UK Packaging Waste Regulations: EPR, pEPR & How to Comply

Key Takeaways

• The UK’s packaging waste regulations have evolved significantly with the introduction of Extended Producer Responsibility (EPR) legislation, which effectively replaces the old Producer Responsibility Obligations Regulations.
• Businesses handling more than 50 tonnes of packaging per year with an annual turnover of over £2 million are considered large producers and must comply with pEPR regulations. Non-compliance can result in severe penalties.
• The new system places full financial responsibility for managing packaging waste on producers, with modulated fees to be introduced in 2025 based on packaging recyclability.
• Globe Packaging offers 100% recyclable and recycled packaging options at market-leading prices, along with free next-day delivery on orders over £50 to support your sustainability and cost-management goals.

The Shift to Full Producer Responsibility

The UK's packaging waste landscape is undergoing its biggest transformation in decades. In 2023, Extended Producer Responsibility (EPR) legislation began phasing in, effectively replacing the Producer Responsibility Obligations that had been in place since 1997.

This fundamental shift transfers the full financial responsibility for managing packaging waste onto the producers themselves. The goal? To dramatically increase recycling rates and reduce environmental impact by making those who create packaging pay for its entire lifecycle.

The new Packaging Waste Regulations, formalised as the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024, create a more comprehensive framework that aligns with circular economy principles.

Rather than the shared responsibility model of the past, producers now face direct accountability for the packaging they place on the market. This includes not just manufacturing and recycling costs, but the entire waste management process from collection to disposal.

Who Is Affected by These Regulations

The UK's Packaging Extended Producer Responsibility (pEPR) regulations cast a wide net, but not all businesses fall under its jurisdiction. You’re likely obligated if your business handles 50 tonnes or more of packaging a year and has an annual turnover of £2 million.

These thresholds capture most medium to large businesses across manufacturing, retail, import/export, and distribution sectors. Specifically, the regulations target businesses performing packaging activities as part of the supply chain. This includes manufacturers of packaging materials, converters who form packaging, businesses that fill packaging with products, sellers who supply packaged goods to end users, and service providers who import packaging.

If your business handles any empty packaging or packaging materials that will eventually become packaging waste in the UK, you need to pay close attention to these regulations.

Key Difference Between EPR vs pEPR

What Extended Producer Responsibility (EPR) Means

Extended Producer Responsibility fundamentally changes how we think about product lifecycles. Rather than responsibility ending at the point of sale, EPR extends a producer's responsibility to the post-consumer stage of a product's lifecycle.

This comprehensive approach aims to internalise the environmental costs associated with products throughout their entire lifecycle, from design to disposal. The EPR principle is being applied globally across various sectors and waste streams, including electronics, batteries, vehicles, and packaging.

It represents a significant shift from traditional waste management approaches where local authorities and taxpayers bore most of the cost. By making producers financially responsible for waste management, EPR creates powerful incentives for eco-design, waste reduction, and increased recycling rates.

For businesses operating in the UK, understanding EPR means recognising that your responsibilities now extend far beyond simply placing products on the market. You're accountable for ensuring those products and their packaging can be effectively collected, sorted, and recycled at the end of their useful life.

What Packaging EPR (pEPR) Means

Packaging EPR (pEPR) refers specifically to the application of Extended Producer Responsibility principles to packaging waste. This targeted implementation focuses on ensuring producers take financial and operational responsibility for collecting, sorting, and recycling the packaging they place on the market.

With the UK generating approximately 12.7 million tonnes of packaging waste annually, pEPR aims to address this significant environmental challenge through producer accountability.

Under pEPR, businesses must provide clear and accurate information to consumers about how to dispose of packaging correctly. This consumer-facing element represents an important expansion of responsibility beyond just financial obligations.

The regulations require producers to fund the waste management system and also actively participate in educating end-users about proper disposal methods, creating a more comprehensive approach to tackling packaging waste.

What Packaging Does pEPR Cover?

For the purpose of pEPR regulations, packaging includes products made of any materials, of any nature, intended to perform at least one function in relation to the supply of goods. These fall into four packaging types: Primary packaging, Secondary packaging, Tertiary packaging, and Shipment packaging.

Generally, primary packaging and shipment packaging should be reported as household packaging, unless it can be evidenced that a business or public institution is the final user of the goods.

Household vs Non-Household Classification

Household packaging refers to any packaging that will ultimately end up in a household bin at the end of its life cycle, primarily consisting of primary packaging and shipment packaging like product boxes, bubble wraps e.t.c.

Packaging must be declared as household unless you can evidence it is non-household. Large boxes supplied to a business may be used to send goods to consumers (household packaging) or to send products to other businesses for wholesale distribution (non-household packaging).

The non-household classification only applies if you can evidence that the packaging will be disposed of by a business rather than ending up as household waste.

Financial Obligations by Classification

Household packaging carries disposal fees at government-published rates: £196 per tonne for paper/card, £423 per tonne for plastic, and £280 per tonne for wood. These rates are subject to change in future years.

Non-household packaging still carries reporting obligations, and obligated producers must obtain PRNs (Packaging Recovery Notes) to cover the cost of recycling all non-household waste.

Note: These disposal fees were announced for 2025 and are subject to change in future years.

Who Is Obligated to Pay The Disposal Fees?

Distributor

Distributor is the manufacturer or importer that places packaging on the UK market. They are liable for reporting and paying disposal fees on household packaging, except for packaging sold to a large producer functioning as a packer/filler or brand owner, who then assumes responsibility.

Packer/Filler

Packer or filler is the organisation that uses packaging to pack or fill goods, either for their own organisation or another. If the packer/filler is a large producer, they are liable for reporting and paying disposal fees on all household packaging they have used in their operations.

