Extended Producer Responsibility (EPR)

What do you need to know about Extended Producer Responsibility?

If your business has any responsibility for packaging you will be affected by the new Extended Producer Responsibility (EPR) legislation.

From 2025, businesses will have to pay a fee for the packaging they supply to or import into the UK market. The money raised through the scheme will go towards the net costs of collecting, managing, recycling and disposing of household packaging waste.

Ultimately, EPR is a policy tool that has been introduced to help reduce the environmental impact of packaging. Through the legislation, the government is aiming to hold producers accountable for their packaging throughout its whole life cycle.

It will be a legal requirement for all obligated producers to report detailed data on the packaging they handle and supply in the UK.

How can you get ready for Extended Producer Responsibility?

If your business manages more than 50 tonnes of paper-based packaging, you could incur charges of up to £10,000 based on current illustrative EPR fees.

For companies handling significantly larger volumes, these costs can quickly escalate into the millions. This underscores the importance of optimising packaging strategies. At Diamond Box, we help our clients utilise lighter, more sustainable materials. This increases recyclability and minimises excess packaging, helping mitigate the financial impact of EPR, while supporting sustainability efforts.

Reduce the weight of your packaging

Because EPR fees are based on weight, choosing lighter packaging can reduce your costs. Plus, cutting down on packaging weight helps lower carbon emissions, benefiting both your budget and the environment.

Design products to use less packaging

Minimising the packaging you introduce to the UK market reduces your total tonnage. With smart, optimised design, you can achieve this without sacrificing product protection.

Use packaging that is easier to recycle

EPR fees depend on the recyclability of your packaging materials. Hard-to-recycle materials come with higher costs, so switching to more recyclable options now can help reduce your EPR expenses.

What do I need to do to be compliant?

Are you obligated?

You are likely to be classed as an obligated producer under the EPR regulations if your business:

  • Has a UK presence
  • AND a UK annual turnover of £1m or more
  • AND is responsible for more than 25 tonnes of packaging per year

What do you need to do?

If obligated, you must collect and report detailed data to government about all the packaging you handle or supply.

If you are classed as a large producer you will have financial obligations and will also need to complete a recyclability assessment for all your packaging and report the results to government. This applies if you:

  • Have an annual turnover of £2m or more
  • AND are responsible for more than 50 tonnes of packaging per year

The type of waste matters for EPR calculations

Under EPR companies need to report the type of waste their packaging will become at the end of it life. This will determine the level of additional modulated disposal fees that a business needs to pay on top of the PRN system.

By default, all primary and shipment packaging will be treated as household packaging unless you can prove it was supplied to a business who removes it.

This will include all outer and transit packaging that will be removed by a business you have directly supplied.

On-the-go packaging, including packaging around food, frinks and tobacco products subject to size.

Additional reporting will be required for drinks containers to include the weight and number of units supplied by material.

This referes to all packaging that is designed to be re-used. The obligation will only be picked up on first use.

This applied to any waste you take back from your customers, or collected for recycling.

Frequently asked questions about EPR

Promote a circular economy – Encouraging producers to design more sustainable packaging, improve recyclability, and reduce overall waste.

Increase recycling rates – Ensuring that more packaging waste is collected, sorted, and recycled rather than sent to landfill or incineration.

Encourage sustainable packaging design – Incentivising businesses to use materials that are easier to recycle or have a lower environmental impact.

Shift the cost burden to producers – Requiring businesses, rather than taxpayers, to cover the costs of packaging waste management.

Your business, depending on its size and the activities it performs, may need to pay four sets of fees in order to become compliant with the Regulations:

Agency fees – every business has to pay a set environment agency registration fee each year

Annual membership fee – this covers our administration costs of checking and verifying data

EPR fees – the costs associated with managing packaging waste

PRN fees – the cost of procuring recycling evidence notes needed to meet the business’s obligation

Large producer – any business that handled/supplied 50 tonnes or more of packaging in the previous calendar year and had an annual turnover of £2m or more.

Small producer – any business with a turnover in the previous calendar year between £1m-2m which handled/supplied 25 tonnes or more of packaging, or any business that had an annual turnover of £1m or more which handled between 25 and 50 tonnes of packaging. Businesses not meeting one of the small producer definitions are not obligated under EPR.

Small producers must submit data once annually. Small producers incur no financial obligations to support recycling (i.e., they do not need to purchase PRNs or pay EPR fees).

Large producers must submit data every six months on the packaging they have placed on the market. In the future, large producers will also have to pay enhanced fees towards the waste management costs of the packaging they report.

All those exceeding the small producer thresholds must also, once a year, report packaging supplied by them to its end user directly by which UK nation the customer was in.

As of October 2024, the current illustrative fees indicate that plastic could be taxed up to £520 per tonne, while paper may be taxed up to £250 in the highest fee scenarios.

Want to know how Diamond Box can help you navigate EPR?

Book a call with one of our corrugated packaging experts who will help you every step of the way.

100% sustainable packaging solutions

Corrugated cardboard packaging is one of the most sustainable forms of packaging available. It offers companies an eco-conscious choice for their packaging needs. Made from renewable and recyclable materials, corrugated cardboard is a key part of the circular packaging economy.

Diamond Box’s FSC-certified cardboard provides peace of mind that your packaging supports forest conservation. Choose corrugated cardboard for packaging that not only protects your products but also demonstrates your commitment to sustainability.