department for Environment, Food and Rural Affairs (DEFRA).

The core principle is straightforward: businesses that benefit from using packaging should share the cost of managing that packaging as waste. This is a shift from the previous system, where local authorities absorbed most of those costs.

The UK’s EPR framework is separate from EU arrangements following Brexit, though it shares the same underlying policy rationale. The regulations apply specifically to businesses operating in England, Scotland, Wales and Northern Ireland under their respective devolved frameworks.

Why EPR was introduced

Packaging waste has long been one of the most visible environmental challenges in the UK. Before EPR, the Packaging Waste Regulation required producers to purchase Packaging Recovery Notes (PRNs) or Packaging Export Recovery Notes (PERNs) to demonstrate that a proportion of their packaging was being recycled. That system, while functional, didn’t generate enough funding to cover the full cost of kerbside collections and sorting.

EPR is designed to fix that funding gap. By requiring producers to pay fees that reflect the actual cost of collecting and processing their packaging from household waste streams, the government aims to incentivise businesses to use less packaging, choose more recyclable materials and design packaging that’s easier to sort and process.

The legislation also responds to long-running pressure from local councils, which have shouldered the financial burden of household packaging collection without receiving adequate funding from the businesses responsible for that packaging.

Who is affected by UK EPR regulations?

EPR applies to businesses in the UK that fall into one or more defined ‘packaging activity’ roles. The legislation identifies several categories of producers, and your obligations depend on which role or roles apply to your business.

The main categories are:

Brand owners who supply goods in packaging under their own brand
Packer/fillers who put goods into packaging and supply them to the market
Importers who bring packaged goods into the UK for sale
Online marketplace operators who facilitate the sale of packaged goods from overseas sellers
Distributors who supply packaging to businesses that then use it to pack goods
Sellers who supply empty packaging directly to consumers or end users

If your business handles or supplies packaging in one of these ways, you may be subject to EPR. To be affected, your business must meet all four of the following criteria.

You must be a UK business
You must have had a turnover of at least £1 million in the last financial year
You must be responsible for more than 25 tonnes of packaging in a calendar year
You must be involved in one of the packaging activities listed above.

If your business doesn’t meet all four criteria, you won’t be subject to EPR at this time. For many smaller businesses, this means EPR doesn’t apply yet, though it’s worth keeping your packaging volumes under review as your business grows.

Most businesses that are subject to EPR should already have been tracking their packaging data since January 2023. If you haven’t started, it’s worth checking with your suppliers as soon as possible. If you’re a regular customer with one supplier, they may be able to help you fill gaps in your usage data by checking their own records.

Small vs large producer thresholds explained

Once you’ve established that EPR applies to your business, the next step is to determine which producer category you fall into. This determines your reporting frequency and, critically, whether you’ll pay EPR fees.

The threshold split is based on two measures: your annual turnover and the volume of packaging you handle or supply.

Small producer obligations

You’re classed as a small producer if your turnover is between £1 million and £2 million and you’ve supplied or handled more than 25 tonnes of packaging or handled between 25 and 50 tonnes of packaging in a calendar year.

As a small producer, you must report your packaging data once a year. Importantly, small producers won’t incur EPR fees at this stage. This is a meaningful distinction from some of the more alarmist coverage of EPR, which can suggest all businesses face immediate financial penalties. If you’re a small producer, your priority is accurate data collection and annual reporting.

Large producer obligations

You’re classed as a large producer if your turnover exceeds £2 million and you’ve handled or supplied more than 50 tonnes of packaging in a calendar year.

Large producers must report their packaging data twice a year. They’ll also be subject to EPR fees once the full fee obligations come into force. These fees are calculated based on the volume and type of packaging handled, and they’ll vary depending on the materials used and their recyclability.

Producer threshold summary

To make this easier to scan, here’s a structured summary of the two producer categories:

Small producer: Turnover £1m-£2m. Packaging volume above 25 tonnes or handled 25-50 tonnes. Report once a year. No EPR fees at this stage.

Large producer: Turnover above £2m. Packaging volume above 50 tonnes. Report twice a year. Subject to EPR fees.

