Managing packaging compliance across the UK and EU? The UK operates a separate packaging EPR scheme outside the EU PPWR framework. This page focuses specifically on UK packaging EPR — who is in scope, what must be reported, how PackUK fees work, and how the UK system differs from EU country-level packaging EPR obligations.

What is UK packaging EPR?

The UK’s packaging Extended Producer Responsibility scheme — usually shortened to pEPR — places the cost of managing household packaging waste on the businesses that place that packaging on the UK market.

The current UK scheme is based on the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 and subsequent amendments. It changes how packaging waste disposal costs are recovered from producers, while recycling obligations through PRNs and PERNs may still apply where relevant.

The scheme is administered by PackUK, hosted by Defra and appointed jointly by the four UK nations. PackUK is responsible for setting producer fees, issuing Notices of Liability, managing payments and overseeing scheme operation. Enforcement is carried out by the relevant UK environmental regulators.

Producer registration, packaging data reporting and related submissions are managed through the Report Packaging Data (RPD) service on GOV.UK.

Who must comply with UK pEPR?

UK pEPR uses a producer-threshold model. A business is in scope if it meets both a turnover threshold and a packaging-volume threshold in the relevant assessment period.

Large producers

Large producers are generally businesses with annual turnover of £2 million or more that supply or import more than 50 tonnes of packaging to the UK market. Large producers have the broadest obligations, including registration, data reporting, waste-disposal-fee payment and recycling-obligation management where relevant.

Small producers

Small producers are generally businesses with annual turnover of £1 million or more that supply or import more than 25 tonnes of packaging, but do not meet the large-producer thresholds. Small producers have lighter obligations than large producers, but still need to understand registration and reporting requirements.

Roles in scope

The obligated party depends on the supply-chain role and the packaging activity. Relevant roles can include:

• Brand owners
• Packers and fillers
• Importers placing packaged goods on the UK market
• Distributors selling unfilled packaging
• Service providers using packaging in hospitality, takeaway or similar settings
• Online marketplaces, including specific responsibilities for non-UK third-party sellers

Identifying the correct obligated party is one of the most common error points. A business should not assume that an upstream supplier, marketplace or fulfilment provider automatically carries the obligation.

Compliance schemes: what they can and cannot do.

UK packaging compliance schemes can support producers with registration, data reporting and recycling-obligation management. They can register producers with the environmental regulator and report packaging data on their behalf.

However, compliance schemes cannot sign a producer up to the RPD service and cannot pay the producer’s waste-disposal fees. Waste-disposal-fee invoices, known as Notices of Liability, are issued to the producer and must be paid by the producer.

This is an important shift from how many businesses historically thought about packaging compliance. Under UK pEPR, schemes may provide data and compliance support, but financial responsibility for disposal fees remains directly with the producer.

When choosing a compliance scheme, businesses should consider:

• Scheme fees and service scope
• Support with RPD data preparation
• Experience with the producer’s product and packaging categories
• Support with PRN/PERN recycling obligations where relevant
• Ability to help with RAM-based recyclability assessment
• Reporting workflow, data validation and audit support

UK pEPR data reporting through RPD.

The Report Packaging Data service is the central route for UK pEPR data submissions. Producers, or compliance schemes acting on their behalf where permitted, need to report packaging data in the format required by the UK scheme.

Packaging data reporting may include:

• Packaging activity type, such as brand owner, importer, packer/filler or service provider
• Packaging material type, such as paper, board, plastic, glass, aluminium, steel, wood or fibre-based composites
• Tonnage placed on the UK market
• Household or non-household packaging classification
• Recyclability assessment data under the RAM
• Self-managed packaging and shipment packaging where relevant
• Nation data where applicable, subject to current regulator guidance

Reporting schedule

• Large producers: generally report packaging data every six months.
• Small producers: generally report packaging data annually.
• Nation data: reported annually where applicable, subject to current regulator guidance.

Reports should be prepared on time even where internal data is still being reconciled. Missing, late or poor-quality submissions can create regulator queries, correction work and enforcement risk.

Disposal fees, the RAM and fee modulation.

Waste-disposal fees are calculated by PackUK and are designed to recover the costs of managing household packaging waste. Large producers are the key group exposed to these fees.

Year 1: base fees

The first year of UK pEPR disposal fees uses base fees by material type. Recyclability-based modulation does not apply in the first year. PackUK publishes base fee information for materials such as aluminium, fibre-based composite, glass, paper and board, plastic, steel, wood and other material categories.

Year 2 onwards: modulated fees under the RAM

From the 2026 to 2027 financial year, disposal fees move toward modulation based on recyclability. The UK uses the Recyclability Assessment Methodology, known as the RAM, to assess packaging recyclability.

Packaging is rated as:

• Green: recyclable at scale across the UK
• Amber: partially recyclable or requiring improvement
• Red: not recyclable at scale

Red-rated packaging modulation

PackUK’s modulation approach applies increasing fee pressure to Red-rated packaging over time. Red-rated packaging is expected to face escalating multipliers:

• 2026/27: 1.2× base fee
• 2027/28: 1.6× base fee
• 2028/29: 2.0× base fee

The practical implication is significant. Improving a Red-rated packaging component to Amber or Green can reduce future fee exposure, especially across high-volume SKUs.

