Extended Producer Responsibility for packaging is live in the UK. If your business puts packaging onto the UK market above the relevant thresholds, you are paying fees that affect your packaging economics right now, whether or not you've noticed them appearing in your costs yet. If you haven't worked through your compliance position, you're either overpaying or under-reporting, and neither outcome is better than the other.
Who is in scope and what the thresholds actually mean
The EPR obligation falls on producers, defined broadly to include manufacturers, importers, brand owners and some online retailers, depending on their role in the supply chain.
Large producers with full obligations, including data reporting and fee payment, are businesses with annual turnover above £1 million that supply or import more than 25 tonnes of packaging per year. Small producers (turnover above £1 million but below 25 tonnes) have lighter registration obligations currently, with fee payment phased in over time. Businesses below £1 million turnover are currently exempt from all EPR obligations.
The 25-tonne threshold includes all packaging: primary (your product's immediate packaging), secondary (shipper boxes, retail-ready trays), and tertiary (pallet wrap, stretch film, pallet caps). Businesses close to the threshold often underestimate their tertiary packaging tonnage, which is typically the easiest to reduce if you're trying to manage your position relative to the threshold.
What you're paying fees on and what determines the rate
Fees are charged per tonne of packaging supplied, by material type. Paper and board, glass, aluminium, steel, plastics and wood are each rated separately. The fee rate within each material category varies based on recyclability assessment: packaging rated as highly recyclable attracts lower fees than packaging rated as difficult to recycle or non-recyclable.
Plastic packaging attracts substantially higher fees per tonne than paper and board, reflecting the higher cost of collecting and processing plastic and the lower recovery rates. If your business uses plastic films, shrink wrap, flexible mailers, plastic trays or bubble wrap in significant volumes, these are your highest EPR cost items.
The distinction between household and non-household packaging also affects the fee. Packaging that enters household recycling streams (direct-to-consumer e-commerce boxes, any consumer product packaging) attracts higher fees than packaging that stays in commercial waste streams (business-to-business transit packaging). A box sent direct to a consumer via courier is household packaging. The same box sent to a trade customer's warehouse is non-household packaging.
Where businesses consistently get this wrong
The most common error is failing to include tertiary packaging in the tonnage calculation. Stretch film, pallet wrap, corner boards and plastic banding all count. Businesses that have always treated these as invisible operational costs suddenly find they represent a meaningful tonnage.
The second common error is misclassifying household versus non-household packaging. If you sell to both trade and consumer customers using the same box, the allocation matters and needs to reflect actual volumes, not a rough assumption.
The third is not knowing the recyclability rating of packaging components and therefore not knowing whether EPR fee savings might be available through material or design changes. Switching from a mixed-material laminate mailer to a mono-material paper mailer, for example, may increase your recyclability rating and reduce your fee per tonne on that packaging type.
Practical steps if you haven't started
List all packaging your business supplies across primary, secondary and tertiary categories. Establish the weight per unit of each type. Weigh samples if you don't have specifications. Classify each item by material and by household versus non-household. Calculate annual tonnages.
Register with an accredited compliance scheme. These schemes handle the reporting and fee payment to the scheme administrator on your behalf in exchange for a service fee, and they can help you navigate classification questions. Your packaging supplier or an EPR compliance consultancy can help with the initial data collection if your packaging inventory is large.
The data reporting and the fee payment are both mandatory obligations with penalties for non-compliance. The fee costs are real and visible once you've done the inventory. For most businesses, this is also the first time they've had a full picture of their packaging spend by type, which itself is useful.