These thresholds matter because they determine both your compliance obligations and your likely cost exposure. Working out which category you fall into should be your first step once you’ve confirmed EPR applies to your business at all.

Reporting obligations and key EPR deadlines

Understanding the timeline is essential for planning your compliance approach. The legislation has rolled out in stages, and the most significant financial obligations are still ahead.

Packaging data tracking began in January 2023. If you’ve been supplying or handling packaging above the relevant thresholds since that date, you should have records going back to that point. This data forms the basis for your reporting submissions and, for large producers, your fee calculations.

The enhanced fee obligations for large producers came into effect in October 2025. These fees are calculated based on the packaging you used in 2024, not 2025. That means the packaging decisions your business made last year will influence what you’ll owe.

For small producers, the fee obligations don’t apply yet, but reporting requirements do. Staying on top of your data now means you won’t be caught out if the thresholds change or your business grows into the large producer category.

The legislation is still developing in some areas, and the exact fee rates can shift as DEFRA finalises the modulated fee structure. Finding out which threshold you fall under using your data collected since January 2023, alongside your local authority’s cost data, is the most reliable way to estimate your probable EPR costs. For the most recent official guidance, check the relevant EPR packaging guidance on GOV.UK.

PRNs and PERNs under EPR

It’s worth understanding where Packaging Recovery Notes (PRNs) and Packaging Export Recovery Notes (PERNs) fit into the picture. These are the compliance mechanisms through which businesses have historically demonstrated that packaging waste is being recycled.

Under the new EPR framework, the role of PRNs and PERNs is evolving. Large producers will increasingly meet their obligations by paying direct fees to the EPR scheme rather than purchasing PRNs on the open market. However, PRNs and PERNs remain relevant to certain compliance obligations, particularly for producers who also recycle or export packaging waste.

If your business currently purchases PRNs or PERNs as part of your packaging waste compliance, it’s worth reviewing how your obligations will change under EPR. A packaging compliance specialist can help you map this out.

Am I affected by EPR?

Whether this will affect your business depends on the scale of your business and the amount of packaging your products use. The starting point for EPR fees is when all of the following points apply

You are an individual business, subsidiary or group; however, charities are exempt
Your company carries out packaging activities
You are responsible for importing or supplying more than 25 tonnes of packaging to the UK market in the previous calendar year
Your annual turnover exceeds £1 million.

If your business doesn’t meet all four criteria, you won’t be subject to EPR just yet. Most businesses that are subject to EPR should be aware and have been tracking their packaging since January 2023.

This is further split into small and large producers, depending on the scale of the business in terms of product produced and annual turnover

Small Producers will have a turnover between £1-2 million and will have supplied more than 25 tonnes of packaging or handled between 25-50 tonnes of packaging. They must report their usage once a year.
Large Producers will have handled or supplied more than 50 tonnes of packaging and had a turnover of more than £2 million. They need to report usage twice a year.

Notably, if you are considered a small producer, you will not (yet) incur EPR fees.

How to reduce your EPR packaging fees

EPR fees aren’t fixed. They’re modulated based on the type of packaging you use and its recyclability. This means there are real, practical steps your business can take to reduce what you’ll owe.

Start with your packaging data

You should already be tracking your packaging usage. If you haven’t started, do it now. Accurate data is a compliance requirement and the foundation for any cost-reduction work. You can’t identify where savings are possible until you know what you’re using and in what volumes.

As noted above, if you’re a regular customer with a single supplier, they may be able to help you fill any gaps in your usage data from January 2023 onward. Don’t wait until reporting deadlines to chase this information.

Choose lower-cost packaging materials

Not all packaging is subject to the same EPR fee. The modulated fee structure is designed to make recyclable materials cheaper to use than hard-to-recycle ones. In general, paper and card carry lower fees than plastic or composite materials.

If your current packaging uses significant volumes of plastic or composite materials, switching to paper or card-based alternatives could meaningfully reduce your EPR costs. Products like Climapack and paper void fill are practical examples of packaging that replace traditionally plastic products with more recyclable alternatives. These are available through RAJAPACK’s catalogue and are worth exploring if you’re reviewing your packaging mix.

Wood-based materials also tend to carry lower EPR cost ratings than plastic. If your operations use wooden pallets, crates or dunnage, these may attract lower fees than equivalent plastic formats.

