Packaging EPR

Packaging EPR measures are now being phased in to increase responsibility producers must bear for the packaging they place on the market. Are you prepared?
What is packaging EPR?

What is packaging EPR?

Packaging EPR is a policy tool whereby producers are made significantly responsible for the packaging they place on the market at the end of its life. Government first stated their intention for a UK packaging EPR system in the 2018 Resources and Waste Strategy. The overall purpose is to ensure long term planning and investment into sustainable material use and recycling infrastructure, and to fulfil the ‘polluter pays principle’. EPR measures are being phased in and will be fully operational by 2027, with obligated producers expected to bear the ‘full net cost recovery’ of the packaging they place on the market that arises in the household waste stream.



What is the packaging EPR timeline?


In March 2022 government published their response to the EPR for packaging consultation and outlined the timeline below for the implementation of various EPR measures - including the Plastic Packaging Tax, modulated fees, a Deposit Return Scheme and mandatory labelling requirements.


Packaging EPR timeline


Am I affected by packaging EPR?

If you are a producer of packaging, including an importer, you will be impacted by EPR and your compliance costs will inevitably increase. The current producer responsibility system exempts small producers by a 50 tonne placed on market and £2 million turnover de minimis. Government have announced this will remain under the new EPR reform, but producers with more than £1 million annual turnover and who handle over 25 tonnes of packaging will now have reporting-only obligations.

The impact of EPR and full net cost recovery

In March 2022 Government confirmed that there will be two single points of compliance – brand-owners and importers. However, the new system has additional producer categories including online marketplaces and distributors that in turn have varying obligations. Costs will be recovered throughout the supply chain as additional charges are made. Some businesses that are not obligated in the current producer responsibility system may find they are under EPR.

The current ‘PRN’ system – where businesses purchase evidence of recycling based on tonnage – will continue until 2026/2027. However, liable producers will also have to start paying additional costs to local authorities for the collection, recycling and disposal of packaging from households and public bins via modulated fees in 2024. Some businesses may have to additionally participate in the Deposit Return Scheme if putting onto the market certain single-use drinks containers. The plastic packaging tax, from April 1 2022, will also penalise those not using at least 30% recycled content in plastic packaging at £200 per tonne.

A further aspect of the EPR framework will be the introduction of a mandatory standardised labelling system by March 2026. By this time, all primary packaging must sport OPRL’s recycle mark.

Find out more about the new EPR mechanisms below:


Modulated fees

If you are a producer of packaging in the UK you will be affected by modulated fees, used to financially incentivise the use of more sustainable and recyclable materials.

Read more

Deposit Return Scheme

The DRS is set to be implemented in Scotland in 2023 with England following in 2024. All producers of in-scope drink containers will be required to meet a collection target set by government. Are you affected?

Read more


The packaging EPR consultations enable stakeholders to input into regulatory change. Find out about all closed and open consultations here.

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Packaging EPR data services

Optimise for packaging EPR

As your packaging data partner, we'll help you capture and validate the correct data for existing and future legislation, in a database owned by you. Our interactive analytical dashboards will also enable you to budget, model scenarios and develop a strategy to reduce your liabilities. Importantly we will enable you to gain a holistic view of your packaging environmental impact in the context of the Plastic Packaging Tax, EPR, the DRS and your own recyclability goals as well.
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Find out more about existing packaging legislation

Find out if existing packaging producer responsibility legislation applies to you, what you need to do and how we can help.
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