Your Roadmap to EPR Compliance

Packaging is entering a new era

Packaging is becoming more sustainable, driven by new Extended Producer Responsibility (EPR) rules. These regulations make businesses responsible for the entire lifecycle of their product packaging. Over the last year, large producers have been reporting their packaging data and by 1 October, 2025, the first EPR invoices will be provided for the 2024 compliance year.

If you produce or sell packaged products, you may need to comply with EPR, depending on your company's size and packaging waste volume. Compliance is important for legal reasons, cost management, and meeting customer expectations.

To adapt, you’ll need to assess your current practices, understand the requirements, explore sustainable alternatives, and report the data to the government every six months.

This shift isn't just about regulations—it's an opportunity to innovate and improve your business practices. By embracing these changes, you’ll enhance your brand's reputation, potentially reduce costs, and contribute to environmental sustainability.

Packaging	All the materials used to wrap, protect, and present a product. This includes the box or container the product comes in, as well as any extra wrapping or boxes used for shipping.
Producer	The company that puts a product on the market for people to buy. This could be the brand owner or the company that imports the product.
Manufacturer	The company that actually makes or puts together the product.

What is Extended Producer Responsibility (EPR)?

EPR is the new legislation replacing the packaging waste regulations (Producer Responsibility Obligations). It makes manufacturers, importers, and sellers responsible for the environmental impact of their product packaging.

EPR covers all packaging used in product sales, from perfume bottles to takeaway coffee cups and delivery wrappings. The aim is to provide incentives for businesses to use recyclable materials, and to encourage the use of higher recycled content in packaging.

Under EPR, producers must contribute to the recycling and recovery costs of their packaging waste. This shift in responsibility encourages the adoption of more sustainable packaging options, reducing environmental impact and promoting a circular economy.

By making businesses accountable for their packaging waste, EPR further aims to drive innovation in sustainable packaging design and waste management practices.

What's changing and how does it affect your business?

Historically, local councils have been responsible for waste collection including packaging waste), with costs covered by taxpayers through council tax. EPR legislation changes this dynamic and places the responsibility back with the organisations releasing the packaging onto the market

Under EPR, councils will receive additional funding from fees collected from packaging waste producers. This shift introduces two key requirements for producers:

Cost Coverage: Producers must now cover the costs associated with managing their packaging waste. This includes collection, sorting, recycling, and disposal.
Producer Definition: a producer is the company responsible for putting the product and its packaging into the marketplace for consumers to buy.

EPR responsibility varies depending on branding:

For supermarket own-brand products: The supermarket, not the manufacturer, is responsible for EPR compliance.
For manufacturer-branded products: The manufacturer is responsible for EPR compliance.

As of January 2023, producers must report detailed data on their packaging:

This includes type, weight, use, and end destination of packaging materials.
The reporting system aims to measure waste accurately and calculate appropriate fees.
Comprehensive data requirements ensure transparency and accountability in packaging waste management.

The full list can be found here.

EPR compliance is legally required for producers. They must report packaging data and pay the associated fees. Non-compliance or late submissions may result in substantial penalties. The government has not yet specified the exact amounts of these fines, but they are expected to be significant.

Businesses may need to comply with EPR if they:

Supply packaging or packaged goods in the UK
Place goods in empty packaging (Exempt if less than 10 staff, except takeaways)
Import products with packaging
Own an online marketplace
Hire or loan reusable packaging
Supply or sell empty packaging materials

However, not all businesses need to report. Requirements vary based on company size and packaging waste volume. Check the Government's EPR regulations to determine your business's category and obligations.

Compliance timelines:

Large organisations: Collect and report data in 2024; pay fees in 2025 based on this data.
Small organisations: Only need to collect data in 2024; no reporting required.

What are the associated costs of EPR?

EPR presents both challenges and opportunities for producers. You may face costs associated with transitioning to sustainable packaging, including redesigning packaging, sourcing alternative materials, and potentially higher expenses for recycled materials.

However, these initial investments could lead to long-term savings. EPR offers fee reductions of up to 30% for manufacturers who use packaging that either contains at least 30% recycled content or is easily recyclable. You can also save money by minimising packaging use, which reduces both production costs and EPR fees. Of course, by complying with EPR rules, you’ll also boost your sustainability credentials, which could attract and retain customers.

Regarding financial implications, EPR fee payments have been deferred until October 2025. While the exact fee structure hasn't been published yet, it's confirmed that fees will vary, with lower charges for more sustainable packaging.

This approach encourages innovation in sustainable packaging while considering the financial implications for businesses. The delayed implementation and variable fee structure provides companies time to adapt more environmentally friendly practices.

For personalised advice on how EPR affects your business and strategies to ensure compliance while optimising costs, please don't hesitate to reach out. Our team is ready to provide tailored solutions to meet your specific needs.