Reduce overall packaging volume

The most direct way to reduce your EPR costs is to use less packaging overall. This isn’t always straightforward, particularly if your packaging choices are driven by transit protection or product presentation requirements. But a structured packaging review can often identify over-packaging, unnecessarily heavy formats or materials that could be replaced with lighter alternatives without compromising performance.

Reducing volume has a dual benefit: it lowers your EPR fee liability and your material costs.

Get a bespoke packaging audit

Whatever the scale of your business, partnering with a packaging specialist and getting a bespoke packaging audit is one of the most reliable ways to make sure you’re not caught out by EPR fees. An audit can identify where your current packaging mix sits in terms of fee exposure, highlight the materials with the highest cost impact and propose alternatives that meet your operational needs.

This is particularly valuable for businesses that haven’t yet done a detailed review of their packaging data. An audit provides a clear picture of your compliance position and a practical plan to reduce costs.

Eco-design and waste reduction

Beyond immediate fee savings, the UK EPR regulations are pushing businesses towards packaging designed with end-of-life in mind. Eco-design principles, such as using mono-materials rather than composites, avoiding mixed-material laminates and choosing materials with established recycling streams, can reduce both your EPR costs and your broader environmental footprint.

If you’re reviewing your packaging for EPR compliance, it’s worth considering not just the immediate fee impact but how your packaging will perform under future modulated fee structures as the scheme matures.

What to do next

If you haven’t already, confirm whether EPR applies to your business, identify which producer category you fall into, and ensure your packaging data records go back to January 2023.

For smaller businesses, the immediate pressure is lighter, but staying on top of your data now means you’ll be ready when the landscape shifts.

The best way to get a clear, personalised picture of your EPR obligations and cost exposure is to work with a packaging specialist.

Get in touch with our packing specialists today, and we can help you with a comprehensive packaging audit. Our team can review your current packaging mix, identify your EPR cost exposure and recommend practical alternatives that meet your operational needs while reducing your producer responsibility obligations.

Key takeaways

The EPR meaning is Extended Producer Responsibility. It refers to legislation that makes UK businesses financially responsible for the end-of-life costs of the packaging they handle or supply above set thresholds.
To be subject to EPR, your business must meet all four criteria: UK-based, turnover above £1 million, handling more than 25 tonnes of packaging per year and involved in a qualifying packaging activity.
Small producers with turnover between £1 million and £2 million must report packaging data once a year, but won’t incur EPR fees at this stage.
Large producers with turnover above £2 million and handling more than 50 tonnes of packaging must report twice a year and will be subject to fees from October 2025, calculated on 2024 packaging data.
Switching from plastic or composite packaging to paper, card or wood-based materials can directly reduce your EPR fee liability under the modulated fee structure.

FAQ: EPR meaning and packaging compliance in the UK

What does EPR stand for?

EPR stands for Extended Producer Responsibility. The ‘extended’ part refers to the fact that producers’ responsibility for their packaging extends beyond the point of sale to cover the cost of collecting and recycling that packaging at the end of its life.

Who is exempt from EPR packaging obligations?

Businesses with a turnover below £1 million or those handling fewer than 25 tonnes of packaging per year aren’t subject to EPR at this time. Businesses that don’t carry out any of the qualifying packaging activities. Such as brand owner, packer/filler or importer. Are also outside the scope of the regulations.

When do EPR fees start?

The enhanced EPR fee obligations for large producers came into effect in October 2025. The fees were calculated based on the packaging your business used in 2024, so your material choices last year already affect what you’ll owe.

How are EPR fees calculated?

EPR fees are modulated based on the type and volume of packaging your business handles. Materials that are harder to recycle, such as plastics and composites, attract higher fees than paper, card or wood. The exact fee rates are set through DEFRA’s modulated fee structure and may be updated as the scheme develops.

Can switching packaging materials reduce my EPR costs?

Yes. The EPR fee structure is modulated, meaning recyclable materials like paper and card attract lower fees than plastic or composite packaging. Products like Climapack and paper void fill are practical alternatives that can reduce your EPR cost exposure while maintaining transit protection.