In the UK, a significant shift is underway in how packaging waste is managed. Since 2023, the government’s Extended Producer Responsibility (EPR) scheme has made businesses more accountable for the packaging they produce and supply, including covering the full cost of recycling. The goal is to encourage more sustainable practices and reduce the environmental impact of packaging waste. Previously, the UK followed the Producer Responsibility Obligations, introduced in 1997 to boost recycling. These helped increase packaging recycling rates to around 70%, with cardboard and paper reaching about 84%, and ensured national targets were consistently met. However, with the rapid evolution of production and consumer habits, the old system is no longer enough. The new EPR rules are designed to meet today’s environmental challenges and ensure producers take greater responsibility throughout the packaging lifecycle.

What is the EPR Scheme?

The EPR scheme makes businesses responsible for the full cost of managing the packaging waste they generate. This includes costs associated with collection, sorting, treatment, and recycling. The goal is to incentivise producers to design packaging that is easier to recycle and to reduce unnecessary packaging. Packaging is any material used to protect or hold goods, making them easier and safer to handle or deliver. At the moment local councils and taxpayers typically cover these costs. Under the EPR scheme, the financial responsibility for managing packaging waste shifts to the companies that produce it. By holding producers directly accountable for the environmental costs, the scheme aims to encourage the use of less packaging and promote more recyclable materials. In addition to data reporting and account registration, the EPR scheme also brings new labelling rules. From 31 March 2027, all packaging including flexible films must carry a clear "recycle" or "do not recycle" label.

Businesses under the EPR scheme are required to:

• Collect and report detailed data on the packaging they handle

• Pay fees based on the amount and recyclability of their packaging

• Ensure compliance with recycling obligations.

The EPR regulations apply to UK-based organisations that meet all of the following criteria:

• Have an annual turnover of £1 million or more

• Are an individual business, subsidiary, or group

• Handle more than 25 tonnes of packaging per year

Under the EPR scheme, obligations are tiered according to company size and the volume of packaging handled.

What is a Small Organisation?

You are considered a small organisation if you meet either of these criteria:

• Your turnover is between £1 million and £2 million, and you handle more than 25 tonnes of packaging per year, or

• Your turnover is over £1 million, and you handle between 25 and 50 tonnes of packaging per year.

What You Need to Do

• Create an online account for the EPR Packaging service

• Record and submit packaging data once a year

Key Deadlines

• 1 April 2025 - Deadline to register and submit your 2024 data (past deadline).

• 1 April 2026 - Deadline to submit your 2025 data.

If you are a small organisation and missed the 1 April 2025 deadline to register and submit your 2024 data, you should still register and submit as soon as possible to avoid penalties and maintain compliance. It is important to meet the next deadline on 1 April 2026.

What is a Large Organisation?

You are considered a large organisation if:

• Your annual turnover is £2 million or more, and

• You handle more than 50 tonnes of packaging per year.

What you need to do:

• Create an online account for the EPR Packaging service.

• Record and report packaging data every six months.

• Submit your data by the official deadlines.

Key deadlines:

• 1 October 2024 - Deadline to submit data for January to June 2024 (past deadline).

• 1 April 2025 - Deadline to submit data for July to December 2024 (past deadline).

• 1 October 2025 - Deadline to submit data for January to June 2025.

The deadlines on 1 October 2024 and 1 April 2025 have already passed. If you have missed these deadlines, you should submit your outstanding data as soon as possible to avoid penalties and demonstrate compliance.

What Might You Have to Pay?

From 2025, based on your 2024 data, you may be required to:

• Pay a registration fee to the environmental regulator

• Pay a waste management fee for the collection and recycling of packaging

• Cover scheme administration costs

• Purchase PRNs (Packaging Recycling Notes) or PERNs (Packaging Export Recycling Notes) to meet recycling obligations

• Report where your packaging is used and where it ends up in the UK (this is known as "nation data")

What are PRNs and PERNs?

PRNs and PERNs are certificates that prove your packaging waste has been recycled, either in the UK (PRNs) or abroad (PERNs). These are purchased from accredited recyclers or exporters to demonstrate compliance with recycling requirements.

Advice on EPR Compliance

• Understand Your Packaging Use

Begin by thoroughly reviewing the packaging your business uses across production, delivery, and retail. Categorise the materials by type, such as plastic, cardboard, and metal, and by weight. Assess the recyclability of each material and identify opportunities to reduce packaging or switch to more sustainable alternatives. Having a clear understanding of your packaging early will simplify reporting and can help reduce waste and costs over time.

• Stay Updated on EPR Timelines

The EPR scheme is still developing so it

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