Notices of Liability and payment risk.

PackUK issues Notices of Liability to liable producers. These notices set out the producer’s waste-disposal-fee liability and payment requirements.

A Notice of Liability should be treated as a formal compliance and finance document. Businesses should check the underlying data, confirm material and tonnage assumptions, review any dispute route, and ensure payment responsibilities are clear internally.

Businesses should prepare for:

• PackUK fee notices and internal approval workflows
• Review of data behind the fee calculation
• Reconciliation with RPD submissions
• Dispute handling where there are reasonable grounds
• Clear finance ownership for payment deadlines
• Evidence retention for future regulator or PackUK queries

Penalties and enforcement.

UK pEPR is enforced by the relevant environmental regulators across the UK. Non-compliance can lead to enforcement action, including civil sanctions, variable monetary penalties, late-payment consequences and, in serious cases, prosecution.

Areas that can trigger compliance risk include failure to register, failure to report, poor-quality data, failure to pay waste-disposal fees, and failure to maintain adequate records.

The public nature of producer registration and the increasing customer focus on packaging compliance also create commercial and reputational risk. Buyers, retailers, marketplaces and business partners may ask for evidence that a company is managing its UK pEPR obligations.

How UK pEPR differs from EU packaging EPR.

For businesses managing packaging compliance across both the UK and the EU, the schemes may look similar at first but operate differently in practice.

Key differences include:

• Single UK scheme administrator: UK pEPR is administered through PackUK and RPD, while EU countries each have their own national EPR systems and producer responsibility organisations.
• Producer thresholds: the UK has small and large producer thresholds, while many EU markets apply packaging EPR obligations with limited or no practical threshold exemptions.
• Direct producer invoicing: UK waste-disposal fees are invoiced to the producer by PackUK, while many EU systems collect fees through PRO membership.
• Reporting cadence: UK large producers generally report twice yearly, while many EU markets use annual reporting cycles.
• RAM-based modulation: the UK uses Green, Amber and Red RAM ratings, while EU countries apply their own national modulation or fee structures.
• Marketplace provisions: the UK has specific marketplace responsibilities, especially for non-UK sellers, which need to be assessed separately from EU rules.

Multinational sellers should treat UK pEPR and EU EPR as connected but distinct workstreams. The underlying packaging data may overlap, but the reporting logic, fee mechanisms, deadlines and legal roles do not fully transfer.

How businesses should prepare for UK pEPR.

The most effective preparation is structural rather than reactive. Businesses should build a repeatable packaging data and evidence process that can support RPD reporting, RAM assessment, PackUK fee review and wider EPR/PPWR obligations.

Practical preparation steps include:

• Map all packaging placed on the UK market by material, component, weight and supply-chain role
• Identify the in-scope legal entity, especially in multi-entity groups
• Assess small or large producer threshold position annually
• Set up RPD access and decide whether to use a compliance scheme
• Build RAM recyclability assessment at SKU or packaging-component level
• Establish reporting workflows with internal validation before submission
• Forecast disposal fees by material category and assess Red-rated packaging exposure
• Track PackUK fee schedules, modulation policy statements and RAM updates

How RegSurance can help with UK pEPR.

RegSurance supports businesses with UK packaging EPR requirements, including producer threshold assessment, RPD reporting readiness, compliance scheme route review, RAM-aligned recyclability assessment, waste-disposal-fee forecasting and evidence management.

For companies selling across both the UK and EU, RegSurance can help create a joined-up packaging compliance structure so that UK pEPR, EU EPR and PPWR obligations are managed through one coherent packaging data and evidence model.

FAQs

Do foreign companies need to comply with UK packaging EPR?

Foreign companies may need to assess UK packaging EPR where they place packaged goods on the UK market. This is especially relevant for importers, marketplace sellers, ecommerce sellers and businesses supplying UK customers directly.

What is RPD?

RPD means Report Packaging Data. It is the GOV.UK service used for UK packaging EPR reporting and related producer data submissions.

What is PackUK?

PackUK is the UK scheme administrator for packaging EPR. It is hosted by Defra and is responsible for areas such as producer fees, Notices of Liability, payments and scheme operation.

Do compliance schemes pay UK pEPR disposal fees?

No. Compliance schemes can support registration and data reporting, but they cannot pay a producer’s waste-disposal fees. Producers must pay PackUK directly.

When do modulated fees start?

Fee modulation based on recyclability starts from the 2026 to 2027 financial year, using RAM-based recyclability ratings. Red-rated packaging faces increasing fee multipliers over time.

What is the biggest UK pEPR mistake?

The biggest mistake is treating UK pEPR as just another EU-style PRO registration. The UK has different thresholds, reporting cadence, direct PackUK invoicing, RAM-based modulation and specific marketplace considerations.

Disclaimer: This page provides general informational guidance on UK packaging Extended Producer Responsibility and does not constitute legal or regulatory advice. UK pEPR is evolving, and fee schedules, RAM methodology, modulation policy, regulator guidance and threshold application may change. Businesses should verify current obligations against official PackUK, GOV.UK and regulator publications before relying on any compliance approach.