Brand Owner

Brand owner is the entity supplying goods under their own brand. Large producers functioning as brand owners are liable for reporting and paying disposal fees on all household packaging associated with their brand, including packaging used for their branded products by a manufacturer, importer, or overseas supplier.

How to Comply to the New EPR & pEPR Regulations:

Step-by-Step Guide

Registration Requirements

All obligated producers must register with the appropriate environmental regulator—Environment Agency in England, Scottish Environment Protection Agency, Natural Resources Wales, or Northern Ireland Environment Agency.

Registration can be completed directly with the regulator or through an approved compliance scheme, with the latter being the preferred option for most businesses.

Documentation You Must Keep

Maintaining comprehensive documentation is a fundamental aspect of compliance with packaging regulations. At minimum, you should preserve records of all data submissions, calculations, and methodology used to determine packaging weights and obligations.

This includes supplier declarations, sampling records, weighing certificates, and any other evidence that supports your packaging data reporting. Regulators recommend retaining this documentation for at least four years, as it may be required during compliance audits or investigations.

Establishing a systematic record-keeping system that organises documentation by reporting period can significantly streamline future audits and ensure continuity of compliance knowledge within your organisation. Many businesses are implementing digital document management systems specifically for compliance records to ensure nothing falls through the cracks.

Fee Payment Timeline

Understanding when various fees are due is crucial for financial planning and maintaining compliance. Registration fees must be paid annually during the registration period, typically in the first quarter of the year. PRN/PERN purchase obligations under the transitional system are typically settled quarterly, with final reconciliation by January of the following compliance year.

As the system transitions to full pEPR implementation, additional fee structures will be introduced. Businesses should be budgeting now for these upcoming fee obligations, particularly if they handle significant quantities of hard-to-recycle packaging that may incur higher rates.

Future-Proofing Your Business for Upcoming Changes

Expected Regulatory Developments

The packaging regulatory landscape will continue to evolve even after full pEPR implementation. By 2026–2027, we can expect further refinements to the modulated fee structure, with increasingly granular distinctions between packaging types based on recyclability.

Additional reporting requirements around carbon impact and recycled content are likely to be introduced as the UK pursues its net-zero carbon commitments. Most notably, the scope of the regulations may expand to include more types of businesses and additional packaging formats that are currently exempt.

This will create a more comprehensive system with fewer gaps in responsibility.

Building Sustainable Packaging Strategies

Start by conducting a thorough assessment of your entire packaging portfolio, identifying opportunities to reduce material usage, increase recyclability, and eliminate problematic components. Consider establishing cross-functional teams that bring together expertise from product development, operations, marketing, and sustainability to drive holistic packaging innovation.

Engaging suppliers early in redesign efforts can uncover innovative solutions that might otherwise be missed. Many material suppliers and packaging manufacturers have developed alternatives specifically designed to perform well under the new modulated fee structure.

By establishing sustainability criteria in your procurement processes and communicating clear expectations to your supply chain partners, you can foster a collaborative approach to packaging improvement that delivers environmental and financial benefits.

Managing UK Packaging Compliance with Globe Packaging

Understanding and complying with the UK's evolving packaging waste regulations, from the transition to Extended Producer Responsibility (EPR) to the full implementation of packaging EPR (pEPR) in 2025, requires both regulatory knowledge and access to compliant packaging solutions.

At Globe Packaging, we've established ourselves as one of the UK's leading packaging distributors by offering industry-standard packaging products at market-leading prices while supporting businesses through regulatory transitions. Our extensive range includes 100% recyclable and 100% recycled packaging options that align perfectly with the new modulated fee structure.

By choosing packaging materials designed for optimal recyclability, you can significantly reduce your future fee obligations under pEPR while meeting consumer expectations for sustainable products.

Our specialised team brings years of experience in both standard and bespoke packaging solutions, helping businesses redesign their packaging portfolios to meet regulatory requirements without compromising functionality or brand identity.

With free next-day delivery on orders over £50 and exceptional service levels, we make it easy to access compliant packaging solutions that support your sustainability goals.

Shop Globe Packaging Now →

Frequently Asked Questions (FAQs)

What businesses must comply with UK packaging waste regulations?

Businesses with £2m+ annual turnover handling 50+ tonnes of packaging, must comply. This includes manufacturers, converters, fillers, sellers, and importers of packaged goods.

The regulations apply to all packaging types including primary, secondary, and tertiary packaging across all materials (plastic, paper, glass, aluminium, steel, wood).

How do the new pEPR regulations differ from the old PRN system?

The old PRN system allowed producers to purchase evidence of recycling after-the-fact through a market-based mechanism. The new pEPR regime shifts to full cost recovery where producers pay fees that directly fund the entire waste management infrastructure.

How can businesses reduce costs under the new modulated fee structure?

Businesses can reduce costs by conducting recyclability assessments of their packaging portfolios and prioritising redesigns for high-fee items.

Strategies include reducing packaging weight, increasing recyclability through material selection, replacing problematic components, incorporating recycled content, and working with suppliers to develop sustainable alternatives.

Even small changes to packaging components can significantly improve recyclability classifications and reduce future obligations.

How does Globe Packaging help businesses comply with pEPR regulations?

Globe Packaging offers an extensive range of 100% recyclable and 100% recycled packaging products at market-leading prices, helping businesses reduce future modulated fees.

Our specialised team provides expertise in both standard and bespoke packaging solutions designed for optimal recyclability. With free next-day delivery on orders over £50 and years of industry experience, we help businesses redesign packaging portfolios to meet regulatory requirements while maintaining functionality.