Extended Producer Responsibility (EPR) is one of the most significant regulatory changes affecting UK businesses that use, supply or import packaging. If your business places packaging or packaged goods onto the market, EPR will directly impact how you operate, report data and manage costs.
Businesses with a turnover between £1 million and £2 million, and also handle up to 50 tonnes of packaging a year were originally exempt from paying EPR fees, but this has now changed. They are required to collect detailed data on the type and quantity of packaging used, with yearly reports needed. Businesses with an annual turnover of more than £2 million and handles over 50 tonnes of packaging will need to create reports every 6 months. This has led to businesses having to implement new internal systems and processes to ensure accurate reports.
What Is EPR? (Extended Producer Responsibility Explained)
EPR stands for Extended Producer Responsibility, and is a policy framework that makes businesses responsible for the full lifecycle of the packaging they place on the market, including its collection, recycling, and disposal.
In simple terms, EPR shifts the financial and operational responsibility for packaging waste onto the businesses that produce it. New EPR rules are already changing how organisations approach packaging design and sustainability.
Under EPR, responsibility falls on:
-
Producers of packaged goods
-
Importers bringing packaged goods into the UK
-
Ecommerce businesses supplying directly to consumers
The main aim of EPR is to incentivise better packaging design and reduce environmental impact by making businesses financially accountable for waste.
When Did EPR Come Into Force?
EPR has been introduced in stages across the UK, mainly due to delays because of the pandemic and shifts in the political sphere. In late 2024, EPR legislation was formally made into law. On the 1st January 2025, the law officially came into force, and the following months saw the operational rollout begin. October 2025 was the start of paying waste disposal costs, where businesses started paying fees for waste disposal, or had a compliance scheme on their behalf to complete these invoices.
EPR is now fully operational, with reporting and fee obligations firmly in place. And it’s not just the UK that has implemented these regulations. Similar frameworks are expanding globally, with developments underway in the EU, US and Canada, where packaging regulations are becoming increasingly stringent.
When Do EPR Fees Start?
EPR fees for packaging began in October 2025, with the first reporting deadline for packaging data set at 1st April 2026. Looking ahead, a modulated fee structure is expected in 2026/27, which will adjust costs based on how recyclable your packaging is. This means businesses using more sustainable, easily recyclable materials could benefit from lower fees.
What Is EPR Packaging?
EPR covers a wide range of packaging materials placed on the UK market, regardless of whether they are used for shipping, retail or product protection.
The most common examples include:
-
Plastic packaging - mailers, films and containers
-
Paper and cardboard - boxes, envelopes, inserts and void fills
-
Glass and metal packaging
-
Composite or mixed-material packaging
What matters under EPR is not just the material itself, but how it performs within the UK’s recycling infrastructure. Packaging is assessed based on how easily it can be collected from households or businesses, whether it can be sorted efficiently and whether it can be successfully recycled at scale. This means two materials that appear similar may be treated very differently under EPR depending on how widely they are recycled in practice.
Understanding EPR Packaging Categories (Red, Amber, Green)
To support fee modulation, packaging is categorised based on its recyclability, and data must be broken down by material and packaging format.
-
Green - widely recyclable and easily processed within UK systems
-
Amber - recyclable but materials might not be accepted everywhere and are generally harder to process
-
Red - difficult or uneconomical to recycle, often leading to disposal rather than recovery
Packaging formats can be broken down into distinct categories too, including:
-
Primary - packaging that’s in direct contact with the product
-
Secondary - used to group products for display or handling
-
Shipment - packaging for delivering goods to consumers and used by ecommerce businesses
-
Tertiary - pallets, crates and other packaging used in transport and logistics
A crucial nuance is that “eco-friendly” does not always mean “low cost” under EPR. For example, some biodegradable or compostable materials may not be accepted in standard recycling streams. Also, certain mixed-material designs can be difficult to separate and process.
As a result of this, businesses need to look beyond marketing claims and focus on how packaging performs within real-world recycling systems.
How EPR Affects Your Business
EPR has wide-ranging implications for businesses that go beyond simple compliance.
Firstly, packaging that is harder to recycle will result in higher EPR fees, which can significantly impact margins, particularly for high-volume businesses.
As mentioned above, one of the key changes is the expansion of reporting obligations under EPR regulations. Smaller businesses that were previously exempt must now track packaging data and submit annual reports, while larger organisations are required to report every six months. This has increased the need for stronger internal processes and data management systems to maintain compliance.
Also, missing report deadlines or submitting incorrect data can lead to enforcement action, making compliance a business-critical function. Your responsibilities depend on factors such as annual turnover and how much packaging you handle.
How to Meet EPR Targets
Meeting EPR targets, standards and requirements is not just about compliance. EPR is a great incentive and opportunity to improve efficiency and reduce long-term costs.
Key actions you should implement include:
-
Reducing excess packaging - eliminate unnecessary layers and materials to lower both usage and costs
-
Switching to more recyclable materials - prioritise materials that are widely accepted in UK recycling systems
-
Improving packaging design - avoid complex or mixed material formats that are harder to process
-
Implementing accurate tracking systems - ensure you can confidently report packaging data and respond to audits
Taking these steps early can help future-proof your business as EPR evolves.
Common Mistakes Businesses Are Making with EPR
Businesses that are falling behind on EPR requirements are facing some quite drastic consequences. Avoid these mistakes to ensure compliance, reduced costs and better preparation.
-
Assuming all sustainable packaging is compliant - not all “green” materials perform well under EPR criteria
-
Poor data tracking - incomplete or inaccurate data can lead to compliance issues and incorrect fee payments
-
Underestimating costs - some businesses have not yet accounted for how significant EPR fees can become
-
Delaying preparation - waiting until deadlines approach can result in rushed decisions and higher costs
How to Prepare for EPR Changes Now
If your business is struggling to meet EPR packaging standards, or hasn’t fully adapted yet, taking action now is essential. Start by auditing your current packaging, identifying what materials you use and in what volumes. Get a full understanding of how your packaging is likely to be categorised under EPR and plan in advance for any cost increases over the coming years.
At SR Mailing, we supply a range of sustainable packaging solutions and have had to navigate Extended Producer Responsibility standards ourselves ever since they came into law back in 2024. We can help you review your packaging, understand your obligations and help identify practical ways to stay compliant while managing costs. Get in touch today to ensure your business is compliant with EPR standards.
